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Dear SIG members,
A new version of the proposal "prop-148-v002: Clarification - Leasing of Resources is not Acceptable" has been sent to the Policy SIG for review.
Information about earlier versions is available from:
http://www.apnic.net/policy/proposals/prop-148
You are encouraged to express your views on the proposal:
- Do you support or oppose the proposal? - Is there anything in the proposal that is not clear? - What changes could be made to this proposal to make it more effective?
Please find the text of the proposal below.
Regards, Bertrand, Shaila, and Ching-Heng APNIC Policy SIG Chairs
---------------------------------------------------------------------- *prop-148-v002: Clarification - 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 a 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 delegated by APNIC or an NIR, the justification of the need implies the need to use on their own infrastructure and/or network connectivity services provided directly to customers. As a result, any form of IP address leasing is unacceptable, 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.
APNIC may proactively investigate those cases and also initiate the investigation in case of reports by means of a form, email address or other means developed by APNIC.
If any form of leasing, regardless of when the delegation has been issued, is confirmed by an APNIC investigation, it will be considered a policy violation and revocation may apply against any account holders who are leasing or using them for any purposes not specified in the initial request.
5. Advantages / Disadvantages ----------------------------- Advantages: Fulfilling the objective above indicated and making the policy clear.
Disadvantages: None.
6. Impact on resource holders ----------------------------- None.
7. References ------------- https://www.arin.net/participate/policy/proposals/2022/ARIN_prop_308_v2/ https://politicas.lacnic.net/politicas/detail/id/LAC-2022-2/language/en
Dear Colleagues,
I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team..
I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals.
Many participants support the intent of the proposal but felt that implementation would be challenging.
(comment details) - It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses. - I think this proposal would be useful if the concept of leasing is accurately defined. - Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement.
Regards,
Satoru Tsurumaki / JPOPF Steering Team
2022年8月26日(金) 17:27 Shaila Sharmin shaila.sharmin.ovi@gmail.com:
Dear SIG members,
A new version of the proposal "prop-148-v002: Clarification - Leasing of Resources is not Acceptable" has been sent to the Policy SIG for review.
Information about earlier versions is available from:
http://www.apnic.net/policy/proposals/prop-148
You are encouraged to express your views on the proposal:
- Do you support or oppose the proposal?
- Is there anything in the proposal that is not clear?
- What changes could be made to this proposal to make it more effective?
Please find the text of the proposal below.
Regards, Bertrand, Shaila, and Ching-Heng APNIC Policy SIG Chairs
prop-148-v002: Clarification - 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 a 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 delegated by APNIC or an NIR, the justification of the need implies the need to use on their own infrastructure and/or network connectivity services provided directly to customers. As a result, any form of IP address leasing is unacceptable, 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.
APNIC may proactively investigate those cases and also initiate the investigation in case of reports by means of a form, email address or other means developed by APNIC.
If any form of leasing, regardless of when the delegation has been issued, is confirmed by an APNIC investigation, it will be considered a policy violation and revocation may apply against any account holders who are leasing or using them for any purposes not specified in the initial request.
- Advantages / Disadvantages
Advantages: Fulfilling the objective above indicated and making the policy clear.
Disadvantages: None.
- Impact on resource holders
None.
- 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 _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.net
Dear Team,
As Mr. Satoru, mentioned there are changes, but if carefully implemented in phased manner, unauthorised leasing can be stopped.
For example in first phase, leasing among countries can be stopped, if the owner company doesn't provide any services beyond its home country. For example if a company in India doesn't have any operation in Singapore or Japan , can't lease resources to those companies in Singapore or Japan. This can be verified by taking business registration documents of both lease and lessor. Once this is done same may be granularized at RIR level, where in country like India, leasing can be restricted to the licensed service area for service provider within their designated service area. This may stop majority of issues, barring few exceptions. Some more brainstorming is required for better understanding and precise implementation.
