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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 (amritachoudhury@ccaoi.in) Fernando Frediani (fhfredani@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://www.arin.net/participate/policy/proposals/2022/ARIN_prop_308_v2/ https://politicas.lacnic.net/politicas/detail/id/LAC-2022-2/language/en
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/8We 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-148Regards, 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 (amritachoudhury@ccaoi.in) Fernando Frediani (fhfredani@gmail.com)
- 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.
- 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.
- 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.
- 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.
- Advantages / Disadvantages
Advantages: Fulfilling the objective above indicated and making the policy clear.
Disadvantages: None.
- Impact on resource holders
None.
- References
https://aus01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.arin.n... https://aus01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fpoliticas.... _______________________________________________ sig-policy -https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email tosig-policy-leave@lists.apnic.net
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" sunny@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 (amritachoudhury@ccaoi.in) Fernando Frediani (fhfredani@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.n... https://aus01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fpoliticas.... _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.net
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 sunny@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" <sunny@apnic.net mailto:sunny@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 mailto:jordi.palet@theipv6company.comAnupam ) Amrita Choudhury (amritachoudhury@ccaoi.in mailto:amritachoudhury@ccaoi.in ) Fernando Frediani (fhfredani@gmail.com mailto:fhfredani@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.n... 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 &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.... 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 &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-leave@lists.apnic.net mailto:sig-policy-leave@lists.apnic.net
Leasing addresses has been common practice for my entire career in the ISP/CSP world, back when 28.8kbps was normal. Someone with excess would assist a smaller entity while they sorted out AUNIC/APNIC applications (and often learned the ropes). Leasing, while not limited to smaller organisations, benefits those of us who are small ( and do not have caches of resources to help us when a single /24 for 24 months would make an enormous difference to the viability of our business).
On the topic of smaller resource holders, I believe we need to make life easier for them, rather than harder - the fee structure is already biased against someone who holds a /22 compared to a /16, they have limited staff to follow policy, apply for that otherwise leasable /24 etc.
In this day and age the idea that an organisation would voluntarily hand back IPv4 so it can be reallocated seems to be overly optimistic. It is considered a rare and limited supply business asset and a valuable one at that.
Punitive punishments as suggested in the proposal are also about as welcome as another wave of covid inspired lock-downs and reinforce my belief that not only is this proposed policy unsupportable but actually is attempting to do the opposite of what we need to do - that is - change the policy to support and encourage leasing where needs justify. As historical cases show, leasing is useful.
I too am against this policy.
Kind Regards,
Richard
------ Original Message ------ From: "Mike Burns" mike@iptrading.com To: "'JORDI PALET MARTINEZ'" jordi.palet@consulintel.es; "'Srinivas (Sunny) Chendi'" sunny@apnic.net; sig-policy@lists.apnic.net Sent: 23/08/2022 3:17:12 AM Subject: [sig-policy] Re: prop-148-v001: Leasing of Resources is not Acceptable
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 sunny@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" sunny@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-148APNIC 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/8We 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-148Regards, 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 (amritachoudhury@ccaoi.in) Fernando Frediani (fhfredani@gmail.com)
- 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.
- 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.
- 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.
- 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.
- Advantages / Disadvantages
Advantages: Fulfilling the objective above indicated and making the policy clear.
Disadvantages: None.
- Impact on resource holders
None.
- References
https://aus01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.arin.n... https://aus01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fpoliticas.... _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@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 _______________________________________________________________________
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Hi Richard,
Maybe it passed without noticing that is not a valid justification use.
Morally, the correct thing to do is to return unused resources to the RIR. We accepted a way in the middle with transfers. So be it. Transfer the resources that you don’t use, but don’t lease them.
Resources are not meant to make business but to ensure a global, open, stable and secure Internet.
Again, let’s wait for the secretariat confirmation on this.
Regards,
Jordi
@jordipalet
El 22/8/22, 18:07, "Richard Ham" sigpol@edit-co.com escribió:
Leasing addresses has been common practice for my entire career in the ISP/CSP world, back when 28.8kbps was normal. Someone with excess would assist a smaller entity while they sorted out AUNIC/APNIC applications (and often learned the ropes). Leasing, while not limited to smaller organisations, benefits those of us who are small ( and do not have caches of resources to help us when a single /24 for 24 months would make an enormous difference to the viability of our business).
On the topic of smaller resource holders, I believe we need to make life easier for them, rather than harder - the fee structure is already biased against someone who holds a /22 compared to a /16, they have limited staff to follow policy, apply for that otherwise leasable /24 etc.
In this day and age the idea that an organisation would voluntarily hand back IPv4 so it can be reallocated seems to be overly optimistic. It is considered a rare and limited supply business asset and a valuable one at that.
Punitive punishments as suggested in the proposal are also about as welcome as another wave of covid inspired lock-downs and reinforce my belief that not only is this proposed policy unsupportable but actually is attempting to do the opposite of what we need to do - that is - change the policy to support and encourage leasing where needs justify. As historical cases show, leasing is useful.
I too am against this policy.
Kind Regards,
Richard
------ Original Message ------
From: "Mike Burns" mike@iptrading.com
To: "'JORDI PALET MARTINEZ'" jordi.palet@consulintel.es; "'Srinivas (Sunny) Chendi'" sunny@apnic.net; sig-policy@lists.apnic.net
Sent: 23/08/2022 3:17:12 AM
Subject: [sig-policy] Re: prop-148-v001: Leasing of Resources is not Acceptable
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 sunny@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" sunny@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 (amritachoudhury@ccaoi.in)
Fernando Frediani (fhfredani@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.n...
https://aus01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fpoliticas....
_______________________________________________
sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/
To unsubscribe send an email to sig-policy-leave@lists.apnic.net
Hi Mike,
In at least, LACNIC and AFRINIC, it has been made clear by staff, that leasing is not a valid justification for getting resources, *THE SAME as in APNIC*, so if you use that as a justification, the request is denied. If you change the “usage” after the request is passed, then you’re bypassing the original justification, which is also *disallowed*.
I will let the secretariat to confirm if leasing is allowed or not, actually responding to your points on APNIC policies, even if this policy doesn't reach consensus. However, in my opinion the policy manual must be clear enough so nobody can interpret that something is not allowed when actually is not.
Regards,
Jordi
@jordipalet
El 22/8/22, 12:17, "Mike Burns" mike@iptrading.com escribió:
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 sunny@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" sunny@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 (amritachoudhury@ccaoi.in) Fernando Frediani (fhfredani@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.n... https://aus01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fpoliticas.... _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.net
Sorry the email went thru while I was still preparing it …
APNIC confirmed to the authors, that “leasing is not recognized as a valid “use” of resources”.
Further to that, to receive resources for the purpose of “leasing” them to other parties is not recognized under APNIC policies as an acceptable use. APNIC resources are delegated based on demonstrated needs. In order to receive resources (by allocation from APNIC or through transfer from others), the recipient must demonstrate their need for those resources by describing the proposed use of the resources in some specific network infrastructure which they own or control. Implicitly, the recipient could not receive addresses for subsequent reallocation to other purposes, because the actual use of the addresses would be unknown and cannot be subjected to the required assessment of the need.
APNIC policies also state that if the declared use of allocated resources changes fundamentally, then the resources may be subject to reclamation by APNIC.
Is not that clear enough?
Regards,
Jordi
@jordipalet
El 22/8/22, 18:40, "JORDI PALET MARTINEZ" jordi.palet@consulintel.es escribió:
Hi Mike,
In at least, LACNIC and AFRINIC, it has been made clear by staff, that leasing is not a valid justification for getting resources, *THE SAME as in APNIC*, so if you use that as a justification, the request is denied. If you change the “usage” after the request is passed, then you’re bypassing the original justification, which is also *disallowed*.
I will let the secretariat to confirm if leasing is allowed or not, actually responding to your points on APNIC policies, even if this policy doesn't reach consensus. However, in my opinion the policy manual must be clear enough so nobody can interpret that something is not allowed when actually is not.
Regards,
Jordi
@jordipalet
El 22/8/22, 12:17, "Mike Burns" mike@iptrading.com escribió:
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 sunny@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" sunny@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 (amritachoudhury@ccaoi.in) Fernando Frediani (fhfredani@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.n... https://aus01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fpoliticas.... _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.net
Hi Jordi,
Hah, sorry, my reply went to your first message but all my points hold.
No, you are not being clear. Leasing is not the same as justification and you are not clarifying things, quite the opposite.
I am not saying leased addresses can be used for justification. But that does not preclude existing address holders from leasing out their addresses nor does it preclude APNIC members leasing addresses from other members in order to use them.
