[arin-ppml] Draft Policy ARIN-2022-9: Leasing Not Intended
Fernando Frediani
fhfrediani at gmail.com
Mon Sep 12 13:32:38 EDT 2022
Hi Adam
On 12/09/2022 13:56, Adam Thompson wrote:
>
> The error in what Fernando just said is: parent companies do not, in
> fact, transfer their possibly-valuable IP space to subsidiaries - they
> assign/allocate instead. Until very recently, that wasn’t possible in
> many cases, so we wound up with yet another instance of ARIN policy
> that actively prevented the database from being as accurate as
> possible. That’s fixed (more or less) as of this year – I admit I
> haven’t done all the SWIPs I should have by now, now that I can!
>
> My primary concern with this policy is that it will do much the same –
> drive leasing underground, and the public registry will then fail to
> accurately reflect reality in yet another way.
>
This cannot be more important than have the rules followed, rules that
were agreed when the contracts were originally signed by each member. We
cannot accept a situation that may be out of the rules or abnormal and
turn into something normal just because some people do that and "we have
to accept". No, in the other hand people must follow what is expected
and those who don't will be subject to sanctions. There is a reason most
rules exist and in general these have been discussed extensively to get
to that point.
There was not much a while ago a discussion in this very same list where
many people showed their contrariety about IPs being leased "per se"
without any form of connectivity services involved and how many of them
disapprove to see that happening, just look at the archives, otherwise
this proposal would not be here. So there is a fair amount of people
who are equally suffering with IPv4 exhaustion that do not wish to keep
watching IP addresses being handled by third parties, and end up going
to those who can pay more rather than to those who really have proper
justification to get them directly from ARIN following the same rules
that everybody else is subjected equally.
It is common during these times some may want to look 'more beautiful'
than others there is always a special reason 'for that case' and this is
where a lot of unfairness is generated.
> I hold ARIN’s goal of maintaining an open, accurate database of IP
> address usage to be ultimately far more important than its explicit
> non-goal of regulating IP address usage.
>
> I believe this proposal tries to put ARIN into the role of “Internet
> cop” again and is inappropriate.
>
This is not true and it is often used to oppose this type of idea of
complete ban leasing because it damages specific type of business like
IP brokerage.
ARIN or any RIR duties are not limited only to keep an accurate database
of IP address, but also to make sure that those IPs - that doesn't
belong to any resources holder, important to remember - are used in the
fair and correct way they should. And if it not the case to revoke those
resources. This doesn't have to do with the way people operate their
networks in the sense of what BGP filters they apply, what Transit
Providers they get, if they use CGNAT or issue Public IPs to their
customers, etc.
This has to do with following the policy rules regarding IP address and
in this sense it is up to the RIR to make sure of that without anything
related to "internet police"
>
> Preventing legitimate users from using leased IP addresses does not
> help the internet. Preventing illegitimate users from doing so might
> well help the internet, but leads straight into the classic “only
> criminals will have guns” argument – why would anyone with a shady use
> ever use truthful information in an application to ARIN in the first
> place?
>
A legitimate user should get these addresses from ARIN directly and sign
a contract with it otherwise they can get the address from their
upstream provider who provides connectivity services to them. An
illegitimate resource holder should return them back if they don't have
usage anymore.
This helps the internet when organizations abide by the rules, is more
secure in the sense that there are mechanisms to stop abuses and
security issues and everybody is subjected to the same rules and
requirements to have address to something they don't own.
