[arin-ppml] Draft Policy ARIN-2021-6: Remove Circuit Requirement

[Chris Woodfield]

I’m speaking to the risk that an organization that engages in leasing address blocks without providing related connectivity services. Given that these blocks cannot currently be used as justification for additional space, an organization that does so would not qualify for additional space should they require it, unless they are falsifying the nature of the allocations in their justification documentation (which, of course, is a policy violation that could lead to that organizations’s allocations being reclaimed if discovered).

This policy proposal, per the problem statement, is explicitly aimed at removing that risk, and as such, putting ARIN’s stamp of approval on this type of lease practice, and in fact, allows organizations to require additional space which it could then lease out, without the need to provide the network services associated with the blocks being leased. Which is a type of IP block monetization that I simply cannot stand behind.

As such, I remain opposed to this proposal.

-C

> On Sep 22, 2021, at 7:00 AM, Mike Burns <mike at iptrading.com> wrote:
> 
> Hi Chris,
>  
> Can you be more specific on which inherent risk this policy would remove?
> Somebody +1’d this, but I don’t understand what you mean.
> I don’t even know which party’s risk is being commented on.
>  
> Regards,
> Mike
>  
>  
> From: ARIN-PPML <arin-ppml-bounces at arin.net> On Behalf Of Chris Woodfield
> Sent: Tuesday, September 21, 2021 9:21 PM
> To: Owen DeLong <owen at delong.com>
> Cc: PPML <arin-ppml at arin.net>
> Subject: Re: [arin-ppml] Draft Policy ARIN-2021-6: Remove Circuit Requirement
>  
>  
>> On Sep 21, 2021, at 10:22 AM, Owen DeLong <owen at delong.com <mailto:owen at delong.com>> wrote:
>>  
>> This policy doesn’t affect that… Leasing of address space you already have is permitted under current policy and cannot be grounds for revocation of address space.
>>  
>> The change in this policy proposal is not to permit or deny leasing, but to permit leased addresses to be considered utilized for purposes of determining eligibility for additional address acquisition.
>>  
>  
> You are correct that the proposal may not permit or prohibit leasing, but it does (intentionally, per the problem statement) remove one of the inherent risks of the practice, and as such, in my view, is effectively an endorsement. 
>  
> As such, my opposition stands.
>  
> -C
> 
> 
>> Owen
>>  
>> 
>> 
>>> On Sep 21, 2021, at 08:22 , Chris Woodfield <chris at semihuman.com <mailto:chris at semihuman.com>> wrote:
>>>  
>>> Writing in opposition. I do not support the practice of leasing IP address resources. Organizations who have received larger amounts of IP address space than what they are efficiently utilizing are free to relieve themselves of their excess space via the transfer market.
>>>  
>>> Thanks,
>>>  
>>> -Chris
>>> 
>>> 
>>>> On Sep 21, 2021, at 8:06 AM, ARIN <info at arin.net <mailto:info at arin.net>> wrote:
>>>>  
>>>> On 16 September 2021, the ARIN Advisory Council (AC) accepted "ARIN-prop-302: Remove Circuit Requirement " as a Draft Policy.
>>>>  
>>>> Draft Policy ARIN-2021-6 is below and can be found at:
>>>>  
>>>> https://www.arin.net/participate/policy/drafts/2021_6/ <https://www.arin.net/participate/policy/drafts/2021_6/>
>>>>  
>>>> You are encouraged to discuss all Draft Policies on PPML. The AC will evaluate the discussion in order to assess the conformance of this draft policy with ARIN's Principles of Internet number resource policy as stated in the Policy Development Process (PDP). Specifically, these principles are:
>>>>  
>>>> * Enabling Fair and Impartial Number Resource Administration
>>>> * Technically Sound
>>>> * Supported by the Community
>>>>  
>>>> The PDP can be found at:
>>>>  
>>>> https://www.arin.net/participate/policy/pdp/ <https://www.arin.net/participate/policy/pdp/>
>>>>  
>>>> Draft Policies and Proposals under discussion can be found at:
>>>> https://www.arin.net/participate/policy/drafts/ <https://www.arin.net/participate/policy/drafts/>
>>>>  
>>>> Regards,
>>>>  
>>>> Sean Hopkins
>>>> Senior Policy Analyst
>>>> American Registry for Internet Numbers (ARIN)
>>>>  
>>>>  
>>>> Draft Policy ARIN-2021-6: Remove Circuit Requirement 
>>>>  
>>>> Problem Statement:
>>>>  
>>>> Current ARIN policy prevents the use of leased-out addresses as evidence of utilization.
>>>>  
>>>> Policy statement:
>>>>  
>>>> Replace
>>>>  
>>>> “2.4. Local Internet Registry (LIR) A Local Internet Registry (LIR) is an IR that primarily assigns address space to the users of the network services that it provides. LIRs are generally Internet Service Providers (ISPs), whose customers are primarily end users and possibly other ISPs.”
>>>>  
>>>> with
>>>>  
>>>> “2.4. Local Internet Registry (LIR) A Local Internet Registry (LIR) is an IR that primarily assigns address space to users of the network. LIRs are generally Internet Service Providers (ISPs), whose customers are primarily end users and possibly other ISPs.”
>>>>  
>>>> Timetable for implementation: Immediate
>>>>  
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>>> 
>>>  
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