-Adam
*Adam Thompson*
Consultant, Infrastructure Services
MERLIN
100 - 135 Innovation Drive
Winnipeg, MB R3T 6A8
(204) 977-6824 or 1-800-430-6404 (MB only)
https://www.merlin.mb.ca <https://www.merlin.mb.ca/>
Chat with me on Teams
<https://teams.microsoft.com/l/chat/0/0?users=athomp...@merlin.mb.ca>
*From:*ARIN-PPML <arin-ppml-boun...@arin.net> *On Behalf Of *Fernando
Frediani
*Sent:* September 11, 2022 10:30 PM
*To:* arin-ppml@arin.net
*Subject:* Re: [arin-ppml] Draft Policy ARIN-2022-9: Leasing Not Intended
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
<fhfredi...@gmail.com> <mailto:fhfredi...@gmail.com> 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
<fhfredi...@gmail.com> <mailto:fhfredi...@gmail.com>
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 <arin-ppml-boun...@arin.net>
<mailto:arin-ppml-boun...@arin.net> *On Behalf Of
*ARIN
*Sent:* Tuesday, August 23, 2022 12:29 PM
*To:* PPML <arin-ppml@arin.net>
<mailto:arin-ppml@arin.net>
*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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