Hello Bruce
Thanks for sharing these concerns. Seem reasonable ones.
Talking briefly it is hard to catch all possible details, but I see that in
a network infrastructure transfer to a subsidiary there are different ways
that can be done. In general these subsidiary may likely have direct
connectivity from the parent company in a provider/customer relationship,
but when it is not the case I think it is fair to think that the subsidiary
or startup company may not need a large amount of addresses to start with,
so the parent willing to support it can easily transfer a small amount of
address via the normal transfer process and allow that company to start
giving more flexibility so it to grow overtime and if necessary make
subsequent transfers.
I understand the scenario you describe may look legitimate, but the issue is
to have too generic and open way that end up allowing the usage of resources
in a forbidden or unfair way that is damageable to the Internet community.
The most common to start with is, if the resource holder doesn't provide any
type of connectivity to the receiving organization it may cause security
issues because the resource holder does not have immediate physical control
to manager or filter them.
Some of the drivers of the proposal is to make sure that resources are
always used in the most fair way and that doesn't cause security issues to
Internet ecosystem overtime. It doesn't sound fair, specially in times of
IPv4 exhaustion that a shared resources that nobody owns alone, to go to
those who can pay more rather than to those who really need and justify for
them according to the current rules that everyone is subjected to. There is
no justification to have a prefix allocated from an organization to another
if the second one is perfectly able to get them directly from a neutral and
well established organization - ARIN.
I hope it helps to address some of your concerns, otherwise we carry on.
Best regards
Fernando
On 10/09/2022 16:25, Bruce Cornett wrote:
I still see a significant issue. Consider the transfer of
network infrastructure to a subsidiary or possibly a startup.
And for the moment the parent corporation is not providing
connectivity. If the blocks are transferred to the subsidiary
and something goes awry with that business segment, access to
the blocks could be lost. The end users with connectivity go
belly up with essentially no recourse.
The reasonable solution is to simply allow the subsidiary or startup
to use the blocks subject to an agreement between the two parties.
While I can't suggest I know the driver for the proposal, I would
guess it's to reign in the month to month leasing of address blocks
for dubious services.
It may make sense to make a policy that disallows leasing for network
usage justification.
Bruce C
On Sep 10, 2022, at 10:13 AM, Fernando Frediani
<[email protected]> wrote:
Hello Bruce
There is not problem at all in these scenarios as
resources can be easily transferred and there are policies
for that already, therefore the mechanism already exist.
Fernando
On 10/09/2022 13:31, Bruce Cornett via ARIN-PPML wrote:
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.
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