I agree with Mike Burns. Bruce C
> On Sep 12, 2022, at 9:09 AM, Mike Burns <[email protected]> wrote: > > > Hi Fernando, > > Why not go back and fix the proposal language mis-describing the situation at > other RIRs and define leasing within your proposal, and provide us with a new > version to consider? > > I will simply point out that leasing is effectively a transfer to those in > need, and that not everybody in need can afford a transfer purchase. This > policy would prevent those in need from receiving blocks unless they have > deep pockets. It’s not fair to smaller, less capitalized businesses who need > IPv4, so I remain opposed. > > 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]> 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. > > > _______________________________________________ > 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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