I express opposition to this policy change.

There seems to me a misunderstanding of the term sub assignments in the 
proposal.

A subassignment is an issuance of a portion of your prefix to an external third 
party recorded at the RIR level or provided in a public database (e.g. whois, 
rwhois, or RDAP).

Point to point prefixes are generally exempt from being reported to the 
registry. In the case of a guest WiFi or VPN, again, these are not generally 
considered to be external subassignments subject to reporting.

The intent of the policy as written as I understand it (and staff, please 
clarify if APNIC is applying different interpretation) is to cover situations 
where an LIR (whether service provider or otherwise) is making recorded 
delegations of smaller blocks of address space to external entities (e.g. when 
an ISP assigns a /48 to a customer end site). It is not intended to and does 
not (to the best of my knowledge) preclude any of the use cases you have 
mentioned.

Owen


> On Feb 21, 2019, at 21:46 , JORDI PALET MARTINEZ <jordi.pa...@consulintel.es> 
> wrote:
> 
> Dear Satoru, all,
>  
> First of all, thanks a lot for your inputs!
>  
> Let me try to clarify this.
>  
> The text of the problem statement has been the same (maybe minor variations) 
> across the 4 previous versions, so it is difficult to understand what is not 
> clear now, which can have been addressed before.
>  
> In any case, what it matters in a policy proposal, is the policy text and the 
> objective of the change.
>  
> What happens with current policy is that if you’re an enterprise with 
> assigned addressing space, you can only use it for your own infrastructure 
> and within it.
>  
> If you want to have a “guest” WiFi (visitors in the company, students in a 
> University), or you need to provide it via VPN, or point-to-point links, it 
> is not allowed. The problem statement just provides more examples and cases, 
> but everything boils down to the same.
>  
> I don’t think that was the intended purpose of the original policy, but that 
> text has been carried out from IPv4 policies, and in most of the cases, there 
> you don’t have the same problem because you’re providing to the visitors or 
> students private addressing space behind a NAT.
>  
> Let me know please, if this is clearer as a “short” for the problem statement 
> and objective of the policy change.
> 
> Regards,
> Jordi
> 
>  
> 
>  
>  
> De: <sig-policy-boun...@lists.apnic.net> en nombre de Satoru Tsurumaki 
> <satoru.tsurum...@g.softbank.co.jp>
> Fecha: viernes, 22 de febrero de 2019, 12:29
> Para: Policy SIG <sig-pol...@apnic.net>
> Asunto: Re: [sig-policy] prop-124-version 5: Clarification on IPv6 
> Sub-Assignments
>  
> Dear Colleagues,
>  
> I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team.
>  
> I would like to share a feedback in our community for prop-124,
> based on a meeting we organized on 12th Feb to discuss these proposals.
>  
> Many participants expressed a neutral for the proposal with reasons that
> the problem in the current policy is something vague.
>  
> And a few opposing comments were expressed with same reason as above.
>  
>  
> Best Regards,
>  
> Satoru Tsurumaki
> JPOPF-ST
>  
> 2019年1月10日(木) 13:28 Bertrand Cherrier <b.cherr...@micrologic.nc 
> <mailto:b.cherr...@micrologic.nc>>:
>> Dear SIG members,
>> 
>> We wish you all the best for this new year !
>> 
>> A new version of the proposal "prop-124: Clarification on IPv6
>> Sub-Assignments"
>> has been sent to the Policy SIG for review.
>> 
>> Information about earlier versions is available from:
>> 
>> https://www.apnic.net/community/policy/proposals/prop-124 
>> <https://www.apnic.net/community/policy/proposals/prop-124>
>> 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.
>> 
>> Kind Regards,
>> 
>> Sumon, Bertrand, Ching-Heng
>> APNIC Policy SIG Chairs
>> 
>> prop-124-v005: Clarification on IPv6 Sub-Assignments
>> 
>> Proposer: Jordi Palet Martínez
>> jordi.pa...@theipv6company.com <mailto:jordi.pa...@theipv6company.com>
>> 1. Problem Statement
>> 
>> When the policy was drafted, the concept of assignments/sub-assignments