Can you point me to the “fundamental change in usage“ language you mention below in APNIC policy that renders addresses revokable? This might be the most important element in our discussion.
Regards,
Mike
From: JORDI PALET MARTINEZ jordi.palet@consulintel.es Sent: Monday, August 22, 2022 7:46 PM To: mike@iptrading.com; 'Srinivas (Sunny) Chendi' sunny@apnic.net; sig-policy@lists.apnic.net Subject: Re: [sig-policy] Re: prop-148-v001: Leasing of Resources is not Acceptable
Sorry the email went thru while I was still preparing it …
APNIC confirmed to the authors, that “leasing is not recognized as a valid “use” of resources”.
Further to that, to receive resources for the purpose of “leasing” them to other parties is not recognized under APNIC policies as an acceptable use. APNIC resources are delegated based on demonstrated needs. In order to receive resources (by allocation from APNIC or through transfer from others), the recipient must demonstrate their need for those resources by describing the proposed use of the resources in some specific network infrastructure which they own or control. Implicitly, the recipient could not receive addresses for subsequent reallocation to other purposes, because the actual use of the addresses would be unknown and cannot be subjected to the required assessment of the need.
APNIC policies also state that if the declared use of allocated resources changes fundamentally, then the resources may be subject to reclamation by APNIC.
Is not that clear enough?
Regards,
Jordi
@jordipalet
El 22/8/22, 18:40, "JORDI PALET MARTINEZ" <jordi.palet@consulintel.es mailto:jordi.palet@consulintel.es > escribió:
Hi Mike,
In at least, LACNIC and AFRINIC, it has been made clear by staff, that leasing is not a valid justification for getting resources, *THE SAME as in APNIC*, so if you use that as a justification, the request is denied. If you change the “usage” after the request is passed, then you’re bypassing the original justification, which is also *disallowed*.
I will let the secretariat to confirm if leasing is allowed or not, actually responding to your points on APNIC policies, even if this policy doesn't reach consensus. However, in my opinion the policy manual must be clear enough so nobody can interpret that something is not allowed when actually is not.
Regards,
Jordi
@jordipalet
El 22/8/22, 12:17, "Mike Burns" <mike@iptrading.com mailto:mike@iptrading.com > escribió:
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 mailto:sig-policy@lists.apnic.net > Sent: Monday, August 22, 2022 9:21 AM To: Srinivas (Sunny) Chendi <sunny@apnic.net mailto:sunny@apnic.net >; sig-policy@lists.apnic.net mailto: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" <sunny@apnic.net mailto:sunny@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 mailto:jordi.palet@theipv6company.comAnupam ) Amrita Choudhury (amritachoudhury@ccaoi.in mailto:amritachoudhury@ccaoi.in ) Fernando Frediani (fhfredani@gmail.com mailto:fhfredani@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.n... 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 &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.... 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 &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-leave@lists.apnic.net mailto:sig-policy-leave@lists.apnic.net
Hi
While my company does not hold any resources from APNIC, I would say this policy will put APNIC in a legally dangerous situation as AFRINIC.
RIRs are registration bodies only, using it beyond what registration is, without any real enforcement power, is extremely dangerous.
There are millions of IP address currently in lease in APNIC region, this policy will put APNIC into following situations:
1. APNIC ignored the violation, which rander the policy useless.
2. APNIC selectly enforces the violation, which makes APNIC lose credibility.
3. APNIC enforces the policy, results in millions of end user loss connections and large cooperation starts sueing APNIC, and ends up like AFRINIC.
Registration of IPv4 numbers in a global unique database has commercial value, a small room of policy specialists here is not in any way representing the true community's will.
Also, any IP address is leased, from hosting provider to ISPs, distinguishing and force provider lease with connectivity does not in any way achieve what you want to achieve here, a simple lease contract of very small connectivity service will bypass any policy.
The world is changing, the internet is no longer a small room with few nerds, but effectively modern utility, and it's the time changing with it, recognize what true community will be and act based on that.
Also Jordi, do you understand the legal value of this so called policy, is not more than any company's dress code?
It's a policy made by a private company, like the dress code policy in any company, it really does not go beyond that.
trying to use dress code to tell third parties how to act on their multi billion dollar business, simply doesn't work.
With regards.
Lu
On Tue, 23 Aug 2022 at 08:30, Mike Burns mike@iptrading.com wrote:
Hi Jordi,
Hah, sorry, my reply went to your first message but all my points hold.
No, you are not being clear. Leasing is not the same as justification and you are not clarifying things, quite the opposite.
I am not saying leased addresses can be used for justification. But that does not preclude existing address holders from leasing out their addresses nor does it preclude APNIC members leasing addresses from other members in order to use them.
Can you point me to the “fundamental change in usage“ language you mention below in APNIC policy that renders addresses revokable? This might be the most important element in our discussion.
Regards,
Mike
*From:* JORDI PALET MARTINEZ jordi.palet@consulintel.es *Sent:* Monday, August 22, 2022 7:46 PM *To:* mike@iptrading.com; 'Srinivas (Sunny) Chendi' sunny@apnic.net; sig-policy@lists.apnic.net *Subject:* Re: [sig-policy] Re: prop-148-v001: Leasing of Resources is not Acceptable
Sorry the email went thru while I was still preparing it …
APNIC confirmed to the authors, that “leasing is not recognized as a valid “use” of resources”.
Further to that, to receive resources for the purpose of “leasing” them to other parties is not recognized under APNIC policies as an acceptable use. APNIC resources are delegated based on demonstrated needs. In order to receive resources (by allocation from APNIC or through transfer from others), the recipient must demonstrate their need for those resources by describing the proposed use of the resources in some specific network infrastructure which they own or control. Implicitly, the recipient could not receive addresses for subsequent reallocation to other purposes, because the actual use of the addresses would be unknown and cannot be subjected to the required assessment of the need.
APNIC policies also state that if the declared use of allocated resources changes fundamentally, then the resources may be subject to reclamation by APNIC.
Is not that clear enough?
Regards,
Jordi
@jordipalet
El 22/8/22, 18:40, "JORDI PALET MARTINEZ" jordi.palet@consulintel.es escribió:
Hi Mike,
In at least, LACNIC and AFRINIC, it has been made clear by staff, that leasing is not a valid justification for getting resources, **THE SAME as in APNIC**, so if you use that as a justification, the request is denied. If you change the “usage” after the request is passed, then you’re bypassing the original justification, which is also **disallowed**.
I will let the secretariat to confirm if leasing is allowed or not, actually responding to your points on APNIC policies, even if this policy doesn't reach consensus. However, in my opinion the policy manual must be clear enough so nobody can interpret that something is not allowed when actually is not.
Regards,
Jordi
@jordipalet
El 22/8/22, 12:17, "Mike Burns" mike@iptrading.com escribió:
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 sunny@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" sunny@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-148APNIC 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/8We 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-148Regards,
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 (amritachoudhury@ccaoi.in) Fernando Frediani (fhfredani@gmail.com)
- 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.
- 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.
- 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.
- 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.
- Advantages / Disadvantages
Advantages:
Fulfilling the objective above indicated and making the policy clear.
Disadvantages:
None.
- Impact on resource holders
None.
- References
https://aus01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.arin.n...
https://aus01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fpoliticas....
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Senior Advisor - Policy and Community Development
Asia Pacific Network Information Centre (APNIC) | Tel: +61 7 3858 3100
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This electronic message contains information which may be privileged or confidential. The information is intended to be for the exclusive use of the individual(s) named above and further non-explicilty authorized disclosure, copying, distribution or use of the contents of this information, even if partially, including attached files, is strictly prohibited and will be considered a criminal offense. If you are not the intended recipient be aware that any disclosure, copying, distribution or use of the contents of this information, even if partially, including attached files, is strictly prohibited, will be considered a criminal offense, so you must reply to the original sender to inform about this communication and delete it. _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.net
Hi Jordi,
Thanks for your reply.
What you wrote is about justification not leasing, and is correct not only for LACNIC and AFRINIC but ARIN too, as I tried to clearly express in my post. (Except the draconian belief that a change in usage of addresses makes them revokable, that is not ARIN’s policy.)
Let’s not conflate the act of leasing with the act of using leased addresses as justification.
I tried to be very clear that the first is allowed and the second is not.
If you already have addresses, you can lease them out and not be subject to revocation under current policies in APNIC. And this is in fact happening today with APNIC members. Change in usage does not make APNIC addresses revokable, this is only possible when there is fraud in the justification which is not the same as a mere change in usage.
