Regards,
Mike
*From:* ARIN-PPML <[email protected]> *On Behalf Of *Fernando
Frediani
*Sent:* Saturday, September 10, 2022 1:25 PM
*To:* arin-ppml <[email protected]>
*Subject:* Re: [arin-ppml] Draft Policy ARIN-2022-9: Leasing Not Intended
I don't understand your way to oppose this proposal. You want to
oppose it based a small subset of 'situation in other regions' text ?
That your only point to oppose this proposal ?
The text clearly says the leasing of addresses is not authorized
explicitly in the policy manuals and in most RIRs it has been already
confirmed this is not allowed in most RIRs (exactly as it should be).
In RIPE that you are picking in order to try oppose this proposal it
mentions specifically that this cannot be used as a justification of
need and it is obvious you cannot go to RIPE, ask for addresses and
justify that you will use them to lease to someone else, pretending to
be a sub-RIR. It is just simple.
In ARIN this proposal will make it very clear not only for
justification of need which is already forbidden but also later on for
usage and that is the right thing to do in order to avoid more
unfairness with the whole community in times of IPv4 exhaustion.
What is the logic for not being able to justify the need based on
leasing but be allowed to used for them for leasing later on ?
The point here is quiet simple and most people are able to understand:
if you have a need to keep IP resources as a resource holder for
justified need proposes you are fine to keep the addresses
indefinitely, if not your should either transfer them to whoever has
real need or return them back to ARIN so them can be directly assigned
by ARIN to any member who really needs them and have no intermediaries
in the middle pretending to be a RIR and bringing real security issues
to the whole Internet.
Fernando
On 10/09/2022 14:01, 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.
Regards,
Mike
---- On Fri, 09 Sep 2022 12:44:10 -0400 *Fernando Frediani
<[email protected]> <mailto:[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]>
<mailto:[email protected]> *On Behalf Of *ARIN
*Sent:* Tuesday, August 23, 2022 12:29 PM
*To:* PPML <[email protected]> <mailto:[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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