I also agree with what has been said, and am also opposed to the proposal.
Some of the justification seems to be in the form of "I cannot afford to
buy a car, so I demand that someone permit me to lease one". Noone is
going to get into the car leasing business unless they can make money.
Generally the only money making segment is going to be the short term,
since the lessors profit is going to make buying cheaper than leasing in
the longer term. I think the same applies to IP leasing.
In the case of IP address leasing, the only major users of short term
leases are abusers. The advancers of this proposal talk of longer term
leases to get discussion away from those abusers. However, most of the
time, someone wanting a long term lease would be better off to buy, as
they can always sell them on again at the end of the need and often
recover nearly all of their original investment, effectively having a
short term use of the address space nearly free. I think the long term
IP leasing business model will not work.
The only valid leasing I can see is an entity that has excess address
space that they expect to use in the future, and I think that case is
already addressed in the current rules. They would also be unlikely to
lease to someone that is an abuser, since they will have to live with the
block reputation after the lease ends.
Albert Erdmann
Network Administrator
Paradise On Line Inc.
On Fri, 1 Nov 2019, Fernando Frediani wrote:
Exactly, and the main justification for this proposal to allow subleasing is a
total misuse of IP addressing and a try to privilege specific companies in
detriment to all others.
I do not agree that legitimizing leasing as such increases accessibility to
IPv4 space. Organization already have access to it by transfers. By allowing
leasing as such prices of both leasing and transfer has the potential to rise
significantly as organizations will prefer much more to sublease than to
transfer which is logic to think that will increase pricing in general for both
and which is only interesting to those who are involved in the transaction
and not to those who are seeking for IPv4 space and have already access via
transfers.
The point about keeping the correct registry updated is not a justification
either because this is already a obligation. If someone is not doing that or is
doing things in a different way is going against the current policies. Any
organization who signed a contract when they became a member accepted to follow
these rules and they must bound to them, not the other way round.
As said there is not reasons to issue addresses to anyone who will not be using
them on a operational network other than legitimate speculation of IP space.
I consider the current text in NRPM as appropriate and therefore I oppose this
proposal in full.
Regards
Fernando
On 01/11/2019 11:28, Owen DeLong wrote:
I have trouble with both phrases.
Even if the resources are to be re-assigned to organizations or entities which
do not receive connectivity from the original registrant, I see no
reason to issue addresses to anyone who will not be using them on an
operational network.
Owen
On Oct 31, 2019, at 3:10 PM, Scott Leibrand <scottleibr...@gmail.com>
wrote:
On Thu, Oct 31, 2019 at 3:03 PM Kiran Malancharuvil <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
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