[arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Mike Burns]

Hi Bill,

I understand there are ways to effectively circumvent ARIN policy through legal relationships.
But it's just simpler to create a thin VPN or to operate out of the RIPE RIR.
My point is that ARIN policy doesn't prevent leasing, it only restricts lessors to incumbent holders and thwarts newcomers. And current policy doesn't seem to have broken anything.

You can't go to ARIN and simply predict you will have X customers within two years and receive transfer pre-approval. The same rules would apply here, the same initial block size and protections, everything in justification remaining the same as it is for those who used to be called ISPs. Except historically ISPs could use their SWIPed addresses to show utilization only if they were connected to their clients by a circuit. They still have to be real clients, they still have to deployed on an operating network, they will still be required to submit evidence of that to ARIN.

Regards,
Mike


-----Original Message-----
From: William Herrin <bill at herrin.us> 
Sent: Friday, March 11, 2022 12:28 PM
To: Mike Burns <mike at iptrading.com>
Cc: PPML <arin-ppml at arin.net>
Subject: Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

On Fri, Mar 11, 2022 at 6:25 AM Mike Burns <mike at iptrading.com> wrote:
> Are you against all renting of IPv4 addresses, and if so, why?
> Or are you against only non-incumbent owners renting space?

Hi Mike,

I would suggest that if you really want to lease addresses without infrastructure there are lawful and compliant ways to do so without change to ARIN policy. For example:

The broker and user of the addresses might form a legal partnership.
The address user would have the right to terminate its participation in the partnership comparable to a lessor's terms for ending a lease.
The broker would have the right, upon termination of the partnership, to resell the numbers compliant with ARIN rules and would retain the proceeds of such sale.
Finally the partnership, including both the practicing user and the purchasing broker, would request addresses through ARIN and, upon approval, purchase them on the open market. Because the partnership is, in fact, deploying a network which uses the addresses, such a use is compliant with ARIN policy.

While more complicated than a simple lease agreement, such a process would assure compliance with the community's then-extant number policies. In particular, the actual user of the addresses would be evaluated by ARIN and would have to qualify.

Even were I to find such "leasing" objectionable, I would have no cause for objection under current ARIN policy.

I note that once the initial template development is complete, instancing such legal partnerships is of trivial cost.

Regards,
Bill Herrin


--
William Herrin
bill at herrin.us
https://bill.herrin.us/