On Jul 10, 2023, at 10:22, John Curran <jcurran@arin.net> wrote:

On Jul 5, 2023, at 10:06 PM, Owen DeLong via NANOG <nanog@nanog.org> wrote:
...
Opinions regarding leasing vary throughout the industry. In my opinion, since the shift to provider assigned addresses during the CIDR efforts in the mid 1990s, the majority of addresses have been leased in one form or another. 

The only thing novel here is the leasing of addresses independent of connectivity services. However, once the RIRs and their communities normalized the sale of addresses through directed transfer policies, I think this was an inevitable next step in the devolution of IPv4 into a monetized asset. 

It doesn’t help that the earliest and most prolific adopters of this form of leasing have been snowshoe spammers. 

However, there are leasing agencies that insist on getting proper justification from their customers and have strong anti-abuse policies. I would strongly encourage you to seek out such an organization to partner with if you choose to lease your addresses as there are a number of pitfalls you can encounter otherwise. 

To follow-up on Owen’s points and clarify just a bit (at least to respect to policy in the ARIN region) – 

– IP address blocks in the ARIN region are issued by ARIN based upon operational need (as per the community-developed policy document in the Number Resource Policy Manual [NRPM - https://www.arin.net/participate/policy/nrpm/]) 

– Portions of IP address blocks are routinely “leased” by ISPs to customers, although such leasing has historically been as part of a bundle including connectivity services.

– Because one needs IP addressed to provide connectivity services, leasing of address space as part of providing connectivity is considered operational need (and as such counts towards utilization of one’s address space) 

– Leasing of IP address space independent of connectivity doesn’t fulfill operational need, and hence doesn’t count as utilization when you come back to ARIN seeking additional space (or approval of a transfer inwards of an IP address block)

Exceptions apply. For example, I know of situations where providers have continued to lease addresses to former customers that wanted to avoid renumbering,
yet ARIN has permitted those addresses to be counted as utilized during applications for additional space. I don’t know if these exceptions were intentional on
ARIN’s part or not, but they have definitely occurred and I’m not convinced that ARIN could reject them under existing policy.

– Leasing of IP address blocks independent of connectivity is not explicitly recognized in ARIN number resource policy (i.e. there is no policy that specifically allows or prohibits such activity.) 

Correct me if I am wrong here, but in general, that which is not explicitly prohibited is implicitly allowed.

– In the ARIN region, we have fairly clear guidelines requiring documentation [via SWIP, RWHOIS, RDAP…] of significant reassignment/reallocations to connectivity customers (as part of documenting IP address block usage), but no clear requirements for reporting of reissuance of space via leasing independent of connectivity.  Furthermore, all address blocks in the ARIN registry are required to have accurate abuse contacts (unless residential in which case accurate contacts must be in the upstream providers block.)

Actually, I couldn’t find anything in the NRPM which leads me to believe that there is any distinction in the documentation requirements for reassignment/reallocation regardless of associated connectivity. None of the policies seemed to specify this. As such, I would think that Connectivity Independent Leasing (CIL) and Connectivity Related Leasing (CRL) would be subject to exactly the same recording/reporting requirements.

If folks wish to have the registry operate accordingly to some other policies, please submit a policy proposal <https://www.arin.net/participate/policy/pdp/appendix_b/> (or seek out a member of the ARIN Advisory Council <https://www.arin.net/about/welcome/ac/> which helps shepherd the policy development process and can assist you with preparation of same…) 

I think that you know that if I had a problem with the current status quo, I would do exactly that. ;-) I have never hesitated in the past.

Owen