On Oct 31, 2019, at 3:10 PM, Scott Leibrand <scottleibr...@gmail.com
<mailto:scottleibr...@gmail.com>> wrote:
On Thu, Oct 31, 2019 at 3:03 PM Kiran Malancharuvil
<k...@openiadvisors.com <mailto:k...@openiadvisors.com>> wrote:
Dear All,
Prior to tomorrow's community discussion of Draft Policy
ARIN-2019-18, I wanted to offer some clarification and propose
some language for consideration to address questions posed on the
PPML.
Regarding the question over the intended meaning of
"non-connected networks", I will clarify that I mean this policy
to refer to re-assignment to organizations and entities which do
not receive connectivity from the original registrant.
As such, I wanted to offer the following alternative edit to 8.5.2:
8.5.2 Operational Use
ARIN allocates or assigns number resources to organizations
via transfer */primarily/* for the purpose of use on an
operational network, */but may allocate or assign number
resources to organizations for other purposes, including
re-assignment to organizations and entities which do not
receive connectivity from the original registrant/.*
I believe this is consistent with the intent of 2019-18, and I would
support this language.
Alternatively, and more simply, since the sentence referencing
"non-connected networks" starts with "including" and is therefore
not meant to be an exclusive "other purpose", but rather
illustrative, we can remove it entirely. That option would read:
8.5.2 Operational Use
ARIN allocates or assigns number resources to organizations
via transfer */primarily/* for the purpose of use on an
operational network, */but may allocate or assign number
resources to organizations for other purposes. /*
I believe this is materially different than the text above, in that
it would give ARIN permission to approve transfers for any reason
whatsoever. ARIN in the past has interpreted such ambiguity in favor
of allowing whatever is not expressly prohibited. As such, I don't
think this language accomplishes the original intent, and would
oppose it.
-Scott
/*please note that the online version of the policy proposal
reads "solely primarily" instead of "primarily". This is a
typo due to originally proposing the language with the word
"solely" in strike-through text (solely), which did not
translate. /
Further, I want to clarify, as the original author of the
proposal, that the key intent of the policy is to acknowledge
that small and medium-sized businesses have a need for IPv4
space, but often cannot afford to buy space in the current
market. Legitimizing a subleasing market increases accessibility
to IPv4 space, and opens the market to business solutions to
facilitate safe, trusted subleasing practices, including keeping
the correct registry updated.
Thanks all for the continued discussion.
Best,
Kiran
--
Kiran Malancharuvil
Open-i Advisors
p: 415 419 9138
http://openiadvisors.com <http://openiadvisors.com/>
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