Regards,
Rajesh Panwala For Smartlink Solutions Pvt Ltd +91-9227886001 +91-9426110781
On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru stsuruma@bbix.net wrote:
Dear Colleagues,
I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team..
I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals.
Many participants support the intent of the proposal but felt that implementation would be challenging.
(comment details)
- It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses.
- I think this proposal would be useful if the concept of leasing is
accurately defined.
- Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement.
Regards,
Satoru Tsurumaki / JPOPF Steering Team
2022年8月26日(金) 17:27 Shaila Sharmin shaila.sharmin.ovi@gmail.com:
Dear SIG members,
A new version of the proposal "prop-148-v002: Clarification - Leasing of Resources is not Acceptable" has been sent to the Policy SIG for review.
Information about earlier versions is available from:
http://www.apnic.net/policy/proposals/prop-148
You are encouraged to express your views on the proposal:
- Do you support or oppose the proposal?
- Is there anything in the proposal that is not clear?
- What changes could be made to this proposal to make it more
effective?
Please find the text of the proposal below.
Regards, Bertrand, Shaila, and Ching-Heng APNIC Policy SIG Chairs
prop-148-v002: Clarification - 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 a 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 delegated by APNIC or an NIR, the justification of the need implies the need to use on their own infrastructure and/or network connectivity services provided directly to customers. As a result, any form of IP address leasing is unacceptable, 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.
APNIC may proactively investigate those cases and also initiate the investigation in case of reports by means of a form, email address or other means developed by APNIC.
If any form of leasing, regardless of when the delegation has been issued, is confirmed by an APNIC investigation, it will be considered a policy violation and revocation may apply against any account holders who are leasing or using them for any purposes not specified in the initial request.
- Advantages / Disadvantages
Advantages: Fulfilling the objective above indicated and making the policy clear.
Disadvantages: None.
- Impact on resource holders
None.
- 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 _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.net
--
Satoru Tsurumaki BBIX, Inc _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.net
Hello everyone,
In my opinion, even Trading of IPs (leave apart the lease for making dollars) in the name of transfers must be stopped. If organisation doesn’t need IPs , then those must be returned back so that smaller organisations can get it from the RIR.
Currently, only the one which have millions of dollars can think of getting IPs. In today’s scenario, no one can start the Data Centre, ISP business without investing millions in IPs. Even education and research org doesn’t have an option to get IPs from RIR.
This is like horse trading and isn’t a good practice for the community as a whole.
Regards, Gaurav Kansal
On 02-Sep-2022, at 12:20, rajesh@smartlinkindia.com wrote:
Dear Team,
As Mr. Satoru, mentioned there are changes, but if carefully implemented in phased manner, unauthorised leasing can be stopped.
For example in first phase, leasing among countries can be stopped, if the owner company doesn't provide any services beyond its home country. For example if a company in India doesn't have any operation in Singapore or Japan , can't lease resources to those companies in Singapore or Japan. This can be verified by taking business registration documents of both lease and lessor. Once this is done same may be granularized at RIR level, where in country like India, leasing can be restricted to the licensed service area for service provider within their designated service area. This may stop majority of issues, barring few exceptions. Some more brainstorming is required for better understanding and precise implementation.
Regards,
Rajesh Panwala For Smartlink Solutions Pvt Ltd +91-9227886001 +91-9426110781
On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru <stsuruma@bbix.net mailto:stsuruma@bbix.net> wrote: Dear Colleagues,
I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team..
I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals.
Many participants support the intent of the proposal but felt that implementation would be challenging.
(comment details)
- It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses.
- I think this proposal would be useful if the concept of leasing is
accurately defined.
- Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement.
Regards,
Satoru Tsurumaki / JPOPF Steering Team
2022年8月26日(金) 17:27 Shaila Sharmin <shaila.sharmin.ovi@gmail.com mailto:shaila.sharmin.ovi@gmail.com>:
Dear SIG members,
A new version of the proposal "prop-148-v002: Clarification - Leasing of Resources is not Acceptable" has been sent to the Policy SIG for review.
