On Sat, 10 Sep 2022, Mike Burns wrote:

Fernando,

Your proposal says leasing is banned at other RIRs.

I am telling you once again that leasing is NOT banned at RIPE and leased 
addresses CAN be used as justification at RIPE. 
I speak from direct experience.

And once again there is no policy nor contract requirement to utilize addresses 
at ARIN for their originally intended purposes, ergo leasing is not
prohibited to address holders at ARIN.

Please define the word leasing as that impacts enforcement and other issues.

This proposal remains deeply flawed.

So I remain deeply opposed.

Rather than just argue about what's permitted by various RIRs, I think it would be helpful to back up assertions with references to RIR policies.

Being based in the US and having primarily dealt with ARIN as "my RIR", I certainly don't claim to be an expert on RIPE policy...but looking at their latest document on "IPv4 Address Allocation and Assignment Policies for the RIPE NCC Service Region": https://www.ripe.net/publications/docs/ripe-733

I see no mention of leasing or renting. I do see numerous references to "downstream network operators" in the context of an LIR making sub-allocations of their PA space to "downstream network operators."

i.e.

"LIRs may make sub-allocations to multiple downstream network operators.

The LIR is contractually responsible for ensuring the address space allocated to it is used in accordance with the RIPE community's policies. It is recommended that LIRs have contracts requiring downstream network operators to follow the RIPE community's policies when those operators have sub-allocations.

Sub-allocations form part of an LIR's aggregatable address space. As such, an LIR may want to ensure that the address space is not retained by a downstream network if the downstream network operator ceases to receive connectivity from the LIR's network."

"LIRs are allocated Provider Aggregatable (PA) address space. They sub-allocate and assign this to downstream networks. If a downstream network or End User changes its service provider, the address space assigned or sub-allocated by the previous service provider must be returned and the network renumbered."

Perhaps I'm missing something, but the above sections of ripe-733 seem to make it abundantly clear that RIPE policy is that LIRs can sub-allocate their PA space to downstream network customers buying connectivity from the LIR / service provider...and that if that provider/customer relationship terminates, the space must be returned to the LIR.

I'll grant you that some RIPE LIRs have gotten away with making a business of leasing IP space absent network connectivity to the LIR, but I don't see how that complies with ripe-733.

I'm not crazy about some of the wording/language in ARIN-2022-9, but I do support the premise that IP space leased to "customers", not in association with network connectivity over which that IP space is utilized, should not be countable as utilized when justifying subsequent allocations.

----------------------------------------------------------------------
 Jon Lewis, MCP :)           |  I route
 StackPath, Sr. Neteng       |  therefore you are
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