If we are to discuss leasing, it might make sense to define it, as we are dealing with multiple languages and as somebody else said, leasing is an unclear word in English as it can be applied to either side of the transaction. You might find it hard to define the practice of leasing, and once you do, you can be sure it will take a different form in the market.
As I remember it took some time for you to come around on the idea of a global IPv4 transfer market. I hope you will come to realize that leasing is merely another way of distributing IPv4 to those who need it, and that is our overarching purpose.
You didn’t answer my question of what difference, in terms of justification, does it matter if the addresses are used on the owner’s network or another network?
Regards,
Mike
From: JORDI PALET MARTINEZ jordi.palet@consulintel.es Sent: Monday, August 22, 2022 7:41 PM To: mike@iptrading.com; 'Srinivas (Sunny) Chendi' sunny@apnic.net; sig-policy@lists.apnic.net Subject: Re: [sig-policy] Re: prop-148-v001: Leasing of Resources is not Acceptable
Hi Mike,
In at least, LACNIC and AFRINIC, it has been made clear by staff, that leasing is not a valid justification for getting resources, *THE SAME as in APNIC*, so if you use that as a justification, the request is denied. If you change the “usage” after the request is passed, then you’re bypassing the original justification, which is also *disallowed*.
I will let the secretariat to confirm if leasing is allowed or not, actually responding to your points on APNIC policies, even if this policy doesn't reach consensus. However, in my opinion the policy manual must be clear enough so nobody can interpret that something is not allowed when actually is not.
Regards,
Jordi
@jordipalet
El 22/8/22, 12:17, "Mike Burns" <mike@iptrading.com mailto:mike@iptrading.com > escribió:
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 mailto:sig-policy@lists.apnic.net > Sent: Monday, August 22, 2022 9:21 AM To: Srinivas (Sunny) Chendi <sunny@apnic.net mailto:sunny@apnic.net >; sig-policy@lists.apnic.net mailto: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" <sunny@apnic.net mailto:sunny@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 mailto:jordi.palet@theipv6company.comAnupam ) Amrita Choudhury (amritachoudhury@ccaoi.in mailto:amritachoudhury@ccaoi.in ) Fernando Frediani (fhfredani@gmail.com mailto:fhfredani@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.n... 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 &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.... 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 &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-leave@lists.apnic.net mailto:sig-policy-leave@lists.apnic.net
Hi Jordi,
Please see our comments inline...
On 23/08/2022 9:40 am, JORDI PALET MARTINEZ wrote:
Hi Mike,
In at least, LACNIC and AFRINIC, it has been made clear by staff, that leasing is not a valid justification for getting resources, **THE SAME as in APNIC**, so if you use that as a justification, the request is denied. If you change the “usage” after the request is passed, then you’re bypassing the original justification, which is also **disallowed**.
I will let the secretariat to confirm if leasing is allowed or not, actually responding to your points on APNIC policies, even if this policy doesn't reach consensus. However, in my opinion the policy manual must be clear enough so nobody can interpret that something is not allowed when actually is not.
The same topic was discussed on the apnic-transfers mailing list sometime in June this year. https://mailman.apnic.net/hyperkitty/list/apnic-transfers@apnic.net/thread/P...
I'm copying and pasting my colleague Vivek's response here.
<quote> APNIC delegates IP addresses to Members based on their demonstrated need. What Members can do with that address space once it is no longer needed is impacted by policy requirements. I will provide two examples.
Example 1: Addresses delegated from the last /8 pool cannot be transferred for a minimum of five years. During that time, if the reason for the original request is no longer valid, the resources must be returned to APNIC. https://www.apnic.net/community/policy/resources#8.0.-IPv4-Transfers https://www.apnic.net/community/policy/resources#4.0.-Resource-License
So in this instance, if a Member leases out their IP addresses within five years of receiving the delegation from APNIC, they are clearly not needed for their original declared purpose and must be returned to APNIC.
Example 2: For addresses delegated to a Member more than five years ago, if a Member no longer has the need for the address space, APNIC policy says the Member can choose to transfer it to another organization or return it to APNIC. APNIC policy does not have provisions for leasing. So in the second example, APNIC Members leasing addresses would be doing so outside the policy framework and will not receive APNIC services such as whois registration and RPKI/ROA access related to those addresses. This in turn may make it difficult to freely utilise those addresses on the Internet, due to lack of clear authorisation and a reliance on the registered holder (lessor) to assist. Of course, if the addresses being leased were not delegated by APNIC, then the relevant RIR’s policies apply to those addresses. <unquote>
Regards, Sunny APNIC Secretariat
Regards,
Jordi
@jordipalet
El 22/8/22, 12:17, "Mike Burns" mike@iptrading.com escribió:
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 sunny@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 2^nd 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 3^rd 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" sunny@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 (amritachoudhury@ccaoi.in) Fernando Frediani (fhfredani@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%2Fwww.arin.net%2Fparticipate%2Fpolicy%2Fproposals%2F2022%2FARIN_prop_308_v2%2F&data=05%7C01%7C%7Cff1f47d7d3cb4332f83508da8497de87%7C127d8d0d7ccf473dab096e44ad752ded%7C0%7C0%7C637968085076202445%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=Zd1wq3xTtwE47M8PH0mX3rRpHGytfkJaTeZ%2Bn5ABU7I%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 <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%7Cff1f47d7d3cb4332f83508da8497de87%7C127d8d0d7ccf473dab096e44ad752ded%7C0%7C0%7C637968085076359108%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=fbCVYmRHKMrlxD2uckeuVTuL5OtPFr260AW8tnagWj4%3D&reserved=0> _______________________________________________ sig-policy -https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email tosig-policy-leave@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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Thanks for the clarification. The makes it very clear that what we are doing is just willing to make something that *already exist* clear in the policy text, for the avoidance of doubt of all members and fair usage of allocated resources by APNIC to those who really justify the need.
Fernando
On 23/08/2022 07:35, Srinivas (Sunny) Chendi wrote:
Hi Jordi,
Please see our comments inline...
On 23/08/2022 9:40 am, JORDI PALET MARTINEZ wrote:
Hi Mike,
In at least, LACNIC and AFRINIC, it has been made clear by staff, that leasing is not a valid justification for getting resources, **THE SAME as in APNIC**, so if you use that as a justification, the request is denied. If you change the “usage” after the request is passed, then you’re bypassing the original justification, which is also **disallowed**.
I will let the secretariat to confirm if leasing is allowed or not, actually responding to your points on APNIC policies, even if this policy doesn't reach consensus. However, in my opinion the policy manual must be clear enough so nobody can interpret that something is not allowed when actually is not.
The same topic was discussed on the apnic-transfers mailing list sometime in June this year. https://mailman.apnic.net/hyperkitty/list/apnic-transfers@apnic.net/thread/P...
I'm copying and pasting my colleague Vivek's response here.
<quote> APNIC delegates IP addresses to Members based on their demonstrated need. What Members can do with that address space once it is no longer needed is impacted by policy requirements. I will provide two examples.
Example 1: Addresses delegated from the last /8 pool cannot be transferred for a minimum of five years. During that time, if the reason for the original request is no longer valid, the resources must be returned to APNIC. https://www.apnic.net/community/policy/resources#8.0.-IPv4-Transfers https://www.apnic.net/community/policy/resources#4.0.-Resource-License
So in this instance, if a Member leases out their IP addresses within five years of receiving the delegation from APNIC, they are clearly not needed for their original declared purpose and must be returned to APNIC.
Example 2: For addresses delegated to a Member more than five years ago, if a Member no longer has the need for the address space, APNIC policy says the Member can choose to transfer it to another organization or return it to APNIC. APNIC policy does not have provisions for leasing. So in the second example, APNIC Members leasing addresses would be doing so outside the policy framework and will not receive APNIC services such as whois registration and RPKI/ROA access related to those addresses. This in turn may make it difficult to freely utilise those addresses on the Internet, due to lack of clear authorisation and a reliance on the registered holder (lessor) to assist. Of course, if the addresses being leased were not delegated by APNIC, then the relevant RIR’s policies apply to those addresses.
