Hi, I am strongly in opposition of this policy. There is no need to change the policy related to this in my opinion. Regards, Ajai Kumar
On Mon, 22 Aug 2022 at 22:47, Mike Burns <m...@iptrading.com> wrote: > There are a number of problems with this policy. > > > > First let’s start with Jordi stating the policy is just a clarification of > fact. > > If so, why is it necessary? Actually it is not a fact as leasing is > occurring in APNIC and there is nothing in policy preventing it. So this > needs to be considered as a change in policy. > > > > Second, there are inaccuracies in the verbiage associated with the policy, > particularly in reference to the status of leasing at other RIRs. How can > you make the statement “ In other RIRs, the leasing of addresses is not > authorized either and since it is not explicit in their policy manuals…”? > > > > Are you unilaterally deciding that things which are not mentioned in > policy are by definition “unauthorized”? I think this is wrong, and it’s > better to consider things as authorized unless they are forbidden by > policy. However, either way there is no language in any RIR regarding > leasing and you can’t make assumptions based on your own feelings. > > > > You are also wrong in stating that “Nothing is currently mentioned in RIPE > about this and it is not acceptable as a justification of the need.” In > actual fact, RIPE will accept leased-out addresses as justification of need > in the only case where RIPE actually has a needs test, and that is with > inter-regional transfers sourced in ARIN. It bears remembering that RIPE > simply has no needs test for transfers and this has been the policy for > many years. You may wonder what the point of a needs-test for transfers > is, since the recipients are paying for the addresses. > > > > ARIN staff has made it known that leasing addresses is not against policy > at all, but leased-out addresses can’t be used to justify transfers. > However a policy explicitly allowing leased-out addresses to be used as > justification is under consideration. > > > > Also leases can be used to justify addresses in ARIN if any tiny > connectivity is created between the lessor and lessee. For example, a small > VPN can be created, even though it carries no (or nearly no) traffic. If > you want to get technical, the lessor and the lessee both advertise the > block, but the lessor advertises a longer and more expensive route than the > lessee, who will receive all the traffic except for any loose packets that > find their way to the lessor, who will send them down the tunnel to the > lessee. > > > > The issue of retention of a needs test should be reconsidered by the APNIC > community in the face of evidence garnered from the RIPE experiment. RIPE > has had no needs test and APNIC had also removed the needs-test for > transfers but only restored it at the behest of ARIN, who at the time was > the only source for desperate APNIC members faced with APNIC exhaust. Now > there are other sources for inter-regional transfers to APNIC, and APNIC > can take the path of RIPE in performing needs test only for inbound ARIN > transfers so that source would not be precluded. So why not return to > APNIC’s previous position of removing the needs test from transfers? > > > > Leasing is a natural progression of the IPv4 market that provides benefits > to both lessee and lessor, and that is why it is inevitable and why it > exists today. There are those who hold unused addresses but who don’t want > to sell for some reason. There are those who need IPv4 but who can’t afford > to pay for it all at once. There are those with a temporary need. Leasing > is the answer for the smaller organizations that need IPv4. There are no > addresses left in the free pool, so it’s either buy or lease. No other > options. > > > > Today APNIC (and ARIN and RIPE) will allow existing address holders to > lease their blocks to non-connected customers. This is not a policy > violation and addresses can’t be revoked for reasons of utilization or > non-utilization. I believe that contra this policy, leasing should be > authorized explicitly and that leased out addresses in-use on an > operational network should logically be accepted as justification, because > does it really matter whose network they are used on? Isn’t the salient > point that they are in use? > > > > I am against this policy. > > > > Regards, > Mike Burns > > > > > > > > > > > > > > *From:* JORDI PALET MARTINEZ via sig-policy <sig-policy@lists.apnic.net> > *Sent:* Monday, August 22, 2022 9:21 AM > *To:* Srinivas (Sunny) Chendi <su...@apnic.net>; > sig-policy@lists.apnic.net > *Subject:* [sig-policy] Re: prop-148-v001: Leasing of Resources is not > Acceptable > > > > Hi Sunny, all, > > > > In my opinion because the policy is just a clarification of a fact, it > doesn’t change the situation for non-LIR/ISP account holders. Further to > that, direct assignments from APNIC can’t be further sub-assigned, so > clearly this disallows any type of “business” with addresses for those > account holders. Do you think that’s sufficiently clear or do you think a > small text clarification in the proposal is needed? > > > > Regarding your 2nd point, there is not already a generic contact email to > let know APNIC if anything is wrong regarding policy compliance? It will be > surprising that today anyone discovers some breach and can’t report it, so > this will also apply the same to this proposal. Again, if you believe a > text clarification is needed, we can make a new version for that. > > > > Finally, regarding your 3rd question, in my understanding the policy > manual apply to **all the resources** unless we state otherwise. So not > only those after being implemented are subjected to this proposal. And once > more, the proposal is only a clarification, not changing what is the > current reality. Anyway, we are happy to state it more clearly if needed. > > > > Tks! > > > > Regards, > > Jordi > > @jordipalet > > > > > > El 22/8/22, 2:45, "Srinivas (Sunny) Chendi" <su...