I’m speaking to the risk that an organization that engages in leasing address 
blocks without providing related connectivity services. Given that these blocks 
cannot currently be used as justification for additional space, an organization 
that does so would not qualify for additional space should they require it, 
unless they are falsifying the nature of the allocations in their justification 
documentation (which, of course, is a policy violation that could lead to that 
organizations’s allocations being reclaimed if discovered).

This policy proposal, per the problem statement, is explicitly aimed at 
removing that risk, and as such, putting ARIN’s stamp of approval on this type 
of lease practice, and in fact, allows organizations to require additional 
space which it could then lease out, without the need to provide the network 
services associated with the blocks being leased. Which is a type of IP block 
monetization that I simply cannot stand behind.

As such, I remain opposed to this proposal.

-C

> On Sep 22, 2021, at 7:00 AM, Mike Burns <[email protected]> wrote:
> 
> Hi Chris,
>  
> Can you be more specific on which inherent risk this policy would remove?
> Somebody +1’d this, but I don’t understand what you mean.
> I don’t even know which party’s risk is being commented on.
>  
> Regards,
> Mike
>  
>  
> From: ARIN-PPML <[email protected]> On Behalf Of Chris Woodfield
> Sent: Tuesday, September 21, 2021 9:21 PM
> To: Owen DeLong <[email protected]>
> Cc: PPML <[email protected]>
> Subject: Re: [arin-ppml] Draft Policy ARIN-2021-6: Remove Circuit Requirement
>  
>  
>> On Sep 21, 2021, at 10:22 AM, Owen DeLong <[email protected] 
>> <mailto:[email protected]>> wrote:
>>  
>> This policy doesn’t affect that… Leasing of address space you already have 
>> is permitted under current policy and cannot be grounds for revocation of 
>> address space.
>>  
>> The change in this policy proposal is not to permit or deny leasing, but to 
>> permit leased addresses to be considered utilized for purposes of 
>> determining eligibility for additional address acquisition.
>>  
>  
> You are correct that the proposal may not permit or prohibit leasing, but it 
> does (intentionally, per the problem statement) remove one of the inherent 
> risks of the practice, and as such, in my view, is effectively an 
> endorsement. 
>  
> As such, my opposition stands.
>  
> -C
> 
> 
>> Owen
>>  
>> 
>> 
>>> On Sep 21, 2021, at 08:22 , Chris Woodfield <[email protected] 
>>> <mailto:[email protected]>> wrote:
>>>  
>>> Writing in opposition. I do not support the practice of leasing IP address 
>>> resources. Organizations who have received larger amounts of IP address 
>>> space than what they are efficiently utilizing are free to relieve 
>>> themselves of their excess space via the transfer market.
>>>  
>>> Thanks,
>>>  
>>> -Chris
>>> 
>>> 
>>>> On Sep 21, 2021, at 8:06 AM, ARIN <[email protected] <mailto:[email protected]>> 
>>>> wrote:
>>>>  
>>>> On 16 September 2021, the ARIN Advisory Council (AC) accepted 
>>>> "ARIN-prop-302: Remove Circuit Requirement " as a Draft Policy.
>>>>  
>>>> Draft Policy ARIN-2021-6 is below and can be found at:
>>>>  
>>>> https://www.arin.net/participate/policy/drafts/2021_6/ 
>>>> <https://www.arin.net/participate/policy/drafts/2021_6/>
>>>>  
>>>> You are encouraged to discuss all Draft Policies on PPML. The AC will 
>>>> evaluate the discussion in order 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/ 
>>>> <https://www.arin.net/participate/policy/pdp/>
>>>>  
>>>> Draft Policies and Proposals under discussion can be found at:
>>>> https://www.arin.net/participate/policy/drafts/ 
>>>> <https://www.arin.net/participate/policy/drafts/>
>>>>  
>>>> Regards,
>>>>  
>>>> Sean Hopkins
>>>> Senior Policy Analyst
>>>> American Registry for Internet Numbers (ARIN)
>>>>  
>>>>  
>>>> Draft Policy ARIN-2021-6: Remove Circuit Requirement 
>>>>  
>>>> Problem Statement:
>>>>  
>>>> Current ARIN policy prevents the use of leased-out addresses as evidence 
>>>> of utilization.
>>>>  
>>>> Policy statement:
>>>>  
>>>> Replace
>>>>  
>>>> “2.4. Local Internet Registry (LIR) A Local Internet Registry (LIR) is an 
>>>> IR that primarily assigns address space to the users of the network 
>>>> services that it provides. LIRs are generally Internet Service Providers 
>>>> (ISPs), whose customers are primarily end users and possibly other ISPs.”
>>>>  
>>>> with
>>>>  
>>>> “2.4. Local Internet Registry (LIR) A Local Internet Registry (LIR) is an 
>>>> IR that primarily assigns address space to users of the network. LIRs are 
>>>> generally Internet Service Providers (ISPs), whose customers are primarily 
>>>> end users and possibly other ISPs.”
>>>>  
>>>> Timetable for implementation: Immediate
>>>>  
>>>> _______________________________________________
>>>> ARIN-PPML
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>>>> Please contact [email protected] <mailto:[email protected]> if you experience any 
>>>> issues.
>>> 
>>>  
>>> _______________________________________________
>>> ARIN-PPML
>>> You are receiving this message because you are subscribed to
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>>> issues.

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