<unquote>
Regards, Sunny APNIC Secretariat
Regards,
Jordi
@jordipalet
El 22/8/22, 12:17, "Mike Burns" mike@iptrading.com escribió:
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 sunny@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 2^nd 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 3^rd 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" sunny@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 (amritachoudhury@ccaoi.in) Fernando Frediani (fhfredani@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%2Fwww.arin.net%2Fparticipate%2Fpolicy%2Fproposals%2F2022%2FARIN_prop_308_v2%2F&data=05%7C01%7C%7Cff1f47d7d3cb4332f83508da8497de87%7C127d8d0d7ccf473dab096e44ad752ded%7C0%7C0%7C637968085076202445%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=Zd1wq3xTtwE47M8PH0mX3rRpHGytfkJaTeZ%2Bn5ABU7I%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 <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%7Cff1f47d7d3cb4332f83508da8497de87%7C127d8d0d7ccf473dab096e44ad752ded%7C0%7C0%7C637968085076359108%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=fbCVYmRHKMrlxD2uckeuVTuL5OtPFr260AW8tnagWj4%3D&reserved=0> _______________________________________________ sig-policy -https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email tosig-policy-leave@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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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 _______________________________________________________________________
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There is nothing in that statement that precludes apnic members from leasing out their space. Nor is there anything in policy that prevents it. I participated in that discussion on the transfer list and I suggest everybody review it carefully. In this case apnic staff continues to muddy the waters by conflating justification fraud with the act of leasing already acquired addresses. I note we do not have any word on Jordi's prior assertion that a fundamental change in usage renders the address block revocable.Will apnic staff forbid the creation of an ROA by a member which includes the AS number they do not own?Under which policy will Apnic staff forbid the creation of such ROAs, as the secretariat threatened? An APNIC member has every right under contract and policy to change the use of his addresses and also to lease them out. Please please do not conflate the final /8 policies and justification fraud with actual leasing. Fraud in justification has always been punishable in every registry. It's not the issue here.Regards,Mike ---- On Tue, 23 Aug 2022 07:51:50 -0400 fhfrediani@gmail.com wrote ----
Thanks for the clarification. The makes it very clear that what we are doing is just willing to make something that *already exist* clear in the policy text, for the avoidance of doubt of all members and fair usage of allocated resources by APNIC to those who really justify the need. Fernando
On 23/08/2022 07:35, Srinivas (Sunny) Chendi wrote:
Hi Jordi,
Please see our comments inline...
On 23/08/2022 9:40 am, JORDI PALET MARTINEZ wrote:
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Hi Mike, In at least, LACNIC and AFRINIC, it has been made clear by staff, that leasing is not a valid justification for getting resources, *THE SAME as in APNIC*, so if you use that as a justification, the request is denied. If you change the “usage” after the request is passed, then you’re bypassing the original justification, which is also *disallowed*. I will let the secretariat to confirm if leasing is allowed or not, actually responding to your points on APNIC policies, even if this policy doesn't reach consensus. However, in my opinion the policy manual must be clear enough so nobody can interpret that something is not allowed when actually is not.
The same topic was discussed on the apnic-transfers mailing list sometime in June this year. https://mailman.apnic.net/hyperkitty/list/apnic-transfers@apnic.net/thread/P...
I'm copying and pasting my colleague Vivek's response here.
<quote> APNIC delegates IP addresses to Members based on their demonstrated need. What Members can do with that address space once it is no longer needed is impacted by policy requirements. I will provide two examples.
Example 1: Addresses delegated from the last /8 pool cannot be transferred for a minimum of five years. During that time, if the reason for the original request is no longer valid, the resources must be returned to APNIC. https://www.apnic.net/community/policy/resources#8.0.-IPv4-Transfers
https://www.apnic.net/community/policy/resources#4.0.-Resource-License
So in this instance, if a Member leases out their IP addresses within five years of receiving the delegation from APNIC, they are clearly not needed for their original declared purpose and must be returned to APNIC.
Example 2: For addresses delegated to a Member more than five years ago, if a Member no longer has the need for the address space, APNIC policy says the Member can choose to transfer it to another organization or return it to APNIC. APNIC policy does not have provisions for leasing. So in the second example, APNIC Members leasing addresses would be doing so outside the policy framework and will not receive APNIC services such as whois registration and RPKI/ROA access related to those addresses. This in turn may make it difficult to freely utilise those addresses on the Internet, due to lack of clear authorisation and a reliance on the registered holder (lessor) to assist. Of course, if the addresses being leased were not delegated by APNIC, then the relevant RIR’s policies apply to those addresses. <unquote>
Regards, Sunny APNIC Secretariat
Regards,
Jordi @jordipalet
El 22/8/22, 12:17, "Mike Burns" mike@iptrading.com escribió:
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 sunny@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" sunny@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 (amritachoudhury@ccaoi.in) Fernando Frediani (fhfredani@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.n... https://aus01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fpoliticas.... _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@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. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.net
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This electronic message contains information which may be privileged or confidential. The information is intended to be for the exclusive use of the individual(s) named above and further non-explicilty authorized disclosure, copying, distribution or use of the contents of this information, even if partially, including attached files, is strictly prohibited and will be considered a criminal offense. If you are not the intended recipient be aware that any disclosure, copying, distribution or use of the contents of this information, even if partially, including attached files, is strictly prohibited, will be considered a criminal offense, so you must reply to the original sender to inform about this communication and delete it.
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This electronic message contains information which may be privileged or confidential. The information is intended to be for the exclusive use of the individual(s) named above and further non-explicilty authorized disclosure, copying, distribution or use of the contents of this information, even if partially, including attached files, is strictly prohibited and will be considered a criminal offense. If you are not the intended recipient be aware that any disclosure, copying, distribution or use of the contents of this information, even if partially, including attached files, is strictly prohibited, will be considered a criminal offense, so you must reply to the original sender to inform about this communication and delete it.
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_______________________________________________________________________
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. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message.
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Hi All,
Thank you for your valued inputs and interpretations.
APNIC staff has confirmed that leasing is not allowed and by proposing this policy change we want to explicitly state the same.
As you can see that without this explicit statement community members are free to interpret or misinterpret as it suits them.
I would request all community members to look at this proposed policy change from the lens of bringing in a more accountable and transparent IP resource allocation process which can be easily understood by all.
Regards,
Amrita
From: Fernando Frediani fhfrediani@gmail.com Sent: 23 August 2022 17:22 To: sig-policy@lists.apnic.net Subject: [sig-policy] Re: prop-148-v001: Leasing of Resources is not Acceptable
Thanks for the clarification. The makes it very clear that what we are doing is just willing to make something that *already exist* clear in the policy text, for the avoidance of doubt of all members and fair usage of allocated resources by APNIC to those who really justify the need.
Fernando
On 23/08/2022 07:35, Srinivas (Sunny) Chendi wrote:
Hi Jordi,
Please see our comments inline...
On 23/08/2022 9:40 am, JORDI PALET MARTINEZ wrote:
Hi Mike,
In at least, LACNIC and AFRINIC, it has been made clear by staff, that leasing is not a valid justification for getting resources, *THE SAME as in APNIC*, so if you use that as a justification, the request is denied. If you change the “usage” after the request is passed, then you’re bypassing the original justification, which is also *disallowed*.
I will let the secretariat to confirm if leasing is allowed or not, actually responding to your points on APNIC policies, even if this policy doesn't reach consensus. However, in my opinion the policy manual must be clear enough so nobody can interpret that something is not allowed when actually is not.
The same topic was discussed on the apnic-transfers mailing list sometime in June this year. https://mailman.apnic.net/hyperkitty/list/apnic-transfers@apnic.net/thread/P...
I'm copying and pasting my colleague Vivek's response here.
<quote> APNIC delegates IP addresses to Members based on their demonstrated need. What Members can do with that address space once it is no longer needed is impacted by policy requirements. I will provide two examples.
Example 1: Addresses delegated from the last /8 pool cannot be transferred for a minimum of five years. During that time, if the reason for the original request is no longer valid, the resources must be returned to APNIC. https://www.apnic.net/community/policy/resources#8.0.-IPv4-Transfers https://www.apnic.net/community/policy/resources#4.0.-Resource-License
So in this instance, if a Member leases out their IP addresses within five years of receiving the delegation from APNIC, they are clearly not needed for their original declared purpose and must be returned to APNIC.
