[arin-ppml] Draft Policy ARIN-2022-9: Leasing Not Intended

[Scott Leibrand]

Opposed. There is no good reason I am aware of for ARIN to require the bundling of IP addressing and connectivity services. The arguments provided in this draft policy are not sound or valid ones.  

Scott

> On Aug 23, 2022, at 9:28 AM, ARIN <info at arin.net> wrote:
> 
> 
> On 18 August 2022, the ARIN Advisory Council (AC) accepted "ARIN-prop-308: Leasing Not Intended" as a Draft Policy.
>  
> Draft Policy ARIN-2022-9 is below and can be found at:
>  
> https://www.arin.net/participate/policy/drafts/2022_9/
>  
> You are encouraged to discuss all Draft Policies on PPML. The AC will evaluate the discussion 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/
>  
> Draft Policies and Proposals under discussion can be found at: https://www.arin.net/participate/policy/drafts/
>  
> Regards,
>  
> Sean Hopkins
> Senior Policy Analyst
> American Registry for Internet Numbers (ARIN)
>  
>  
> Draft Policy ARIN-2022-9: Leasing Not Intended
>  
> Problem Statement:
>  
> “IPv6 Policy (section 6.4.1.) explicitly mention that address space is not a property. This is also stated in the RSA (section 7.) for all the Internet Number Resources.
>  
> However, with the spirit of the IPv4 allocation policies being the same, there is not an equivalent text for IPv4, neither for ASNs.
>  
> Further to that, policies for IPv4 and IPv6 allocations, clearly state that allocations are based on justified need and not solely on a predicted customer base. Similar text can be found in the section related to Transfers (8.1).
>  
> Consequently, resources not only aren’t a property, but also, aren’t allocated for leasing purposes, only for justified need of the resource holder and its directly connected customers.
>  
> Therefore, and so that there are no doubts about it, it should be made explicit in the NRPM that the Internet Resources should not be leased “per se”, but only as part of a direct connectivity service. At the same time, section 6.4.1. should be moved to the top of the NRPM (possibly to section 1. “Principles and Goals of the American Registry for Internet Numbers (ARIN)”.”
>  
> Policy statement:
>  
> Actual Text (to be replaced by New Text):
>  
> 6.4.1. Address Space Not to be Considered Property
>  
> It is contrary to the goals of this document and is not in the interests of the Internet community as a whole for address space to be considered freehold property.
>  
> The policies in this document are based upon the understanding that globally-unique IPv6 unicast address space is allocated/assigned for use rather than owned.
>  
> New Text
>  
> 1.5. Internet Number Resources Not to be Considered Property
>  
> It is contrary to the goals of this document and is not in the interests of the Internet community as a whole for address space to be considered freehold property.
>  
> The policies in this document are based upon the understanding that Internet Number Resources are allocated/assigned for use rather than owned.
>  
> ARIN allocate and assign Internet resources in a delegation scheme, with an annual validity, renewable as long as the requirements specified by the policies in force at the time of renewal are met, and especially the justification of the need.
>  
> Therefore, the resources can’t be considered property.
>  
> The justification of the need, generically in the case of addresses, implies their need to directly connect customers. Therefore, the leasing of addresses is not considered acceptable, nor does it justify the need, if they are not part of a set of services based, at least, on direct connectivity.
>  
> Even in cases of networks not connected to the Internet, the leasing of addresses is not admissible, since said sites can request direct assignments from ARIN and even in the case of IPv4, use private addresses or arrange transfers.
>  
> Timetable for implementation: Immediate
>  
> Situation in other Regions:
>  
> In other RIRs, the leasing of addresses is not authorized either and since it is not explicit in their policy manuals either, this proposal will be presented as well.
>  
> Nothing is currently mentioned in RIPE about this and it is not acceptable as a justification of the need. In AFRINIC, APNIC and LACNIC, the staff has confirmed that address leasing is not considered as valid for the justification.
>  
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