@apnic.net> escribió: > > > > Hi all, > > This is the secretariat's impact assessment for prop-148-v001, which is > also > available on the proposal page. > > http://www.apnic.net/policy/proposals/prop-148 > > APNIC notes that this proposal suggests explicitly stating in the APNIC > Internet Number Resources policy document that leasing of IP addresses is > not permitted in the APNIC region. > > *Clarifications:* > > Is this proposal restricted to LIRs/ISPs, or does it apply to all APNIC > account holders? > > The proposal does not specify how an APNIC investigation should be > initiated. > Should there be a form to report this, similar to IRT escalation? > > Does this proposal apply to all existing allocations or only those > delegated > after the policy is implemented? > > *Implementation:* > > This proposal may require changes to the system. > > If this proposal reaches consensus, implementation may be completed within > 3 months. > > Regards, > Sunny > APNIC Secretariat > > On 11/08/2022 5:01 pm, chku wrote: > > Dear SIG members, > > > > The proposal "prop-148: Leasing of Resources is not Acceptable" has been > > sent to the Policy SIG for review. > > > > It will be presented at the Open Policy Meeting (OPM) at APNIC 54 on > > Thursday, 15 September 2022. > > > > https://conference.apnic.net/54/program/schedule/#/day/8 > > > > We invite you to review and comment on the proposal on the mailing list > > before the OPM. > > > > The comment period on the mailing list before the OPM is an important > > part of the Policy Development Process (PDP). We encourage you to > > express your views on the proposal: > > > > - Do you support or oppose this proposal? > > - Does this proposal solve a problem you are experiencing? If so, > > tell the community about your situation. > > - Do you see any disadvantages in this proposal? > > - Is there anything in the proposal that is not clear? > > - What changes could be made to this proposal to make it more effective? > > > > Information about this proposal is appended below as well as available at: > > > > http://www.apnic.net/policy/proposals/prop-148 > > > > Regards, > > Bertrand, Shaila, and Ching-Heng > > APNIC Policy SIG Chairs > > > > --------------------------------------------------------------- > > > > prop-148-v001: Leasing of Resources is not Acceptable > > > > ---------------------------------------------------------------- > > > > Proposer: Jordi Palet Martinez (jordi.palet@theipv6company.comAnupam) > > 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 direct > connectivity service. > > > > 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, the justification of the need > implies the need to directly connect customers. As a result, any form of IP > address leasing is not considered acceptable, nor does it justify the need, > if it is not part of a set of services based, at the very least, on direct > connectivity. 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. > > > > If any form of leasing is confirmed by an APNIC investigation, APNIC may > revoke the IP resources of account holders who are leasing or using them for > any purposes not specified in the initial request. > > > > This includes, but not limited to, the following: > > - Removing delegations from the Whois database. > > - Removing related ROAs. > > - Stop providing APNIC services. > > > > Members of the NIR are subject to the same policy. > > > > > > 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://aus01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.arin.net%2Fparticipate%2Fpolicy%2Fproposals%2F2022%2FARIN_prop_308_v2%2F&data=05%7C01%7C%7C10362f529b0e4536949408da7b677a41%7C127d8d0d7ccf473dab096e44ad752ded%7C0%7C0%7C637957981611076664%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=uhhDD0kaOyJOxHiWa7Z%2BckfPwe9ohLQsidzS9u4BUHo%3D&reserved=0 > > https://aus01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fpoliticas.lacnic.net%2Fpoliticas%2Fdetail%2Fid%2FLAC-2022-2%2Flanguage%2Fen&data=05%7C01%7C%7C10362f529b0e4536949408da7b677a41%7C127d8d0d7ccf473dab096e44ad752ded%7C0%7C0%7C637957981611076664%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=p7nZJRM2zzi2kBOyLeSA%2BOo1qGTU1rBB3VIvQoaLYz0%3D&reserved=0 > > _______________________________________________ > > sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ > > To unsubscribe send an email to sig-policy-le...@lists.apnic.net > > > > -- > > > > _______________________________________________________________________ > > > > Srinivas (Sunny) Chendi (he/him) > > Senior Advisor - Policy and Community Development > > > > Asia Pacific Network Information Centre (APNIC) | Tel: +61 7 3858 3100 > > PO Box 3646 South Brisbane, QLD 4101 Australia | Fax: +61 7 3858 3199 > > 6 Cordelia Street, South Brisbane, QLD | http://www.apnic.net > > _______________________________________________________________________ > > > > NOTICE: This email message is for the sole use of the intended recipient(s) > > and may contain confidential and privileged information. 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