Hi Owen,
RIPE continues to apply needs-tests to inter-regional transfers from ARIN. And
leasing out addresses is considered to be a valid justification. The authors
continue to mislead.
What problem does this policy seek to correct? Can it be stated in a single
sentence rather than book form? I think a clear problem statement guides a
clear discussion.
Regards,
Mike
---- On Sun, 10 Sep 2023 17:53:55 -0400 [email protected] wrote
----3. 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.This
simply isn’t the fact.In ARIN, Leasing is not permitted as justification for
obtaining addresses and addresses leasedwithout associated connectivity are not
considered utilized for the purpose of obtaining additionaladdresses. However,
that does not mean that leasing is not authorized. Leasing is neither
authorized,nor prohibited by ARIN policy at this time.Nothing is currently
mentioned in RIPE about this and originally it was not acceptable as a
justification of the need.Having done away with Need as a justification,
however, there is no longer a prohibition of leasingin any form in the RIPE
region. That which is not prohibited is permitted.In AFRINIC and LACNIC, the
staff has confirmed that address leasing is not considered as valid for the
justification. In ARIN it is not considered valid as justification of need.Not
considered as valid for justification is different from prohibited. Once one
has acquired addressesfrom an RIR, one is free to utilize them for any purpose
not explicitly prohibited by policy, RSA, orthe bylaws of the RIR.A similar
proposal is under discussion in LACNIC and ARIN.Similar proposals have
repeatedly failed in ARIN before and the current one does not, IMHO, havemuch
support.4. Proposed policy solution---------------------------5.8. Leasing of
Internet Number ResourcesIn the case of Internet number resources delegated by
APNIC or a NIR, the justification of the need implies the need to use on their
own infrastructure and/or network connectivity services provided to customers.
As a result, any form of IP address leasing is unacceptable, nor does it
justify the need, unless otherwise justified in the original request. Even for
networks that are not connected to the Internet, any form of leasing of IP
addresses is not permitted, because such sites can request direct assignments
from APNIC or the relevant NIR and, in the case of IPv4, use private addresses
or arrange transfers.The first sentence remains incongruous with the remainder
of the paragraph and I remain opposedto this proposal on that basis.Other than
the first sentence, the rest of the paragraph still purports to prohibit all
forms of leasingwhich would include: Providers providing dynamic addresses to
customers via DHCP Providers providing addresses to customers for a fee for
a certain time periodAPNIC should proactively investigate lack of compliance
with the original resource request justification, including suspected cases for
any form of leasing and also initiate the investigation in case of reports by
means of a form, email address or other means developed by APNIC.The RIRs were
never intended to be the internet police and expanding their role in this
mannerruns contrary to their core mission (the maintenance of an accurate
registry of unique delegations).If any form of leasing, regardless of when the
delegation has been issued, is confirmed by an APNIC investigation, it will be
considered a policy violation and revocation may apply against any account
holders who are leasing or using them for any purposes not specified in the
initial request.This is the most objectionable part of this policy. It
basically says that if a provider has a /24 that waspreviously issued to XYZ
Company and XYZ Company changes providers, but wishes to pay to retainthe
addresses for use with their other providers, this transaction cannot be
permitted. This is a commontransaction and prohibiting it would be very
disruptive. Especially if that /24 is a single /24 in a /20 oreven larger block
nd the entire block is revoked as a result.Further, things change rapidly on
the internet. It is not at all unusual for providers to have to pivotto new
business opportunities. This stretches far beyond leasing and seeks to cause
revocations forany shift in the business environment (or at the very least a
requirement for RIR approval of anynew business model).That’s egregious,
IMHO.Owen5. Advantages /
Disadvantages-----------------------------Advantages:Fulfilling the objective
above indicated and making the policy clear.Disadvantages:None. APNIC can
already do this today, however, existing policies don’t explicit them
clearly.6. Impact on resource holders-----------------------------None, unless
they violate policies, but this proposal don’t change that, only clarify it.7.
References-------------•
https://www.arin.net/participate/policy/proposals/2022/ARIN_prop_308_v2/•
https://politicas.lacnic.net/politicas/detail/id/LAC-2022-2/language/en
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