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

[Jon Lewis]

On Sat, 10 Sep 2022, Mike Burns wrote:

> 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.

Rather than just argue about what's permitted by various RIRs, I think it 
would be helpful to back up assertions with references to RIR policies.

Being based in the US and having primarily dealt with ARIN as "my RIR", I 
certainly don't claim to be an expert on RIPE policy...but looking at 
their latest document on "IPv4 Address Allocation and Assignment Policies 
for the RIPE NCC Service Region": 
https://www.ripe.net/publications/docs/ripe-733

I see no mention of leasing or renting.  I do see numerous references to 
"downstream network operators" in the context of an LIR making 
sub-allocations of their PA space to "downstream network operators."

i.e.

"LIRs may make sub-allocations to multiple downstream network operators.

The LIR is contractually responsible for ensuring the address space 
allocated to it is used in accordance with the RIPE community's policies. 
It is recommended that LIRs have contracts requiring downstream network 
operators to follow the RIPE community's policies when those operators 
have sub-allocations.

Sub-allocations form part of an LIR's aggregatable address space. As such, 
an LIR may want to ensure that the address space is not retained by a 
downstream network if the downstream network operator ceases to receive 
connectivity from the LIR's network."

"LIRs are allocated Provider Aggregatable (PA) address space. They 
sub-allocate and assign this to downstream networks. If a downstream 
network or End User changes its service provider, the address space 
assigned or sub-allocated by the previous service provider must be 
returned and the network renumbered."

Perhaps I'm missing something, but the above sections of ripe-733 seem to 
make it abundantly clear that RIPE policy is that LIRs can sub-allocate 
their PA space to downstream network customers buying connectivity from 
the LIR / service provider...and that if that provider/customer 
relationship terminates, the space must be returned to the LIR.

I'll grant you that some RIPE LIRs have gotten away with making a business 
of leasing IP space absent network connectivity to the LIR, but I don't 
see how that complies with ripe-733.

I'm not crazy about some of the wording/language in ARIN-2022-9, but I do 
support the premise that IP space leased to "customers", not in 
association with network connectivity over which that IP space is 
utilized, should not be countable as utilized when justifying subsequent 
allocations.

----------------------------------------------------------------------
  Jon Lewis, MCP :)           |  I route
  StackPath, Sr. Neteng       |  therefore you are
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