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

[Scott Leibrand]

No, this draft policy is not merely a clarification. This would a
significant change in policy, and if enforced would significantly interfere
with the efficient operation of the Internet.

ARIN should only care whether addresses are in use on an operational
network. They have no reason to care about the connectivity, or lack
thereof, between an LIR and operational networks that it reallocates or
reassigns space to.

I run an operational network. We still use a number of address blocks
originally allocated to us by our transit providers before we acquired our
own space, which we have always announced in BGP in a multihomed fashion.
If we stop announcing the route to the transit provider who announced us
the space, whether temporarily (due to an outage or maintenance) or more
permanently (because we no longer need transit from them there), we should
be able to continue using our assigned space as long as we have appropriate
contractual arrangements in place to do so. That is a form of "leasing"
that has always been allowed, and this policy would disallow it.

Any policy requiring a certain form of connectivity between an LIR and its
customers will either be unenforceable and easily gamed, or onerous,
bureaucratic, and will interfere with the legitimate operation of networks
efficiently utilizing their IPv4 space.

-Scott

On Wed, Aug 24, 2022 at 9:32 AM Fernando Frediani <fhfrediani at gmail.com>
wrote:

> Hello Scott
>
> Could you explain better the arguments you are against in this proposal or
> that don't sound valid?
>
> All this proposal does is to make clear make something clear in the policy
> text.
> If you cannot go to ARIN and justify that you intend to use requested IP
> addresses for simple leasing proposes, to be leased to organization with
> who you don't provide any connectivity services, why would it be an
> accepted thing in any other scenario ?
> IP space is to be used for building Internet infrastructure and to get
> customers connected to the Internet, not to be simply leased from one
> organization pretending to be a RIR to another.
>
> Unless I misunderstood and you like the idea of leasing and so why you
> oppose this proposal.
>
> Regards
> Fernando
> On 24/08/2022 12:40, Scott Leibrand wrote:
>
> 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> <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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