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

Marco Schmidt mschmidt at ripe.net
Mon Sep 12 04:52:19 EDT 2022

Dear Jon and colleagues,

I would like to provide some clarification for the RIPE region.

The proposal states
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 the RIPE region the term "leasing" is not defined and therefore it 
does not play a role in the request evaluation.
Further, the RIPE policies for IPv4 do not require any specific 
justification of the need.

Before providing a statement about the policy status in the RIPE region, 
I kindly suggest that proposers contact first our Policy Officer 
(pdo at ripe.net) for input.

Kind regards,
Marco Schmidt
Manager Registration Services & Policy Development

On 11/09/2022 02:47, Jon Lewis wrote:
> 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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