Example 2: For addresses delegated to a Member more than five years ago, if a Member no longer has the need for the address space, APNIC policy says the Member can choose to transfer it to another organization or return it to APNIC. APNIC policy does not have provisions for leasing. So in the second example, APNIC Members leasing addresses would be doing so outside the policy framework and will not receive APNIC services such as whois registration and RPKI/ROA access related to those addresses. This in turn may make it difficult to freely utilise those addresses on the Internet, due to lack of clear authorisation and a reliance on the registered holder (lessor) to assist. Of course, if the addresses being leased were not delegated by APNIC, then the relevant RIR’s policies apply to those addresses. <unquote>
Regards, Sunny APNIC Secretariat
Regards,
Jordi
@jordipalet
El 22/8/22, 12:17, "Mike Burns" <mike@iptrading.com mailto:mike@iptrading.com > escribió:
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 mailto:sig-policy@lists.apnic.net sig-policy@lists.apnic.net Sent: Monday, August 22, 2022 9:21 AM To: Srinivas (Sunny) Chendi mailto:sunny@apnic.net sunny@apnic.net; sig-policy@lists.apnic.net mailto: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" <sunny@apnic.net mailto:sunny@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 mailto:jordi.palet@theipv6company.comAnupam ) Amrita Choudhury (amritachoudhury@ccaoi.in mailto:amritachoudhury@ccaoi.in ) Fernando Frediani (fhfredani@gmail.com mailto:fhfredani@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.n... 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%7Cff1f47d7d3cb4332f83508da8497de87%7C127d8d0d7ccf473dab096e44ad752ded%7C0%7C0%7C637968085076202445%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=Zd1wq3xTtwE47M8PH0mX3rRpHGytfkJaTeZ%2Bn5ABU7I%3D&reserved=0 &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.... 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%7Cff1f47d7d3cb4332f83508da8497de87%7C127d8d0d7ccf473dab096e44ad752ded%7C0%7C0%7C637968085076359108%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=fbCVYmRHKMrlxD2uckeuVTuL5OtPFr260AW8tnagWj4%3D&reserved=0 &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-leave@lists.apnic.net mailto:sig-policy-leave@lists.apnic.net
I support this policy that the current practice of disallowing leasing be memorialised into a procedure. There seems to be tremendous uncertainty in APNIC around this (at least from the conversations I have been privy to).
Therefore, if it is indeed against APNIC policy to lease number of resources to other parties, I firmly believe this should be concretely enumerated and defined within the Organisation's policy.
Regards,
Michael
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On Wed, Aug 24, 2022 at 3:37 PM Amrita amritachoudhury8@gmail.com wrote:
Hi All,
Thank you for your valued inputs and interpretations.
APNIC staff has confirmed that leasing is not allowed and by proposing this policy change we want to explicitly state the same.
As you can see that without this explicit statement community members are free to interpret or misinterpret as it suits them.
I would request all community members to look at this proposed policy change from the lens of bringing in a more accountable and transparent IP resource allocation process which can be easily understood by all.
Regards,
Amrita
*From:* Fernando Frediani fhfrediani@gmail.com *Sent:* 23 August 2022 17:22 *To:* sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: prop-148-v001: Leasing of Resources is not Acceptable
Thanks for the clarification. The makes it very clear that what we are doing is just willing to make something that *already exist* clear in the policy text, for the avoidance of doubt of all members and fair usage of allocated resources by APNIC to those who really justify the need.
Fernando
On 23/08/2022 07:35, Srinivas (Sunny) Chendi wrote:
Hi Jordi,
Please see our comments inline...
On 23/08/2022 9:40 am, JORDI PALET MARTINEZ wrote:
Hi Mike,
In at least, LACNIC and AFRINIC, it has been made clear by staff, that leasing is not a valid justification for getting resources, **THE SAME as in APNIC**, so if you use that as a justification, the request is denied. If you change the “usage” after the request is passed, then you’re bypassing the original justification, which is also **disallowed**.
I will let the secretariat to confirm if leasing is allowed or not, actually responding to your points on APNIC policies, even if this policy doesn't reach consensus. However, in my opinion the policy manual must be clear enough so nobody can interpret that something is not allowed when actually is not.
The same topic was discussed on the apnic-transfers mailing list sometime in June this year.
https://mailman.apnic.net/hyperkitty/list/apnic-transfers@apnic.net/thread/P...
I'm copying and pasting my colleague Vivek's response here.
<quote> APNIC delegates IP addresses to Members based on their demonstrated need. What Members can do with that address space once it is no longer needed is impacted by policy requirements. I will provide two examples.
Example 1: Addresses delegated from the last /8 pool cannot be transferred for a minimum of five years. During that time, if the reason for the original request is no longer valid, the resources must be returned to APNIC. https://www.apnic.net/community/policy/resources#8.0.-IPv4-Transfers https://www.apnic.net/community/policy/resources#4.0.-Resource-License
So in this instance, if a Member leases out their IP addresses within five years of receiving the delegation from APNIC, they are clearly not needed for their original declared purpose and must be returned to APNIC.
Example 2: For addresses delegated to a Member more than five years ago, if a Member no longer has the need for the address space, APNIC policy says the Member can choose to transfer it to another organization or return it to APNIC. APNIC policy does not have provisions for leasing. So in the second example, APNIC Members leasing addresses would be doing so outside the policy framework and will not receive APNIC services such as whois registration and RPKI/ROA access related to those addresses. This in turn may make it difficult to freely utilise those addresses on the Internet, due to lack of clear authorisation and a reliance on the registered holder (lessor) to assist. Of course, if the addresses being leased were not delegated by APNIC, then the relevant RIR’s policies apply to those addresses.
<unquote>
Regards, Sunny APNIC Secretariat
Regards,
Jordi
@jordipalet
El 22/8/22, 12:17, "Mike Burns" mike@iptrading.com escribió:
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 sig-policy@lists.apnic.net *Sent:* Monday, August 22, 2022 9:21 AM *To:* Srinivas (Sunny) Chendi sunny@apnic.net sunny@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" sunny@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-148APNIC 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/8We 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-148Regards,
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 (amritachoudhury@ccaoi.in) Fernando Frediani (fhfredani@gmail.com)
- 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.
- 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.
- 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.
- 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.
- Advantages / Disadvantages
Advantages:
Fulfilling the objective above indicated and making the policy clear.
Disadvantages:
None.
- Impact on resource holders
None.
- References
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--
Srinivas (Sunny) Chendi (he/him)
Senior Advisor - Policy and Community Development
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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)
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Thank you Micheal for the support.
Regards,
Amrita
From: Michael B. Williams Michael.Williams@glexia.com Sent: 24 August 2022 11:15 To: Amrita amritachoudhury8@gmail.com Cc: Fernando Frediani fhfrediani@gmail.com; sig-policy@lists.apnic.net Subject: Re: [sig-policy] Re: prop-148-v001: Leasing of Resources is not Acceptable
I support this policy that the current practice of disallowing leasing be memorialised into a procedure. There seems to be tremendous uncertainty in APNIC around this (at least from the conversations I have been privy to).
Therefore, if it is indeed against APNIC policy to lease number of resources to other parties, I firmly believe this should be concretely enumerated and defined within the Organisation's policy.
Regards,
Michael
_____
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On Wed, Aug 24, 2022 at 3:37 PM Amrita <amritachoudhury8@gmail.com mailto:amritachoudhury8@gmail.com > wrote:
Hi All,
Thank you for your valued inputs and interpretations.
APNIC staff has confirmed that leasing is not allowed and by proposing this policy change we want to explicitly state the same.
As you can see that without this explicit statement community members are free to interpret or misinterpret as it suits them.
I would request all community members to look at this proposed policy change from the lens of bringing in a more accountable and transparent IP resource allocation process which can be easily understood by all.
Regards,
Amrita
From: Fernando Frediani <fhfrediani@gmail.com mailto:fhfrediani@gmail.com > Sent: 23 August 2022 17:22 To: sig-policy@lists.apnic.net mailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: prop-148-v001: Leasing of Resources is not Acceptable
Thanks for the clarification. The makes it very clear that what we are doing is just willing to make something that *already exist* clear in the policy text, for the avoidance of doubt of all members and fair usage of allocated resources by APNIC to those who really justify the need.
Fernando
On 23/08/2022 07:35, Srinivas (Sunny) Chendi wrote:
Hi Jordi,
Please see our comments inline...
On 23/08/2022 9:40 am, JORDI PALET MARTINEZ wrote:
Hi Mike,
In at least, LACNIC and AFRINIC, it has been made clear by staff, that leasing is not a valid justification for getting resources, *THE SAME as in APNIC*, so if you use that as a justification, the request is denied. If you change the “usage” after the request is passed, then you’re bypassing the original justification, which is also *disallowed*.
I will let the secretariat to confirm if leasing is allowed or not, actually responding to your points on APNIC policies, even if this policy doesn't reach consensus. However, in my opinion the policy manual must be clear enough so nobody can interpret that something is not allowed when actually is not.
The same topic was discussed on the apnic-transfers mailing list sometime in June this year. https://mailman.apnic.net/hyperkitty/list/apnic-transfers@apnic.net/thread/P...
I'm copying and pasting my colleague Vivek's response here.
<quote> APNIC delegates IP addresses to Members based on their demonstrated need. What Members can do with that address space once it is no longer needed is impacted by policy requirements. I will provide two examples.
