[arin-ppml] Change of Use and ARIN (was: Re: AFRINIC And The Stability Of The Internet Number Registry System)

Fernando Frediani fhfrediani at gmail.com
Thu Sep 2 08:16:11 EDT 2021


Exactly, the right to review is a principle in place and if triggered 
the resource holder must explain again if he still justify to maintain 
those resources.

I don't see a need to report any changes afterwards the resources were 
assigned by the RIR, *as long they keep being used according to the 
current policies*. If however the RIR call that organization for a 
review, they must be able to explain themselves at anytime. This is in 
the interest of all.

Now, can IP leasing be a justified need one can give to the RIR in order 
to have some IP space allocated ? Could ever an organization go to the 
RIR and say: "Please give me more IP space as I am going to use them to 
lease to other organizations that have the ability to get them directly 
from the RIR" ?

IP leasing isa real mockery to those who effectively build Internet 
infrastructure and bring connectivity to people in general and those who 
justify for receiving IP allocations. What is the point to pretend it is 
Ok to accept it as a 'normal' practice?
If an organization is able to justify and get IP addresses allocated 
directly by the RIR, accepting people's leasing practices only force 
organization who really justify for those IP addresses to have to pay 
more pay more to a middleman that most possible doesn't built any 
internet infrastructure if they could just be paying ARIN or any RIR's 
administrative fees directly and get those resources directly from there.

Therefore if some organization who received a chunk of addresses in the 
past based in a justification they had to build Internet sudden starts 
to lease those addresses they should go immediately under a revocation 
process as they no longer justify for them. Either they use them  for 
the proposes they justified or give them back to the RIR so the RIR can 
allocate to others  who really justify.

Transfer of resources (even if there is a transaction in the background) 
is something different and fine in the current scenario as it 
facilitates the resources goes to those who really justify for them.

Fernando


Em 01/09/2021 17:35, Chris Woodfield escreveu:
> David -
>
> In addition to the RSA language John cited, Section 12 of the NRPM 
> gives ARIN the right to review an organization’s resource usage at any 
> time for continued  compliance with community-driven policy. I suspect 
> that these reviews are not common, however. What’s more common, in my 
> view, is an organization’s request for additional resources, which 
> must come with justification that currently-held resources are being 
> used in compliance with policy. I do not believe that these are 
> checked against the original requests for consistency, however.
>
> I’d be curious if the clause below can be interpreted as giving 
> organizations a duty to report *any* substantial changes in an 
> organization’s allocation plans if they diverge from the justification 
> filed at the time of the request, or only when such changes would have 
> the effect of putting the organization out of compliance with current 
> policy. I can see the former interpretation being rather troublesome 
> for a large number of organizations, given how often business plans 
> and environments can change over time, as well as adding quite a bit 
> of (IMO unnecessary) overhead to IP allocation managers.
>
> That said, I can see ARIN being quite justified in reclaiming 
> resources if the justification documentation filed with the request 
> had no bearing to the org’s actual plans. I suspect that to be the 
> unspoken subtext of the current controversy, and I absolutely believe 
> that ARIN would and should act similarly in such a scenario (which, in 
> the past, it has).
>
> Regards,,
>
> -Chris
>
>> On Sep 1, 2021, at 1:21 PM, John Curran <jcurran at arin.net 
>> <mailto:jcurran at arin.net>> wrote:
>>
>> David -
>>
>> Excellent question.   The most important item is for the community to 
>> determine its policy goals in this area, and then based on such what 
>> requirements/duties belong in policy language in Number Resource 
>> Policy Manual (NRPM.)
>>
>> The ARIN RSA places an explicit duty of “Information and Cooperation” 
>> on number resource holders (see below) that can be used to enforce 
>> community-developed policy in this area, but the communities thoughts 
>> on the appropriate policy really should drive the discussion –
>>
>>     /2.(c) Information and Cooperation. Holder has completed an
>>     application provided by ARIN for one or more Services (the
>>     “Application”). Holder must (i) promptly notify ARIN if any
>>     information provided in the Application changes during the term
>>     of this Agreement, and (ii) make reasonable efforts to promptly,
>>     accurately, and completely provide any information or cooperation
>>     required pursuant to the Service Terms or in response to any
>>     inquiry or request made to Holder by ARIN during the term of this
>>     Agreement. In addition, Holder shall promptly provide ARIN with
>>     complete and accurate information, and cooperation as required by
>>     any Service Terms or that ARIN requests in connection with ARIN’s
>>     provision of any of the Services to Holder. If Holder does not
>>     provide ARIN with such information or cooperation that ARIN
>>     requests, ARIN may take such failure into account in evaluating
>>     Holder’s subsequent requests for transfer, allocation or
>>     assignment of additional number resources, or requests for
>>     changes to any Services. /
>>
>> Note that material breach of Section 2(c) is one of the events that 
>> provides ARIN clear right of termination for the RSA and subsequent 
>> revocation of the number resources – so let’s be extra careful when 
>> considering any reporting/information duties for placement into NRPM.
>>
>> Thanks!
>> /John
>>
>> John Curran
>> President and CEO
>> American Registry for Internet Numbers
>>
>>
>> On 1 Sep 2021, at 3:47 PM, David Farmer <farmer at umn.edu 
>> <mailto:farmer at umn.edu>> wrote:
>>>
>>> I changed the subject line, as this isn't directly related to the 
>>> dispute between AFRINIC and CI, but more some questions arising from 
>>> it specifically related to the ARIN registered resources.
>>> ----
>>>
>>> So, do ARIN resource holders have a duty to report changes in their 
>>> use of resources? If they do, where does that duty come from in 
>>> policy or contract language? And, what are the relevant changes that 
>>> need to be reported?
>>>
>>> In my review of these questions;
>>>
>>> In the RSA I see where holders are granted, "The right to use the 
>>> Included Number Resources within the ARIN database" (RSA section 2.b 
>>> bullet 2). However, I don't see any limitation to that use, such as 
>>> "originally justified" or any obligation to report a change in such use.
>>>
>>> In policy, "An end-user is an organization receiving assignments of 
>>> IP addresses exclusively for use in its operational networks." (NRPM 
>>> 2.6), with an exception for incidental or transient use (last 
>>> paragraph, section 2.5).
>>>
>>> Maybe to align end-user requirements with the new Registration 
>>> Services Agreement we should change that so end-users have to report 
>>> any use, other than incidental or transient use, outside their 
>>> organization.
>>>
>>> And ISP's have requirements to report the use by their customers 
>>> that exceed certain levels (NRPM sections 4.2.3.7 and 6.5.5).
>>>
>>> So, other than the ISP reporting requirements, I don't see direct 
>>> reporting obligations for change in use. Further, I don't see any 
>>> guidance to what might be a material change in use that is in need 
>>> of reporting, as I'm sure we don't want ARIN Staff tied up with 
>>> reports of all possible changes, most of which are probably irrelevant.
>>>
>>> Are there reporting requirements I'm missing? Maybe implied or 
>>> indirect requirement?
>>>
>>> Should something be added to ARIN's policies explicitly stating 
>>> requirements for reporting a change in the use of resources?
>>>
>>> Thanks
>>
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