Information about earlier versions is available from:
http://www.apnic.net/policy/proposals/prop-148 http://www.apnic.net/policy/proposals/prop-148
You are encouraged to express your views on the proposal:
- Do you support or oppose the proposal?
- Is there anything in the proposal that is not clear?
- What changes could be made to this proposal to make it more effective?
Please find the text of the proposal below.
Regards, Bertrand, Shaila, and Ching-Heng APNIC Policy SIG Chairs
prop-148-v002: Clarification - Leasing of Resources is not Acceptable
Proposer: Jordi Palet Martinez (jordi.palet@theipv6company.comAnupam) Amrita Choudhury (amritachoudhury@ccaoi.in mailto:amritachoudhury@ccaoi.in) Fernando Frediani (fhfredani@gmail.com mailto:fhfredani@gmail.com)
- Problem statement
RIRs have been conceived to manage, allocate and assign resources according to need, in such a 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 delegated by APNIC or an NIR, the justification of the need implies the need to use on their own infrastructure and/or network connectivity services provided directly to customers. As a result, any form of IP address leasing is unacceptable, 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.
APNIC may proactively investigate those cases and also initiate the investigation in case of reports by means of a form, email address or other means developed by APNIC.
If any form of leasing, regardless of when the delegation has been issued, is confirmed by an APNIC investigation, it will be considered a policy violation and revocation may apply against any account holders who are leasing or using them for any purposes not specified in the initial request.
- Advantages / Disadvantages
Advantages: Fulfilling the objective above indicated and making the policy clear.
Disadvantages: None.
- Impact on resource holders
None.
- References
https://www.arin.net/participate/policy/proposals/2022/ARIN_prop_308_v2/ https://www.arin.net/participate/policy/proposals/2022/ARIN_prop_308_v2/ https://politicas.lacnic.net/politicas/detail/id/LAC-2022-2/language/en https://politicas.lacnic.net/politicas/detail/id/LAC-2022-2/language/en _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ 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
--
Satoru Tsurumaki BBIX, Inc _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ 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_______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.net
Yes, I definitively agree with that: The most honorable thing will be to return resources that you don’t use for your directly connected customers.
However, not allowing that when the community accepted it long time ago, would have been a failure, because many organizations just look for their own interest instead of the global community one.
In the case of leasing is already not covered by policies, we just want to make sure that it is sufficiently clear.
Regards,
Jordi
@jordipalet
El 2/9/22, 9:23, "Gaurav Kansal" gaurav.kansal@nic.in escribió:
Hello everyone,
In my opinion, even Trading of IPs (leave apart the lease for making dollars) in the name of transfers must be stopped.
If organisation doesn’t need IPs , then those must be returned back so that smaller organisations can get it from the RIR.
Currently, only the one which have millions of dollars can think of getting IPs. In today’s scenario, no one can start the Data Centre, ISP business without investing millions in IPs. Even education and research org doesn’t have an option to get IPs from RIR.
This is like horse trading and isn’t a good practice for the community as a whole.
Regards,
Gaurav Kansal
On 02-Sep-2022, at 12:20, rajesh@smartlinkindia.com wrote:
Dear Team,
As Mr. Satoru, mentioned there are changes, but if carefully implemented in phased manner, unauthorised leasing can be stopped.
For example in first phase, leasing among countries can be stopped, if the owner company doesn't provide any services beyond its home country. For example if a company in India doesn't have any operation in Singapore or Japan , can't lease resources to those companies in Singapore or Japan. This can be verified by taking business registration documents of both lease and lessor.
Once this is done same may be granularized at RIR level, where in country like India, leasing can be restricted to the licensed service area for service provider within their designated service area.
This may stop majority of issues, barring few exceptions.
Some more brainstorming is required for better understanding and precise implementation.