Example 1: Addresses delegated from the last /8 pool cannot be transferred for a minimum of five years. During that time, if the reason for the original request is no longer valid, the resources must be returned to APNIC. https://www.apnic.net/community/policy/resources#8.0.-IPv4-Transfers https://www.apnic.net/community/policy/resources#4.0.-Resource-License
So in this instance, if a Member leases out their IP addresses within five years of receiving the delegation from APNIC, they are clearly not needed for their original declared purpose and must be returned to APNIC.
Example 2: For addresses delegated to a Member more than five years ago, if a Member no longer has the need for the address space, APNIC policy says the Member can choose to transfer it to another organization or return it to APNIC. APNIC policy does not have provisions for leasing. So in the second example, APNIC Members leasing addresses would be doing so outside the policy framework and will not receive APNIC services such as whois registration and RPKI/ROA access related to those addresses. This in turn may make it difficult to freely utilise those addresses on the Internet, due to lack of clear authorisation and a reliance on the registered holder (lessor) to assist. Of course, if the addresses being leased were not delegated by APNIC, then the relevant RIR’s policies apply to those addresses. <unquote>
Regards, Sunny APNIC Secretariat
Regards,
Jordi
@jordipalet
El 22/8/22, 12:17, "Mike Burns" <mike@iptrading.com mailto:mike@iptrading.com > escribió:
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 mailto:sig-policy@lists.apnic.net sig-policy@lists.apnic.net Sent: Monday, August 22, 2022 9:21 AM To: Srinivas (Sunny) Chendi mailto:sunny@apnic.net sunny@apnic.net; sig-policy@lists.apnic.net mailto: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" <sunny@apnic.net mailto:sunny@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 mailto:jordi.palet@theipv6company.comAnupam ) Amrita Choudhury (amritachoudhury@ccaoi.in mailto:amritachoudhury@ccaoi.in ) Fernando Frediani (fhfredani@gmail.com mailto:fhfredani@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.n... 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%7Cff1f47d7d3cb4332f83508da8497de87%7C127d8d0d7ccf473dab096e44ad752ded%7C0%7C0%7C637968085076202445%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=Zd1wq3xTtwE47M8PH0mX3rRpHGytfkJaTeZ%2Bn5ABU7I%3D&reserved=0 &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.... 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%7Cff1f47d7d3cb4332f83508da8497de87%7C127d8d0d7ccf473dab096e44ad752ded%7C0%7C0%7C637968085076359108%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=fbCVYmRHKMrlxD2uckeuVTuL5OtPFr260AW8tnagWj4%3D&reserved=0 &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-leave@lists.apnic.net mailto:sig-policy-leave@lists.apnic.net
As with all of these questions, I'm keen to understand what policy this is trying to solve, and whether the actual landscape has changed since this discussion was had several years ago. A quick search of the SIG mailing list shows that this has been discussed several times since 2013.
But fundamentally, it strikes me that the policy is worded poorly, and seeks to solve "too many problems" in one go.
The policy appears to be trying to address the following situations:
Scenario 1: An organisation obtains, or has, IPv4 or IPv6 resources surplus to their needs "right now", and given the shortage of IPv4 or IPv6 resources enters a commercial arrangement with another organisation in need of these resources, in exchange for a fee. This is not a transfer, but a temporary "lease". The general discussion on this list is that such actions are considered outside the intent of APNIC allocations.
Some notes: - APNIC already states that this does not meet the justifiable need for resource allocation in existing policies. - APNIC already requires a direct connectivity relationship to sub-allocate resources - APNIC already states sub-allocation is only possible to "one level" - APNIC already states that sub-allocation must be returned to the LIR once the direct connectivity relationship is terminated
In the case of this scenario, it seems that the existing rules already set out the guidelines and the processes for what resource holders can do with their APNIC resources.
Scenario 2: An organisation has grown rapidly and requires additional IPv4 resources to keep up with customer demand. As they are a "new" entrant to the market and have received an allocation from the final /8, they are limited in the new resource space they can apply for. In addition, they already make use of CGNAT and other technologies and have deployed IPv6 throughout their network; but simply need additional IPv4 space. They approach the IPv4 market to purchase additional space under a transfer agreement, but are unable to finance the quite high transfer price for IPv4 address space. They would prefer to lease the space to assist with financial management.
In the case of this scenario, the discussion seems to point that the community would not like this avenue to be available for this type of organisation.
Scenario 3: An organisation already is making use of leased IPv4 space. They are serving active customers using this. This space is leased from an APNIC block from another provider.
Under this policy, this organisation would have their IPv4 space removed from them, and be required to source IPv4 space for their customers through other means, and whatever cost the market determines is required. It is worth noting that this is an "open market" and there is no regulation on transfer price or resource value.
---
In each of these cases, I'm interested in:
a) the extent to which this is a practice in the APNIC region b) the extent to which this policy will solve a problem that actually exists c) whether this policy change would materially impact any organisations, and if so how many d) whether there is any information as to the extent that organisations are utilising IPv4 space that has been assigned to an entity to which there is no appropriate relationship
With the current text of the policy, I cannot support it; and I remain agnostic as to the need for such a policy.
Andrew
On Wed, 24 Aug 2022 at 15:37, Amrita amritachoudhury8@gmail.com wrote:
Hi All,
Thank you for your valued inputs and interpretations.
APNIC staff has confirmed that leasing is not allowed and by proposing
this policy change we want to explicitly state the same.
As you can see that without this explicit statement community members are
free to interpret or misinterpret as it suits them.
I would request all community members to look at this proposed policy
change from the lens of bringing in a more accountable and transparent IP resource allocation process which can be easily understood by all.
Regards,
Amrita
From: Fernando Frediani fhfrediani@gmail.com Sent: 23 August 2022 17:22 To: sig-policy@lists.apnic.net Subject: [sig-policy] Re: prop-148-v001: Leasing of Resources is not
Acceptable
Thanks for the clarification. The makes it very clear that what we are doing is just willing to make
something that *already exist* clear in the policy text, for the avoidance of doubt of all members and fair usage of allocated resources by APNIC to those who really justify the need.
Fernando
On 23/08/2022 07:35, Srinivas (Sunny) Chendi wrote:
Hi Jordi,
Please see our comments inline...
On 23/08/2022 9:40 am, JORDI PALET MARTINEZ wrote:
Hi Mike,
In at least, LACNIC and AFRINIC, it has been made clear by staff, that
leasing is not a valid justification for getting resources, *THE SAME as in APNIC*, so if you use that as a justification, the request is denied. If you change the “usage” after the request is passed, then you’re bypassing the original justification, which is also *disallowed*.
I will let the secretariat to confirm if leasing is allowed or not,
actually responding to your points on APNIC policies, even if this policy doesn't reach consensus. However, in my opinion the policy manual must be clear enough so nobody can interpret that something is not allowed when actually is not.
The same topic was discussed on the apnic-transfers mailing list sometime
in June this year.
https://mailman.apnic.net/hyperkitty/list/apnic-transfers@apnic.net/thread/P...
I'm copying and pasting my colleague Vivek's response here.
<quote> APNIC delegates IP addresses to Members based on their demonstrated need.
What Members can do with that address space once it is no longer needed is impacted by policy requirements. I will provide two examples.
Example 1: Addresses delegated from the last /8 pool cannot be
transferred for a minimum of five years. During that time, if the reason for the original request is no longer valid, the resources must be returned to APNIC.
https://www.apnic.net/community/policy/resources#8.0.-IPv4-Transfers https://www.apnic.net/community/policy/resources#4.0.-Resource-License
So in this instance, if a Member leases out their IP addresses within
five years of receiving the delegation from APNIC, they are clearly not needed for their original declared purpose and must be returned to APNIC.
Example 2: For addresses delegated to a Member more than five years ago,
if a Member no longer has the need for the address space, APNIC policy says the Member can choose to transfer it to another organization or return it to APNIC. APNIC policy does not have provisions for leasing. So in the second example, APNIC Members leasing addresses would be doing so outside the policy framework and will not receive APNIC services such as whois registration and RPKI/ROA access related to those addresses. This in turn may make it difficult to freely utilise those addresses on the Internet, due to lack of clear authorisation and a reliance on the registered holder (lessor) to assist. Of course, if the addresses being leased were not delegated by APNIC, then the relevant RIR’s policies apply to those addresses.
<unquote>
Regards, Sunny APNIC Secretariat
Regards,
Jordi
@jordipalet
El 22/8/22, 12:17, "Mike Burns" mike@iptrading.com escribió:
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 sunny@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" sunny@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-148APNIC 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/8We 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-148Regards,
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 (amritachoudhury@ccaoi.in) Fernando Frediani (fhfredani@gmail.com)
- 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.
