---- On Fri, 16 Sep 2022 06:55:47 -0400 [email protected] wrote ----Dear
Colleagues,In this proposal - Leasing Not Intended- all three concepts of
justification, property and ownership are simply mixed, and introduced as a new
Article 1.5., which should be placed in the Section 1 of the Number Resource
Policy manual, the purpose of which is to define principles and goals of
ARIN.Besides the absence of “Lease” definition itself, probably most
contradictive part of this proposal is that resources would be allocated “with
an annual validity”, which means that organizations would be required to verify
they qualify for the resources every year (?!).There are errors not only in the
logic, structure, or placement of this proposal, but it also directly
contradicts with the newest documentation of ARIN. The proposal is dated August
23rd, and states that “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, on September 12th 2022, ARIN
updated it’s RSA by REMOVING Section 7 of the agreement which stated that “the
Included Number Resources are not property (real, personal, or intellectual) of
Holder” and acknowledged rights to included number resources. Now Section 7 is
called “ACKNOWLEDGED RIGHTS TO INCLUDED NUMBER RESOURCES” and says that “Holder
acknowledges and agrees that Holder acquires express contractual rights to the
Included Number Resources by virtue of this Agreement.”Obviously, this new
proposal is not only taking back all the development process of ARIN, but it
also turns it to punishment and control institution. If RIR would want to
control lease or transfer of LIR’s assets, it creates situation, where RIR
interferes into the business model or business plan of the LIR’s entity. If RIR
prohibits LIR to make one or other transaction, it acts ultra vires, - beyond
the authority of RIR to perform. It is not an audit or supervisory institution,
and should encourage the community to grow and develop, but not control,
interfere, or prohibit commercial transactions of
organizations.Regards,Evelina-----Original Message-----From: ARIN-PPML
<[email protected]> On Behalf Of [email protected]: 2022
m. rugsėjo 12 d., pirmadienis 20:03To: [email protected]: ARIN-PPML
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Burns)----------------------------------------------------------------------Message:
1Date: Mon, 12 Sep 2022 13:02:26 -0400From: "Mike Burns"
<[email protected]>To: "'Fernando Frediani'" <[email protected]>,
"'arin-ppml'" <[email protected]>Subject: Re: [arin-ppml] Draft Policy
ARIN-2022-9: Leasing Not IntendedMessage-ID:
<[email protected]>Content-Type: text/plain;
charset="utf-8"Hi Fernando, Leasing is not defined in the proposal and the
language in the proposal is explicitly false in at least one case regarding
RIPE.I?m not sure why you don?t just fix it and add a lease definition. You
have not addressed the problem of small businesses who can?t afford to purchase
but can afford to lease.You keep saying they should just do a transfer instead,
totally disregarding the cost of a transfer.Your policy denies them the ability
to get needed IPv4 and you have not answered this objection. Regards,Mike
From: ARIN-PPML <[email protected]> On Behalf Of Fernando
FredianiSent: Monday, September 12, 2022 12:40 PMTo: 'arin-ppml'
<[email protected]>Subject: Re: [arin-ppml] Draft Policy ARIN-2022-9: Leasing
Not Intended Hi Em 12/09/2022 13:09, Mike Burns escreveu: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?The situation in the other RIRs are most correct and confirmed.
Only RIPE has clarified in a way previously and now seems to have changed their
mind slightly.In any way this is not an excuse for the proposal to keep its
normal discussion as it is not a critic point that doesn't change the spirit of
the proposal and its main point to be discussed which is making it clear in the
policy text. Leasing in this context is already well defined based mainly on
direct connectivity as discussed in several messages. 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.This looks more
emotional words in order to try protect the leasing practice than a real world
that have options available within the rules and without having do things in a
way that is bad for most community . While I don't deny that some organizations
may be having access to small chunk of address via these practices this can not
be more important than things like the security of the resource holder not
having immediate control of what is used by the customer and more important
than that the unfairness that is causes specially in times of IPv4 Exhaustion
in order to make sure resources go *directly* (which means from ARIN) to the
resource holder and not from um resources holder to someone that has the
ability to get these addresses by themselves via a transfer for
example.Fernando Regards,Mike From: ARIN-PPML
<mailto:[email protected]> <[email protected]> On Behalf Of
Fernando FredianiSent: Saturday, September 10, 2022 1:25 PMTo: arin-ppml
<mailto:[email protected]> <[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.FernandoOn 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
<mailto:[email protected]> <[email protected]> wrote --- HelloThere 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.FernandoOn 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 <mailto:[email protected]>
<[email protected]> On Behalf Of ARINSent: Tuesday, August 23, 2022
12:29 PMTo: PPML <mailto:[email protected]> <[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 HopkinsSenior
Policy AnalystAmerican 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-PPMLYou are
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