[arin-ppml] Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilizatio

John Santos john at egh.com
Mon Aug 8 16:48:28 EDT 2022

I found the policy and original problem statement confusing because the verb 
"lease" is ambiguous.  It can refer to leasing something FROM someone else or to 
leasing something TO someone else.

I read the problem statement as describing a situation where someone has some 
amount of IP space allocated to them but has an operational need for more space. 
  They are leasing additional space from a third party as a temporary measure, 
but would like to increase their allocation to cover their actual needs, but 
ARIN wasn't letting them use that leased space as evidence of need.  (Maybe this 
isn't actually an issue and any organization in such a situation would easily 
meet the needs requirements?)  But if this is the situation the policy is 
attempting to address and it is a real problem, I would support the proposal.

However, it appears this policy is addressing the other situation, an 
organization already has more space than it needs and is leasing out their extra 
space to third parties.  (The key word here is "leased-out".)  I don't see how 
allowing them to obtain additional space in any way qualifies as "needs based". 
  They already have more than they need, or they wouldn't be leasing it out.


On 8/8/2022 3:11 PM, Andrew Dul wrote:
> ARIN Draft Policy 2021-6 was retitled earlier this year as “Permit IPv4 Leased 
> Addresses for Purposes of Determining Utilization for Future Allocations” and 
> the text was also updated based upon feedback from the community at the Fall 
> 2021 meeting.
> https://www.arin.net/participate/policy/drafts/2021_6/
> The draft did not receive sufficient support in the shepherds opinion to move 
> this policy toward a recommended draft policy. Since this time the shepherds 
> have been discussing with various members of the Internet Community and the ARIN 
> AC on a possible path forward for this draft policy.
> One of the ideas was to take a look at the problem statement and perhaps update 
> and clarify the problem statement in hopes that this process would provide 
> additional ideas to move the process forward.
> The current draft policy problem statement is as follows:
> Problem Statement: Current ARIN policy prevents the use of leased-out addresses 
> as evidence of utilization.
> Some contributors have suggested that there are perhaps two or more issues that 
> are attempting to be solved here.
>      Organizations would like the ability to lease some of their address space 
> and not limit the receipt of future IPv4 transfers due the fact that ARIN’s 
> evaluation of utilization considers leased space today to be unused.
>      Organizations who wish to obtain address space are not able to pledge the 
> address space as collateral in a financial transaction.  The RSA and ARIN policy 
> today limit the ability of IPv4 address resources to be transferred to another 
> party (financier) without that party showing need for use on an operational 
> network.
> We invite your feedback on these thoughts and ideas to help us rework the 
> problem statement and future policy language solving these issues.
> In particular, do you believe the problem statement needs to be rewritten to 
> clarify the issue the Internet Community is trying to solve here?
> If so, what problem or problems do you believe that the Internet Community needs 
> to solve and what problem statement(s) make sense to restart the conversation 
> around this topic?
> Thanks in advance for your feedback,
> Andrew
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John Santos
Evans Griffiths & Hart, Inc.
781-861-0670 ext 539

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