<div dir="auto">I strongly oppose this proposal.<div dir="auto"><br></div><div dir="auto">Leasing of IP addresses in such way should never be permmited and is a distortion of the way IP addresses must be used by organizations.</div><div dir="auto"><br></div><div dir="auto">The main reason is simple: if an organization is "leasing" IP address it is a clear sign that the organization does not have usage for that IP space and as it doesn't justify anymore it should therefore return them back to the RIR in order to be re-assigned to those who really have a need for it, via waiting list or other methods covered by the policies.</div><div dir="auto"><br></div><div dir="auto">It is pretty reasonable to think that in no RIRs you are able justify more IP space by saying "I need these addresses in order to lease them to someone else".</div><div dir="auto">If that is never a possible justification that can be used therefore leases don't make any sense.</div><div dir="auto"><br></div><div dir="auto">If an organization needs further IP space for a temporary project it may just get from the LIR or ISP but if that is not possible and the organization is an Autonomous System it can just go to market and get it transfered permanentlly.</div><div dir="auto">Either from the RIR or transfered via market addresses must be justified and leases are nothing but unused address by who is willing to lease.</div><div dir="auto"><br></div><div dir="auto">The justification given to allow organizations to facilitate transition to IPv6 does not apply at all as organizations can go directlly to the RIR for that (4.10). Why would it get via a lease bypassing the RIR ?</div><div dir="auto"><br></div><div dir="auto">RIR is and has always been the one who drives the resources to be efficientlly assigned by analysing justifications not private transfer companies. If an organization is not using resouces efficiently it either may change its resource assignment strategy otherwise it doesn't justify for those addresses anymore and should return them back to the RIR.</div><div dir="auto"><br></div><div dir="auto">By allowing leases it is just skipping the RIR's function to fairly re-distribute them and passing it private companies with financial interests.</div><div dir="auto"><br></div><div dir="auto">I think 8.5.2 is already properly written and doesn't require any change.</div><div dir="auto">Also Non-Connected Networks is not properly defined.</div><div dir="auto"><br></div><div dir="auto">Regarding the point about Conservation to be done through market pricing I will skip to comment such absurd thing.</div><div dir="auto"><br></div><div dir="auto">Regards</div><div dir="auto">Fernando</div></div><br><div class="gmail_quote"><div dir="ltr" class="gmail_attr">On Tue, 24 Sep 2019, 17:41 ARIN, <<a href="mailto:info@arin.net">info@arin.net</a>> wrote:<br></div><blockquote class="gmail_quote" style="margin:0 0 0 .8ex;border-left:1px #ccc solid;padding-left:1ex">On 19 September 2019, the ARIN Advisory Council (AC) accepted <br>
"ARIN-prop-277: LIR/ISP Re-Assignment to Non-Connected Networks" as a <br>
Draft Policy.<br>
<br>
Draft Policy ARIN-2019-18 is below and can be found at:<br>
<br>
<a href="https://www.arin.net/participate/policy/drafts/2019_18/" rel="noreferrer noreferrer" target="_blank">https://www.arin.net/participate/policy/drafts/2019_18/</a><br>
<br>
You are encouraged to discuss all Draft Policies on PPML. The AC will <br>
evaluate the discussion in order to assess the conformance of this draft <br>
policy with ARIN's Principles of Internet number resource policy as <br>
stated in the Policy Development Process (PDP). Specifically, these <br>
principles are:<br>
<br>
* Enabling Fair and Impartial Number Resource Administration<br>
* Technically Sound<br>
* Supported by the Community<br>
<br>
The PDP can be found at:<br>
<a href="https://www.arin.net/participate/policy/pdp/" rel="noreferrer noreferrer" target="_blank">https://www.arin.net/participate/policy/pdp/</a><br>
<br>
Draft Policies and Proposals under discussion can be found at:<br>
<a href="https://www.arin.net/participate/policy/drafts/" rel="noreferrer noreferrer" target="_blank">https://www.arin.net/participate/policy/drafts/</a><br>
<br>
Regards,<br>
<br>
Sean Hopkins<br>
Policy Analyst<br>
American Registry for Internet Numbers (ARIN)<br>
<br>
<br>
<br>
Draft Policy ARIN-2019-18: LIR/ISP Re-Assignment to Non-Connected Networks<br>
<br>
Problem Statement:<br>
<br>
Businesses have a need to lease IPv4 space for limited periods of time, <br>
as evidenced by a robust (technically prohibited) subleasing market. The <br>
lack of legitimization of the subleasing market hinders innovation, <br>
research, reporting, and the development of rules/industry best <br>
practices to ensure identifiability and contactability.<br>
<br>
Policy statement:<br>
<br>
ORIGINAL POLICY LANGUAGE<br>
<br>
2.4. Local Internet Registry (LIR)<br>
<br>
A Local Internet Registry (LIR) is an IR that primarily assigns address <br>
space to the users of the network services that it provides. LIRs are <br>
generally Internet Service Providers (ISPs), whose customers are <br>
primarily end users and possibly other ISPs.<br>
<br>
PROPOSED POLICY LANGUAGE<br>
<br>
A Local Internet Registry (LIR) is an IR that primarily assigns address <br>
space to the users of the network services that it provides. LIRs are <br>
generally Internet Service Providers (ISPs), whose customers are <br>
primarily end users and possibly other ISPs.<br>
<br>
LIRs may also assign address space to other organizations or customers <br>
that request it for use in an operational network.<br>
<br>
ORIGINAL POLICY LANGUAGE<br>
<br>
8.5.2 Operational Use<br>
<br>
ARIN allocates or assigns number resources to organizations via transfer <br>
solely for the purpose of use on an operational network.<br>
<br>
PROPOSED POLICY LANGUAGE<br>
<br>
Option 1 : Remove 8.5.2 entirely<br>
<br>
Option 2 : Edit as follows<br>
<br>
8.5.2 Operational Use<br>
<br>
ARIN allocates or assigns number resources to organizations via transfer <br>
solely primarily for the purpose of use on an operational network, but <br>
may allocate or assign number resources to organizations for other <br>
purposes, including re-assignment to non-connected networks .<br>
<br>
Comments:<br>
<br>
Timetable for implementation: Immediate<br>
<br>
Anything Else:<br>
<br>
The legitimization of a subleasing market for IPv4 has numerous business <br>
and community benefits, including (but not limited to):<br>
<br>
- Allowing organizations to efficiently utilize IPv4 space without <br>
transferring space permanently;<br>
- Allowing organizations to obtain IPv4 space for a limited time in <br>
order to facilitate transition to IPv6;<br>
- Allowing organizations to develop enforceable acceptable use policies <br>
in a previously lawless illegitimate space;<br>
- Allowing the community to develop reporting and recording standards <br>
and/or best practices to the benefit of preserving the integrity of IPv4 <br>
address space.<br>
- We would like to engage further with the ARIN community to discuss the <br>
current state of the unauthorized subleasing market, and how this <br>
proposed policy change would both update ARIN policies to reflect the <br>
reality of the subleasing market, and positively address business and <br>
community concerns.<br>
<br>
_______________________________________________<br>
ARIN-PPML<br>
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</blockquote></div>