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

Sat Sep 10 13:01:17 EDT 2022

Fernando,

Your proposal says leasing is banned at other RIRs.

I am telling you once again that leasing is NOT banned at RIPE and leased addresses CAN be used as justification at RIPE. 

I speak from direct experience.

And once again there is no policy nor contract requirement to utilize addresses at ARIN for their originally intended purposes, ergo leasing is not prohibited to address holders at ARIN.

Please define the word leasing as that impacts enforcement and other issues.

This proposal remains deeply flawed.

So I remain deeply opposed.

Regards,

Mike

---- On Fri, 09 Sep 2022 12:44:10 -0400 Fernando Frediani <fhfrediani at gmail.com> wrote ---

Hello

There is no such error in the proposal.
 This has been checked as being the interpretation staff gives to
      the current policy in most RIRs. APNIC is just an example that
      have confirmed it publicly a couples of days ago. 
 You may not find all the very specific words you may wish for in
      the text, but it is not much difficult for them to have such
      interpretation given the resources must follow a proper
      justification of what they will be used for and that can never be
      that you will use them for leasing (rent of lend). ARIN also
      already confirmed in this very same list they don't accept it as a
      justification.

There is no much around the term leasing. If an organization who
      don't provide any connectivity services to another simply rent or
      lend IP space, with or without a cost associated that is something
      that must not be since they no longer have a justification to keep
      that IP space and instead should either transfer it to those who
      really justify or return to ARIN.

Fernando

On 24/08/2022 11:04, Mike Burns wrote:

Opposed, I think the proposal contains
          errors that should be fixed before the discussion proceeds.

For example this statement :

“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.”

If it is not in their
            policy manuals, how can the proposers state leasing is not
            authorized?

Where do the
            proposers think authority comes from, if not from policy and
            contract?

Are they just
            assuming that all things are prohibited unless they are
            explicitly allowed?

That would be an
            interesting way to read the policy manual, if that is the
            belief, we should discuss that.

Beyond that there is
            the very next sentence:

” Nothing is
            currently mentioned in RIPE about this and it is not
            acceptable as a justification of the need. “ 

Once again the bias is towards prohibition
          despite language about leasing being absent from RIPE policy.
          More to the point, and something that can’t be drummed-home
          clearly enough to this community, RIPE has no needs test at
          all for transfers and hasn’t for years.  And yet RIPE still
          exists and operates as an RIR.  Even further to the point, in
          the one occasion that RIPE performs a needs-test, which is on
          inter-regional transfers from ARIN, leased-out addresses are
          in fact acceptable as justification. That’s because of two
          logical things. First, RIPE understands that the inherent
          value of the addresses drives them towards efficient use.
          Second, RIPE understands that they are charged with getting
          addresses into use, not getting them into use on particular
          networks.

So the first two sentences in the
          “situation at other RIRs” are problematic/false.

Might I suggest fixing those before we move
          forward, and also can you please define the word leasing?

This seems poorly though-out to me, and I
          haven’t started on the meat of the proposal yet nor how it
          would be effectively policed and prohibited.

Regards,
 Mike

From: ARIN-PPML mailto:arin-ppml-bounces at arin.net On Behalf Of ARIN
 Sent: Tuesday, August 23, 2022 12:29 PM
 To: PPML mailto:arin-ppml at arin.net
 Subject: [arin-ppml] Draft Policy ARIN-2022-9:
              Leasing Not Intended

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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