IP range for lease

Tue Jul 11 21:14:22 UTC 2023

> On Jul 11, 2023, at 09:52, John Curran <jcurran at arin.net> wrote:
> 
> 
> 
>> On Jul 11, 2023, at 12:40 PM, Owen DeLong <owen at delong.com> wrote:
>> 
>> 
>>> On Jul 11, 2023, at 09:04, John Curran <jcurran at arin.net> wrote:
>>> 
>>> ...
>>> 
>>> Of course, further policy clarity (whether to make clear that it does apply to non-connectivity reassignments or to make clear it does not apply beyond downstream customers) would be most welcome; I believe you are already aware of the policy proposal submission process if you want to propose updating it accordingly.
>> 
>> All of the organizations I know of that are leasing space apply the term downstream as it pertains to the issuance of the addresses regardless of the connectivity relationship.
> 
> That may be the case, but since the earliest days of ARIN the term “downstream” has been used by this operator community to refer to customer connectivity, so we’ll maintain current usage until directed otherwise by the community. 
> 
>> I suppose policy clarity here could be useful,
> 
> Indeed.
> 
>> … but I suspect that just like ISPs, the situation will basically boil down to “those that want to comply will do so in good faith and others will not.”
> 
> That is also up to the community, as there is an obvious tradeoff between enforcement and registry accuracy – if the community wishes more accuracy in the registry, there needs to be clarity in policy regarding what actions ARIN should take with respect to non-compliance. 
> 
> Thanks!
> /John
> 
> John Curran
> President and CEO
> American Registry for Internet Numbers
> 
> 
> 

In fact, John, some further NRPM research reveals the following:

1.	Downstream references almost all apply to address issuance limitations and customer utilization limitations.
	The only places the term is applied to registration are NRPM 4.2.3..3.2 (Residential customer privacy),
	NRPM 6.5.5.3.1 (Residential Customer Privacy)  and NRPM 6.5.5.4 (Registration Requested by Recipient)..

2.	Language requiring registration of reallocations and reassignments are as follows:

4.2.3.7. Registration
ISPs are required to demonstrate efficient use of IP address space allocations by providing appropriate documentation, including but not limited to assignment histories, showing their efficient use.
4.2.3.7.1. Reassignment and Reallocation Information

Each IPv4 reassignment or reallocation containing a /29 or more addresses shall be registered via SWIP or a directory services system which meets the standards set forth in section 3.2.

Reassignment registrations must include each customer name, except where specifically exempted by this policy. Reassignment registrations shall only include point of contact (POC) information if either: (1) requested by the customer; or (2) the reassigned block is intended to be routed and announced outside of the provider’s network.

Reallocation registrations must contain the customer’s organization name and appropriate point of contact (POC) information.
4.2.3.7.2. Reassignments and Reallocations Visible Within Seven Days
All reassignments and reallocations shall be made visible as required in section 4.2.3.7.1 within seven calendar days of reassignment or reallocation.
6.5.5. Registration
ISPs are required to demonstrate efficient use of IP address space allocations by providing appropriate documentation, including but not limited to reassignment and reallocation histories, showing their efficient use.
6.5.5.1. Reassignment Information
Each static IPv6 reassignment or reallocation containing a /47 or more addresses, or subdelegation of any size that will be individually announced, shall be registered in the WHOIS directory via SWIP or a distributed service which meets the standards set forth in section 3.2. Reassignment and reallocation registrations shall include each client’s organizational information, except where specifically exempted by this policy.
6.5.5.2. Reassignments and Reallocations Visible Within Seven Days
All reassignments and reallocations shall be made visible as required in section 6.5.5.1 within seven calendar days of reassignment or reallocation.
3.	I don’t see anything ambiguous in that text that would exclude reassignments or reallocations independent of connectivity from the registration requirements.

4.	It is my belief that N$PM4 policies still govern IPv4 space held by ARIN subscribers regardless of whether it was obtained by the current registrant as a result of NRPM4 or NPRM8. Please let me know if that is in error.

Owen

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