The error in what Fernando just said is: parent companies do not, in fact, transfer their possibly-valuable IP space to subsidiaries - they assign/allocate instead. Until very recently, that wasn’t possible in many cases, so we wound up with yet another instance of ARIN policy that actively prevented the database from being as accurate as possible. That’s fixed (more or less) as of this year – I admit I haven’t done all the SWIPs I should have by now, now that I can!
My primary concern with this policy is that it will do much the same – drive leasing underground, and the public registry will then fail to accurately reflect reality in yet another way. I hold ARIN’s goal of maintaining an open, accurate database of IP address usage to be ultimately far more important than its explicit non-goal of regulating IP address usage. I believe this proposal tries to put ARIN into the role of “Internet cop” again and is inappropriate. Preventing legitimate users from using leased IP addresses does not help the internet. Preventing illegitimate users from doing so might well help the internet, but leads straight into the classic “only criminals will have guns” argument – why would anyone with a shady use ever use truthful information in an application to ARIN in the first place? -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/> [cid:image002.png@01D8C69E.A8DE4120]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. _______________________________________________ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net<mailto:ARIN-PPML@arin.net>). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net<mailto:i...@arin.net> if you experience any issues. _______________________________________________ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net<mailto:ARIN-PPML@arin.net>). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net<mailto:i...@arin.net> if you experience any issues. _______________________________________________ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net<mailto:ARIN-PPML@arin.net>). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net<mailto:i...@arin.net> if you experience any issues. _______________________________________________ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net<mailto:ARIN-PPML@arin.net>). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net<mailto:i...@arin.net> if you experience any issues.
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