Hello I see a potential problem where changes in corporate structure occur when shifting day to day operations to subsidiaries or sister corporations, leaving the block assignment with the original holder.
Bruce C > On Sep 9, 2022, at 9:44 AM, Fernando Frediani <[email protected]> wrote: > > > Hello > > There is no such error in the proposal. > This has been checked as being the interpretation staff gives to the current > policy in most RIRs. APNIC is just an example that have confirmed it publicly > a couples of days ago. > You may not find all the very specific words you may wish for in the text, > but it is not much difficult for them to have such interpretation given the > resources must follow a proper justification of what they will be used for > and that can never be that you will use them for leasing (rent of lend). ARIN > also already confirmed in this very same list they don't accept it as a > justification. > > There is no much around the term leasing. If an organization who don't > provide any connectivity services to another simply rent or lend IP space, > with or without a cost associated that is something that must not be since > they no longer have a justification to keep that IP space and instead should > either transfer it to those who really justify or return to ARIN. > > Fernando > >> On 24/08/2022 11:04, Mike Burns wrote: >> Opposed, I think the proposal contains errors that should be fixed before >> the discussion proceeds. >> >> For example this statement : >> “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.” >> >> If it is not in their policy manuals, how can the proposers state leasing is >> not authorized? >> Where do the proposers think authority comes from, if not from policy and >> contract? >> Are they just assuming that all things are prohibited unless they are >> explicitly allowed? >> That would be an interesting way to read the policy manual, if that is the >> belief, we should discuss that. >> >> Beyond that there is the very next sentence: >> ” Nothing is currently mentioned in RIPE about this and it is not acceptable >> as a justification of the need. “ >> >> Once again the bias is towards prohibition despite language about leasing >> being absent from RIPE policy. More to the point, and something that can’t >> be drummed-home clearly enough to this community, RIPE has no needs test at >> all for transfers and hasn’t for years. And yet RIPE still exists and >> operates as an RIR. Even further to the point, in the one occasion that >> RIPE performs a needs-test, which is on inter-regional transfers from ARIN, >> leased-out addresses are in fact acceptable as justification. That’s because >> of two logical things. First, RIPE understands that the inherent value of >> the addresses drives them towards efficient use. Second, RIPE understands >> that they are charged with getting addresses into use, not getting them into >> use on particular networks. >> >> So the first two sentences in the “situation at other RIRs” are >> problematic/false. >> Might I suggest fixing those before we move forward, and also can you please >> define the word leasing? >> >> This seems poorly though-out to me, and I haven’t started on the meat of the >> proposal yet nor how it would be effectively policed and prohibited. >> >> Regards, >> Mike >> >> >> >> >> >> >> >> >> From: ARIN-PPML <[email protected]> On Behalf Of ARIN >> Sent: Tuesday, August 23, 2022 12:29 PM >> To: PPML <[email protected]> >> Subject: [arin-ppml] Draft Policy ARIN-2022-9: Leasing Not Intended >> >> 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. >> >> >> >> _______________________________________________ >> ARIN-PPML >> You are receiving this message because you are subscribed to >> the ARIN Public Policy Mailing List ([email protected]). >> Unsubscribe or manage your mailing list subscription at: >> https://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact [email protected] if you experience any issues. > _______________________________________________ > ARIN-PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List ([email protected]). > Unsubscribe or manage your mailing list subscription at: > https://lists.arin.net/mailman/listinfo/arin-ppml > Please contact [email protected] if you experience any issues.
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