>> did not consider a practice very common in IPv4 which is replicated and
>> even amplified in IPv6: the use of IP addresses for point-to-point links
>> or VPNs.
>> 
>> In IPv4, typically, this is not a problem because the usage of NAT.
>> 
>> In the case of IPv6, instead of unique addresses, the use of unique
>> prefixes (/64) is increasingly common.
>> 
>> Likewise, the policy failed to consider the use of IP addresses in
>> hotspots hotspots (when is not an ISP, for example, associations or
>> community networks), or the use of IP addresses by guests or employees
>> in Bring Your Own Device (BYOD) and many other similar cases.
>> 
>> One more case is when an end-user contracts a third-party to do some
>> services in their own network and they need to deploy their own devices,
>> even servers, network equipment, etc. For example, security surveillance
>> services may require that the contractor provides their own cameras,
>> recording system, even their own firewall and/or router for a dedicated
>> VPN, etc. Of course, in many cases, this surveillance system may need
>> to use the addressing space of the end-user.
>> 
>> Finally, the IETF has recently approved the use of a unique /64 prefix
>> per interface/host (RFC8273) instead of a unique address. This, for
>> example, allows users to connect to a hotspot, receive a /64 such that
>> they are “isolated” from other users (for reasons of security, regulatory
>> requirements, etc.) and they can also use multiple virtual machines on
>> their devices with a unique address for each one (within the same /64).
>> 
>> 2. Objective of policy change
>> 
>> Section 2.2.3. (Definitions/Assigned Address Space), explicitly prohibits
>> such assignments, stating that “Assigned ... may not be sub-assigned”.
>> 
>> This proposal clarifies this situation in this regard and better define
>> the concept, particularly considering new uses of IPv6 (RFC8273), by means
>> of new text.
>> 
>> It also clarifies that the usage of sub-assignments in ISPs, data centers
>> and similar cases is not allowed.
>> 
>> 3. Situation in other regions
>> 
>> This situation, has already been corrected in RIPE, and the policy was
>> updated in a similar way, even if right now there is a small discrepancy
>> between the policy text that reached consensus and the RIPE NCC Impact
>> Analysis. A new policy proposal has been submitted to amend that, and
>> the text is the same as presented by this proposal at APNIC. Same text
>> has also been submitted to AfriNIC (already reached consensus), LACNIC
>> and ARIN.
>> 
>> 4. Proposed policy solution
>> 
>> Add a new paragraph after the existing one in 2.2.3.
>> 
>> Actual text:
>> 
>> 2.2.3. Assigned address space
>> Assigned address space is address space that is delegated to an LIR,
>> or end-user, for specific use within the Internet infrastructure they
>> operate. Assignments must only be made for specific, documented purposes
>> and may not be sub-assigned.
>> 
>> New text:
>> 
>> 2.2.3. Assigned address space
>> Assigned address space is address space that is delegated to an LIR,
>> or end-user, for exclusive use within the infrastructure they operate,
>> as well as for interconnection purposes.
>> 
>> The address space assignment is only for use by the original holder of said
>> assignment, as well as for third party devices, as long as they are
>> operating
>> within the original holder infrastructure.
>> 
>> Sub-assignments are not allowed outside that infrastructure (for example
>> using
>> sub-assignments for ISP customers), neither for providing addressing
>> space to
>> third parties in data-centers (or similar cases).
>> 
>> 5. Advantages / Disadvantages
>> 
>> Advantages:
>> Fulfilling the objective above indicated and making sure to match the real
>> situation in the market.
>> 
>> Disadvantages:
>> None foreseen.
>> 
>> 6. Impact on resource holders
>> 
>> None.
>> 
>> 7. References
>> 
>> Links to RIPE policy amended and new policy proposal submitted.
>> 
>> *              sig-policy:  APNIC SIG on resource management policy          
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