[arin-ppml] Draft Policy ARIN-2022-9: Leasing Not Intended
Fernando Frediani
fhfrediani at gmail.com
Fri Sep 9 12:42:42 EDT 2022
Hi Scott, what Internet operation exists there is no connectivity
provided by the resource holder to a customer ?
Unfortunately that's not quiet correct your assertion that simply ARIN
should only care whether addresses are in use on a operation network or
not. Above all they should care if resources are being utilized
according to the current policy and the need they were justified for.
If an organization who doesn't provide any connectivity services to
another and simply leases (rent or lend) address to be used for this
second one creates security issues, given that,*in the absence of
connectivity the member receiving the license to use the addresses does
not have immediate physical control to manage or filter these resources,
something that could potentially result in damages to the entire community.
Fernando
On 24/08/2022 14:26, Scott Leibrand wrote:
> 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>
>>> <mailto: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.
>>>
>>> _______________________________________________
>>> ARIN-PPML
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>>
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