It's very good to have your feedback for the secretariat, thanks Tsurumaki-san.

Please feel free to let us know of any other improvements that we can help 
with, any time.

Paul.

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On Sep 1, 2023, at 13:16, Satoru Tsurumaki 
<stsur...@gmail.com<mailto:stsur...@gmail.com>> wrote:

Dear Colleagues,

I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team.

I would like to express my gratitude to Policy-Sig Chair/Co-Chair and
the APNIC Secretariat.
In the past, policy proposals were posted to the SIG-Policy ML in
batches after the proposal
deadline four weeks before OPM, but now they have posted the proposed
policies sequentially
to the SIG-Policy ML without waiting for the deadline.
This allowed us enough time to translate the proposals and introduce
them to our community for discussion.

Then I would like to share key feedback in our community for prop-148,
based on a meeting we organised on 30th Aug to discuss these proposals.

Many neutral opinions were expressed about this proposal.

(comment details)
 - I agree with the concept of prohibiting leases, but the proposal
   should not affect to the party who has leased the IPv4 from another party.

 - JPNIC has a text equivalent to prohibiting leasing in its guidelines.
   If this proposal becomes a consensus, it is necessary to consider
   including similar text in the address policy depending on its content.

Regards,

Satoru Tsurumaki / JPOPF Steering Team

2023年8月5日(土) 2:00 Shaila Sharmin <shaila.sharmin....@gmail.com>:

 Dear SIG members,

 A new version of the proposal "prop-148-v004: Clarification - Leasing of 
Resources is not Acceptable" has been sent to the Policy SIG for review.

 Information about earlier versions is available from:

 http://www.apnic.net/policy/proposals/prop-148

 You are encouraged to express your views on the proposal:

   - Do you support or oppose the proposal?
   - Is there anything in the proposal that is not clear?
   - What changes could be made to this proposal to make it more effective?

 Please find the text of the proposal below.

 Regards,
 Bertrand, Shaila, and Anupam
 APNIC Policy SIG Chairs


________________________________


 prop-148-v004: Clarification - Leasing of Resources is not Acceptable

________________________________


 Proposer: Jordi Palet Martinez (jordi.pa...@theipv6company.com)
            Amrita Choudhury (amritachoudh...@ccaoi.in)
            Fernando Frediani (fhfred...@gmail.com)


 1. Problem statement
 --------------------
 RIRs have been conceived to manage, allocate and assign resources
 according to need, in such way that a LIR/ISP has addresses to be able
 to directly connect its customers based on justified need. Addresses are
 not, therefore, a property with which to trade or do business.

 When the justification of the need disappears or changes, for whatever
 reasons, the expected thing would be to return said addresses to the
 RIR, otherwise according to Section 4.1. (“The original basis of the
 delegation remains valid”) and 4.1.2. (“Made for a specific purpose that
 no longer exists, or based on information that is later found to be
 false or incomplete”) of the policy manual, APNIC is not enforced to
 renew the license. An alternative is to transfer these resources using
 the appropriate transfer policy.

 If the leasing of addresses is authorized, contrary to the original
 spirit of the policies and the very existence of the RIRs, the link
 between connectivity and addresses disappears, which also poses security
 problems, since, in the absence of connectivity, the resource holder who
 has received the license to use the addresses does not have immediate
 physical control to manage/filter them, which can cause damage to the
 entire community.

 Therefore, it should be made explicit in the Policies that the Internet
 Resources should not be leased “per se”, but only as part of a
 connectivity service, as it was documented with the original need
 justification.

 The existing policies of APNIC are not explicit about that, however
 current policies do not regard the leasing of addresses as acceptable,
 if they are not an integral part of a connectivity service.
 Specifically, the justification of the need would not be valid for those
 blocks of addresses whose purpose is not to directly connect customers
 of an LIR/ISP, and consequently the renewal of the annual license for
 the use of the addresses would not be valid either. Sections 3.2.6.
 (Address ownership), 3.2.7. (Address stockpiling) and 3.2.8.
 (Reservations not supported) of the policy manual, are keys on this
 issue, but an explicit clarification is required.

 2. Objective of policy change
 -----------------------------
 Despite the fact that the intention in this regard underlies the entire
 Policy Manual text and is thus applied to justify the need for
 resources, this proposal makes this aspect explicit by adding the
 appropriate clarifying text.


 3. 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 and LACNIC, the
 staff has confirmed that address leasing is not considered as valid for
 the justification. In ARIN it is not considered valid as justification
 of need.

 A similar proposal is under discussion in LACNIC and ARIN.


 4. Proposed policy solution
 ---------------------------
 5.8. Leasing of Internet Number Resources

 In the case of Internet number resources delegated by APNIC or a NIR,
 the justification of the need implies the need to use on their own
 infrastructure and/or network connectivity services provided to
 customers. As a result, any form of IP address leasing is unacceptable,
 nor does it justify the need, unless otherwise justified in the original
 request. Even for networks that are not connected to the Internet,
 leasing of IP addresses is not permitted, because such sites can request
 direct assignments from APNIC or the relevant NIR and, in the case of
 IPv4, use private addresses or arrange market transfers.

 APNIC should proactively investigate those cases and also initiate the
 investigation in case of reports by means of a form, email address or
 other means developed by APNIC.

 If any form of leasing, regardless of when the delegation has been
 issued, is confirmed by an APNIC investigation, it will be considered a
 policy violation and revocation may apply against any account holders
 who are leasing or using them for any purposes not specified in the
 initial request.


 5. Advantages / Disadvantages
 -----------------------------
 Advantages:
 Fulfilling the objective above indicated and making the policy clear.

 Disadvantages:
 None.


 6. Impact on resource holders
 -----------------------------
 None.


 7. References
 -------------
 https://www.arin.net/participate/policy/proposals/2022/ARIN_prop_308_v2/
 https://politicas.lacnic.net/politicas/detail/id/LAC-2022-2/language/en
 --
 Regards,
 Shaila Sharmin
 +8801811447396
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