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

Owen DeLong owen at delong.com
Thu Sep 2 16:46:59 EDT 2021



> On Sep 2, 2021, at 05:16 , Fernando Frediani <fhfrediani at gmail.com> wrote:
> 
> 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" ?
> 
> 
The following justification:

	“We [will] use the addresses to number X internet-connected hosts on our own infrastructure and Y internet-connected hosts on our Z customers’ networks.”. 

meets the letter of the policy requirements in both thin the ARIN region and the AFRINIC region.

Please show me language in either policy manual which would allow the RIR to reject that justification simply because the customers are not receiving connectivity services from the LIR in question. If you cannot point to specific policy language that covers this, then yes, leasing is permitted and can be a justified need.

In fact, every LIR on the planet is engaged in address leasing. Most of them provide some connectivity service along with the lease, but there are plenty of commercial arrangements where an ISP is still allowing a customer to pay to keep their address space after terminating their connectivity services with that provider. There’s really no difference between these arrangements and leasing. In fact, eve if you include the lease inside of a connectivity contract, it’s still a lease. As such, the vast majority of addresses are actually justified on the basis of an intent to lease them. The difference is merely the nature of the commercial terms of the lease and the presence or absence of connectivity services in parallel to said lease.

> IP leasing is a 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.
> 
Is it? It seems to be facilitating quite of few such organizations to do exactly that with a lower up-front capital outlay for address acquisition. If it didn’t make economic sense for them to lease the addresses they need, why would they do that instead of purchasing them outright?

Is it really the role or job of an RIR to enforce or dictate the commercial terms of an address transaction between consenting parties?
> 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.
> 
I suppose there are number of questions that would have to be asked here…

	Does operating a VPN service count as “building internet”?
	If the leasing provider stood up VPNs to all of its clients who were then multi homed to the leasing provider and other providers
		they peered with or acquired transit from and the leasing provider announced only the aggregates while the customers
		announced the more specifics everywhere else, would that make a difference to how you characterize the situation?
	If that’s true, then what actual difference is there in reality?
	Isn’t the goal of the RIRs to ensure that the addresses are being used according to technical need and efficiency?
	If so, how does leasing contradict this goal?
> 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.
> 
Please explain how the distinction between leasing addresses in conjunction with a connectivity service vs. leasing addresses without providing connectivity to the same customer constitutes a violation of any RIR’s actual written policy. Please provide specific references to the policies in question so that your assertions can be verified.

If you can’t do that, then most of your argument really falls apart.

Owen

> 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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>> 
>> 
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