Hi Scott, what Internet operation exists there is no connectivity provided by the resource holder to a customer ?

Unfortunately that's not quiet correct your assertion that simply ARIN should only care whether addresses are in use on a operation network or not. Above all they should care if resources are being utilized according to the current policy and the need they were justified for. If an organization who doesn't provide any connectivity services to another and simply leases (rent or lend) address to be used for this second one creates security issues, given that,*in the absence of connectivity the member receiving the license to use the addresses does not have immediate physical control to manage or filter these resources, something that could potentially result in damages to the entire community.

Fernando

On 24/08/2022 14:26, Scott Leibrand wrote:
No, this draft policy is not merely a clarification. This would a significant change in policy, and if enforced would significantly interfere with the efficient operation of the Internet.

ARIN should only care whether addresses are in use on an operational network. They have no reason to care about the connectivity, or lack thereof, between an LIR and operational networks that it reallocates or reassigns space to.

I run an operational network. We still use a number of address blocks originally allocated to us by our transit providers before we acquired our own space, which we have always announced in BGP in a multihomed fashion. If we stop announcing the route to the transit provider who announced us the space, whether temporarily (due to an outage or maintenance) or more permanently (because we no longer need transit from them there), we should be able to continue using our assigned space as long as we have appropriate contractual arrangements in place to do so. That is a form of "leasing" that has always been allowed, and this policy would disallow it.

Any policy requiring a certain form of connectivity between an LIR and its customers will either be unenforceable and easily gamed, or onerous, bureaucratic, and will interfere with the legitimate operation of networks efficiently utilizing their IPv4 space.

-Scott

On Wed, Aug 24, 2022 at 9:32 AM Fernando Frediani <[email protected]> wrote:

    Hello Scott

    Could you explain better the arguments you are against in this
    proposal or that don't sound valid?

    All this proposal does is to make clear make something clear in
    the policy text.
    If you cannot go to ARIN and justify that you intend to use
    requested IP addresses for simple leasing proposes, to be leased
    to organization with who you don't provide any connectivity
    services, why would it be an accepted thing in any other scenario ?
    IP space is to be used for building Internet infrastructure and to
    get customers connected to the Internet, not to be simply leased
    from one organization pretending to be a RIR to another.

    Unless I misunderstood and you like the idea of leasing and so why
    you oppose this proposal.

    Regards
    Fernando

    On 24/08/2022 12:40, Scott Leibrand wrote:
    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]>
    <mailto:[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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