Fernando
> -Adam
>
> *Adam Thompson*
>
> Consultant, Infrastructure Services
>
> MERLIN
>
> 100 - 135 Innovation Drive
>
> Winnipeg, MB R3T 6A8
>
> (204) 977-6824 or 1-800-430-6404 (MB only)
>
> https://www.merlin.mb.ca <https://www.merlin.mb.ca/>
>
> Chat with me on Teams
> <https://teams.microsoft.com/l/chat/0/0?users=athompson@merlin.mb.ca>
>
> *From:*ARIN-PPML <arin-ppml-bounces at arin.net> *On Behalf Of *Fernando
> Frediani
> *Sent:* September 11, 2022 10:30 PM
> *To:* arin-ppml at arin.net
> *Subject:* Re: [arin-ppml] Draft Policy ARIN-2022-9: Leasing Not Intended
>
> Hello Bruce
> Thanks for sharing these concerns. Seem reasonable ones.
>
> Talking briefly it is hard to catch all possible details, but I see
> that in a network infrastructure transfer to a subsidiary there are
> different ways that can be done. In general these subsidiary may
> likely have direct connectivity from the parent company in a
> provider/customer relationship, but when it is not the case I think it
> is fair to think that the subsidiary or startup company may not need a
> large amount of addresses to start with, so the parent willing to
> support it can easily transfer a small amount of address via the
> normal transfer process and allow that company to start giving more
> flexibility so it to grow overtime and if necessary make subsequent
> transfers.
>
> I understand the scenario you describe may look legitimate, but the
> issue is to have too generic and open way that end up allowing the
> usage of resources in a forbidden or unfair way that is damageable to
> the Internet community.
> The most common to start with is, if the resource holder doesn't
> provide any type of connectivity to the receiving organization it may
> cause security issues because the resource holder does not have
> immediate physical control to manager or filter them.
>
> Some of the drivers of the proposal is to make sure that resources are
> always used in the most fair way and that doesn't cause security
> issues to Internet ecosystem overtime. It doesn't sound fair,
> specially in times of IPv4 exhaustion that a shared resources that
> nobody owns alone, to go to those who can pay more rather than to
> those who really need and justify for them according to the current
> rules that everyone is subjected to. There is no justification to have
> a prefix allocated from an organization to another if the second one
> is perfectly able to get them directly from a neutral and well
> established organization - ARIN.
>
> I hope it helps to address some of your concerns, otherwise we carry on.
>
> Best regards
> Fernando
>
> On 10/09/2022 16:25, Bruce Cornett wrote:
>
> I still see a significant issue. Consider the transfer of network
> infrastructure to a subsidiary or possibly a startup. And for the
> moment the parent corporation is not providing connectivity. If
> the blocks are transferred to the subsidiary and something goes
> awry with that business segment, access to the blocks could be
> lost. The end users with connectivity go belly up with
> essentially no recourse.
>
> The reasonable solution is to simply allow the subsidiary or
> startup to use the blocks subject to an agreement between the two
> parties.
>
> While I can't suggest I know the driver for the proposal, I would
> guess it's to reign in the month to month leasing of address
> blocks for dubious services.
>
> It may make sense to make a policy that disallows leasing for
> network usage justification.
>
> Bruce C
>
>
>
> On Sep 10, 2022, at 10:13 AM, Fernando Frediani
> <fhfrediani at gmail.com> <mailto:fhfrediani at gmail.com> wrote:
>
>
>
> Hello Bruce
>
> There is not problem at all in these scenarios as resources
> can be easily transferred and there are policies for that
> already, therefore the mechanism already exist.
>
> Fernando
>
> On 10/09/2022 13:31, Bruce Cornett via ARIN-PPML wrote:
>
> Hello
>
>
> I see a potential problem where changes in corporate
> structure occur when shifting day to day operations to
> subsidiaries or sister corporations, leaving the block
> assignment with the original holder.
>
> Bruce C
>
>
>
> On Sep 9, 2022, at 9:44 AM, Fernando Frediani
> <fhfrediani at gmail.com> <mailto: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 <arin-ppml-bounces at arin.net>
> <mailto:arin-ppml-bounces at arin.net> *On Behalf Of
> *ARIN
> *Sent:* Tuesday, August 23, 2022 12:29 PM
> *To:* PPML <arin-ppml at arin.net>
> <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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