Opposed. There is no good reason I am aware of for ARIN to require the bundling 
of IP addressing and connectivity services. The arguments provided in this 
draft policy are not sound or valid ones.  

Scott

> On Aug 23, 2022, at 9:28 AM, ARIN <[email protected]> wrote:
> 
> 
> 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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