- 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.
- 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.
- 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.
- Advantages / Disadvantages
Advantages:
Fulfilling the objective above indicated and making the policy clear.
Disadvantages:
None.
- Impact on resource holders
None.
- References
https://aus01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.arin.n...
https://aus01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fpoliticas....
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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. Any unauthorized
review, use, disclosure or distribution is prohibited. If you are not the
intended recipient, please contact the sender by reply email and destroy
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Hello Andrew
Thanks for your comments. Correct me if I am wrong but despite that fact you recognize leasing is not an allowed practice currently, but you believe it should be under some of all of those scenarios ?
This proposal is NOT trying to solve any of the scenarios you put below. The only propose of this proposal is, for the avoidance of doubt or all members, to make clear in the policy text something that already exists. It solves a problem of people reading the policies, misinterpreting them and end up using resources against what they are allowed for.
Regardless of the scenario and justification, if there is leasing being made from one organization to another that has the ability to receive them directly from APNIC (via a transfer for example), means there are unneeded resources with the member who originally justified them to use either for their own or to bring direct connectivity to their customers and is using for another proposal - to lease them.
Therefore given that this proposal aims only to make an existing fact clear into the policy text, if you are against it could you please point us what part of the text is not good so that can be adjusted as necessary ?
Thanks Regards Fernando
On 24/08/2022 02:59, Andrew Yager wrote:
As with all of these questions, I'm keen to understand what policy this is trying to solve, and whether the actual landscape has changed since this discussion was had several years ago. A quick search of the SIG mailing list shows that this has been discussed several times since 2013.
But fundamentally, it strikes me that the policy is worded poorly, and seeks to solve "too many problems" in one go.
The policy appears to be trying to address the following situations:
Scenario 1: An organisation obtains, or has, IPv4 or IPv6 resources surplus to their needs "right now", and given the shortage of IPv4 or IPv6 resources enters a commercial arrangement with another organisation in need of these resources, in exchange for a fee. This is not a transfer, but a temporary "lease". The general discussion on this list is that such actions are considered outside the intent of APNIC allocations.
Some notes:
- APNIC already states that this does not meet the justifiable need
for resource allocation in existing policies.
- APNIC already requires a direct connectivity relationship to
sub-allocate resources
- APNIC already states sub-allocation is only possible to "one level"
- APNIC already states that sub-allocation must be returned to the LIR
once the direct connectivity relationship is terminated
In the case of this scenario, it seems that the existing rules already set out the guidelines and the processes for what resource holders can do with their APNIC resources.
Scenario 2: An organisation has grown rapidly and requires additional IPv4 resources to keep up with customer demand. As they are a "new" entrant to the market and have received an allocation from the final /8, they are limited in the new resource space they can apply for. In addition, they already make use of CGNAT and other technologies and have deployed IPv6 throughout their network; but simply need additional IPv4 space. They approach the IPv4 market to purchase additional space under a transfer agreement, but are unable to finance the quite high transfer price for IPv4 address space. They would prefer to lease the space to assist with financial management.
In the case of this scenario, the discussion seems to point that the community would not like this avenue to be available for this type of organisation.
Scenario 3: An organisation already is making use of leased IPv4 space. They are serving active customers using this. This space is leased from an APNIC block from another provider.
Under this policy, this organisation would have their IPv4 space removed from them, and be required to source IPv4 space for their customers through other means, and whatever cost the market determines is required. It is worth noting that this is an "open market" and there is no regulation on transfer price or resource value.
In each of these cases, I'm interested in:
a) the extent to which this is a practice in the APNIC region b) the extent to which this policy will solve a problem that actually exists c) whether this policy change would materially impact any organisations, and if so how many d) whether there is any information as to the extent that organisations are utilising IPv4 space that has been assigned to an entity to which there is no appropriate relationship
With the current text of the policy, I cannot support it; and I remain agnostic as to the need for such a policy.
Andrew
On Wed, 24 Aug 2022 at 15:37, Amrita amritachoudhury8@gmail.com wrote:
Hi All,
Thank you for your valued inputs and interpretations.
APNIC staff has confirmed that leasing is not allowed and by
proposing this policy change we want to explicitly state the same.
As you can see that without this explicit statement community
members are free to interpret or misinterpret as it suits them.
I would request all community members to look at this proposed
policy change from the lens of bringing in a more accountable and transparent IP resource allocation process which can be easily understood by all.
Regards,
Amrita
From: Fernando Frediani fhfrediani@gmail.com Sent: 23 August 2022 17:22 To: sig-policy@lists.apnic.net Subject: [sig-policy] Re: prop-148-v001: Leasing of Resources is not
Acceptable
Thanks for the clarification. The makes it very clear that what we are doing is just willing to
make something that *already exist* clear in the policy text, for the avoidance of doubt of all members and fair usage of allocated resources by APNIC to those who really justify the need.
Fernando
On 23/08/2022 07:35, Srinivas (Sunny) Chendi wrote:
Hi Jordi,
Please see our comments inline...
On 23/08/2022 9:40 am, JORDI PALET MARTINEZ wrote:
Hi Mike,
In at least, LACNIC and AFRINIC, it has been made clear by staff,
that leasing is not a valid justification for getting resources, *THE SAME as in APNIC*, so if you use that as a justification, the request is denied. If you change the “usage” after the request is passed, then you’re bypassing the original justification, which is also *disallowed*.
I will let the secretariat to confirm if leasing is allowed or not,
actually responding to your points on APNIC policies, even if this policy doesn't reach consensus. However, in my opinion the policy manual must be clear enough so nobody can interpret that something is not allowed when actually is not.
The same topic was discussed on the apnic-transfers mailing list
sometime in June this year.
https://mailman.apnic.net/hyperkitty/list/apnic-transfers@apnic.net/thread/P...
I'm copying and pasting my colleague Vivek's response here.
<quote> APNIC delegates IP addresses to Members based on their demonstrated
need. What Members can do with that address space once it is no longer needed is impacted by policy requirements. I will provide two examples.
Example 1: Addresses delegated from the last /8 pool cannot be
transferred for a minimum of five years. During that time, if the reason for the original request is no longer valid, the resources must be returned to APNIC.
https://www.apnic.net/community/policy/resources#8.0.-IPv4-Transfers https://www.apnic.net/community/policy/resources#4.0.-Resource-License
So in this instance, if a Member leases out their IP addresses
within five years of receiving the delegation from APNIC, they are clearly not needed for their original declared purpose and must be returned to APNIC.
Example 2: For addresses delegated to a Member more than five years
ago, if a Member no longer has the need for the address space, APNIC policy says the Member can choose to transfer it to another organization or return it to APNIC. APNIC policy does not have provisions for leasing. So in the second example, APNIC Members leasing addresses would be doing so outside the policy framework and will not receive APNIC services such as whois registration and RPKI/ROA access related to those addresses. This in turn may make it difficult to freely utilise those addresses on the Internet, due to lack of clear authorisation and a reliance on the registered holder (lessor) to assist. Of course, if the addresses being leased were not delegated by APNIC, then the relevant RIR’s policies apply to those addresses.
<unquote>
Regards, Sunny APNIC Secretariat
Regards,
Jordi
@jordipalet
El 22/8/22, 12:17, "Mike Burns" mike@iptrading.com escribió:
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 sunny@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" sunny@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 (amritachoudhury@ccaoi.in)
Fernando Frediani (fhfredani@gmail.com)
- 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.
- 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.
- 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.
- 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.
- Advantages / Disadvantages
Advantages:
Fulfilling the objective above indicated and making the policy clear.
Disadvantages:
None.
- Impact on resource holders
None.
- References
https://aus01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.arin.n... 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.... 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
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Srinivas (Sunny) Chendi (he/him)
Senior Advisor - Policy and Community Development
Asia Pacific Network Information Centre (APNIC) | Tel: +61 7 3858 3100
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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 mike@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 sunny@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" sunny@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-148APNIC 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/8We 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-148Regards,
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 (amritachoudhury@ccaoi.in) Fernando Frediani (fhfredani@gmail.com)
- 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.
- 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.
- 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.
- 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.
- Advantages / Disadvantages
Advantages:
Fulfilling the objective above indicated and making the policy clear.
Disadvantages:
None.
- Impact on resource holders
None.
- References
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--
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. Any unauthorized
review, use, disclosure or distribution is prohibited. If you are not the
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copies of the original message.
_______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.net
IPv4 is over Are you ready for the new Internet ? http://www.theipv6company.com The IPv6 Company
This electronic message contains information which may be privileged or confidential. The information is intended to be for the exclusive use of the individual(s) named above and further non-explicilty authorized disclosure, copying, distribution or use of the contents of this information, even if partially, including attached files, is strictly prohibited and will be considered a criminal offense. If you are not the intended recipient be aware that any disclosure, copying, distribution or use of the contents of this information, even if partially, including attached files, is strictly prohibited, will be considered a criminal offense, so you must reply to the original sender to inform about this communication and delete it. _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.net
Hi Jordi,
Please see our comments inline...
On 22/08/2022 11:20 pm, JORDI PALET MARTINEZ wrote:
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?
We are seeking clarification because the current text is not clear enough.
Regarding your 2^nd 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.
We do have generic contact information on the APNIC website here https://help.apnic.net/s/contactsupport
In the proposed policy solution of this proposal, it says "If any form of leasing is confirmed by an APNIC investigation...", but it does not state that these investigations should be conducted in accordance with the current procedure and refers to this in the policy document, nor does it state whether the Secretariat should proactively identify cases of leasing or only investigate cases that are reported or detected when processing resource requests. So, we are seeking clarification in order to have a clear understanding of this.
Finally, regarding your 3^rd 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.
As we all know, this is questionable. In the past, authors either provided clear clarification in their proposal or clarified later after the impact assessment was provided. For example, prop-125, your own proposal, provided a clear clarity with details that were required for everyone's understanding.
Regards, Sunny APNIC Secretariat
Tks!
Regards,
Jordi
@jordipalet
El 22/8/22, 2:45, "Srinivas (Sunny) Chendi" sunny@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 (amritachoudhury@ccaoi.in) Fernando Frediani (fhfredani@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%2Fwww.arin.net%2Fparticipate%2Fpolicy%2Fproposals%2F2022%2FARIN_prop_308_v2%2F&data=05%7C01%7C%7C1c99a14777af4f5b8a5408da8441acf9%7C127d8d0d7ccf473dab096e44ad752ded%7C0%7C0%7C637967715469668969%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C2000%7C%7C%7C&sdata=ZgDAihyLz9N%2BHhSjcur0h6ATszJwmDzlJ71JHenpdXE%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 <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%7C1c99a14777af4f5b8a5408da8441acf9%7C127d8d0d7ccf473dab096e44ad752ded%7C0%7C0%7C637967715469668969%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C2000%7C%7C%7C&sdata=SZBdHiFujZlrMfpcofXybLAdyT%2Bk47StWTV2t98Qfog%3D&reserved=0> _______________________________________________ sig-policy -https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email tosig-policy-leave@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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Hi Sunny,
Responses in line.
From: Srinivas (Sunny) Chendi sunny@apnic.net Sent: 23 August 2022 15:52 To: JORDI PALET MARTINEZ jordi.palet@consulintel.es; sig-policy@lists.apnic.net Subject: [sig-policy] Re: prop-148-v001: Leasing of Resources is not Acceptable
Hi Jordi,
Please see our comments inline...
On 22/08/2022 11:20 pm, JORDI PALET MARTINEZ wrote:
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?
We are seeking clarification because the current text is not clear enough.
Amrita – we could add as Jordi mentioned small text clarification in the proposal.
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.
We do have generic contact information on the APNIC website here https://help.apnic.net/s/contactsupport
In the proposed policy solution of this proposal, it says "If any form of leasing is confirmed by an APNIC investigation...", but it does not state that these investigations should be conducted in accordance with the current procedure and refers to this in the policy document, nor does it state whether the Secretariat should proactively identify cases of leasing or only investigate cases that are reported or detected when processing resource requests. So, we are seeking clarification in order to have a clear understanding of this.
Amrita : What we meant is that if any form of leasing is reported to APNIC, then APNIC should investigate as per the present process of investigation adopted by APNIC for any form of abuse/ concern reported. Do you want us to make it explicit in the proposal?
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.
As we all know, this is questionable. In the past, authors either provided clear clarification in their proposal or clarified later after the impact assessment was provided. For example, prop-125, your own proposal, provided a clear clarity with details that were required for everyone's understanding.
Amrita : We will make a change in the text stating that it will be applicable to all existing allocation. Hope that helps.
Regards, Sunny APNIC Secretariat
Tks!
Regards,
Jordi
@jordipalet
El 22/8/22, 2:45, "Srinivas (Sunny) Chendi" <sunny@apnic.net mailto:sunny@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 mailto:jordi.palet@theipv6company.comAnupam ) Amrita Choudhury (amritachoudhury@ccaoi.in mailto:amritachoudhury@ccaoi.in ) Fernando Frediani (fhfredani@gmail.com mailto:fhfredani@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.n... 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%7C1c99a14777af4f5b8a5408da8441acf9%7C127d8d0d7ccf473dab096e44ad752ded%7C0%7C0%7C637967715469668969%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C2000%7C%7C%7C&sdata=ZgDAihyLz9N%2BHhSjcur0h6ATszJwmDzlJ71JHenpdXE%3D&reserved=0 &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.... 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%7C1c99a14777af4f5b8a5408da8441acf9%7C127d8d0d7ccf473dab096e44ad752ded%7C0%7C0%7C637967715469668969%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C2000%7C%7C%7C&sdata=SZBdHiFujZlrMfpcofXybLAdyT%2Bk47StWTV2t98Qfog%3D&reserved=0 &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-leave@lists.apnic.net mailto:sig-policy-leave@lists.apnic.net
Hi Amrita,
Thank you for your queries.
The Secretariat's role in the policy development process is to assist the Open Policy Meetings and SIG Chairs, to facilitate and guide the policy process, to document and publish proposals/policies, and to provide impact assessment.
The secretariat has no say over what should or should not be included in the proposal. It is up to the authors and the community to work on drafting the proposals, whether or not the Secretariat's assessment analysis is considered.
Regards, Sunny
On 24/08/2022 12:50 am, Amrita wrote:
Hi Sunny,
Responses in line.
*From:*Srinivas (Sunny) Chendi sunny@apnic.net *Sent:* 23 August 2022 15:52 *To:* JORDI PALET MARTINEZ jordi.palet@consulintel.es; sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: prop-148-v001: Leasing of Resources is not Acceptable
Hi Jordi,
Please see our comments inline...
On 22/08/2022 11:20 pm, JORDI PALET MARTINEZ wrote:
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?We are seeking clarification because the current text is not clear enough.
Amrita – we could add as Jordi mentioned small text clarification in the proposal.
Regarding your 2^nd 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.We do have generic contact information on the APNIC website here https://help.apnic.net/s/contactsupport
In the proposed policy solution of this proposal, it says "If any form of leasing is confirmed by an APNIC investigation...", but it does not state that these investigations should be conducted in accordance with the current procedure and refers to this in the policy document, nor does it state whether the Secretariat should proactively identify cases of leasing or only investigate cases that are reported or detected when processing resource requests. So, we are seeking clarification in order to have a clear understanding of this.
Amrita : What we meant is that if any form of leasing is reported to APNIC, then APNIC should investigate as per the present process of investigation adopted by APNIC for any form of abuse/ concern reported. Do you want us to make it explicit in the proposal?
Finally, regarding your 3^rd 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.As we all know, this is questionable. In the past, authors either provided clear clarification in their proposal or clarified later after the impact assessment was provided. For example, prop-125, your own proposal, provided a clear clarity with details that were required for everyone's understanding.
Amrita : We will make a change in the text stating that it will be applicable to all existing allocation. Hope that helps.
Regards, Sunny APNIC Secretariat
Tks! Regards, Jordi @jordipalet El 22/8/22, 2:45, "Srinivas (Sunny) Chendi" <sunny@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 (amritachoudhury@ccaoi.in) Fernando Frediani (fhfredani@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%2Fwww.arin.net%2Fparticipate%2Fpolicy%2Fproposals%2F2022%2FARIN_prop_308_v2%2F&data=05%7C01%7C%7C83238010a2a0488a36f008da8516c954%7C127d8d0d7ccf473dab096e44ad752ded%7C0%7C0%7C637968630653041673%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C2000%7C%7C%7C&sdata=YEhUJuHFqp8yRQBSuAFMF73iW3eFjl%2Bj7ezDOSl%2FJrE%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 <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%7C83238010a2a0488a36f008da8516c954%7C127d8d0d7ccf473dab096e44ad752ded%7C0%7C0%7C637968630653041673%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C2000%7C%7C%7C&sdata=EbO2i91%2F1xmPZfjFjRADJoRLt8SdsUHUslSQIl17Tiw%3D&reserved=0> _______________________________________________ sig-policy -https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email tosig-policy-leave@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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