Regards,
Rajesh Panwala
For Smartlink Solutions Pvt Ltd
+91-9227886001
+91-9426110781
On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru stsuruma@bbix.net wrote:
Dear Colleagues,
I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team..
I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals.
Many participants support the intent of the proposal but felt that implementation would be challenging.
(comment details) - It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses. - I think this proposal would be useful if the concept of leasing is accurately defined. - Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement.
Regards,
Satoru Tsurumaki / JPOPF Steering Team
2022年8月26日(金) 17:27 Shaila Sharmin shaila.sharmin.ovi@gmail.com:
Dear SIG members,
A new version of the proposal "prop-148-v002: Clarification - Leasing of Resources is not Acceptable" has been sent to the Policy SIG for review.
Information about earlier versions is available from:
http://www.apnic.net/policy/proposals/prop-148
You are encouraged to express your views on the proposal:
- Do you support or oppose the proposal?
- Is there anything in the proposal that is not clear?
- What changes could be made to this proposal to make it more effective?
Please find the text of the proposal below.
Regards, Bertrand, Shaila, and Ching-Heng APNIC Policy SIG Chairs
prop-148-v002: Clarification - 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 a 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 delegated by APNIC or an NIR, the justification of the need implies the need to use on their own infrastructure and/or network connectivity services provided directly to customers. As a result, any form of IP address leasing is unacceptable, 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.
APNIC may proactively investigate those cases and also initiate the investigation in case of reports by means of a form, email address or other means developed by APNIC.
If any form of leasing, regardless of when the delegation has been issued, is confirmed by an APNIC investigation, it will be considered a policy violation and revocation may apply against any account holders who are leasing or using them for any purposes not specified in the initial request.
- Advantages / Disadvantages
Advantages: Fulfilling the objective above indicated and making the policy clear.
Disadvantages: None.
- Impact on resource holders
None.
- 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 _______________________________________________ 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,
Have you done any analysis to check how big a problem it is in the APNIC service region? for example check all (or may be a subset of) the allocations and assignments by the APNIC along with their allocated ASN(s) and see if those resources are originating from these ASN(s).
Regards,
Aftab A. Siddiqui
On Wed, 7 Sept 2022 at 20:37, JORDI PALET MARTINEZ via sig-policy < sig-policy@lists.apnic.net> wrote:
Yes, I definitively agree with that: The most honorable thing will be to return resources that you don’t use for your directly connected customers.
However, not allowing that when the community accepted it long time ago, would have been a failure, because many organizations just look for their own interest instead of the global community one.
In the case of leasing is already not covered by policies, we just want to make sure that it is sufficiently clear.
Regards,
Jordi
@jordipalet
El 2/9/22, 9:23, "Gaurav Kansal" gaurav.kansal@nic.in escribió:
Hello everyone,
In my opinion, even Trading of IPs (leave apart the lease for making dollars) in the name of transfers must be stopped.
If organisation doesn’t need IPs , then those must be returned back so that smaller organisations can get it from the RIR.
Currently, only the one which have millions of dollars can think of getting IPs. In today’s scenario, no one can start the Data Centre, ISP business without investing millions in IPs. Even education and research org doesn’t have an option to get IPs from RIR.
This is like horse trading and isn’t a good practice for the community as a whole.
Regards,
Gaurav Kansal
On 02-Sep-2022, at 12:20, rajesh@smartlinkindia.com wrote:
Dear Team,
As Mr. Satoru, mentioned there are changes, but if carefully implemented in phased manner, unauthorised leasing can be stopped.
For example in first phase, leasing among countries can be stopped, if the owner company doesn't provide any services beyond its home country. For example if a company in India doesn't have any operation in Singapore or Japan , can't lease resources to those companies in Singapore or Japan. This can be verified by taking business registration documents of both lease and lessor.
Once this is done same may be granularized at RIR level, where in country like India, leasing can be restricted to the licensed service area for service provider within their designated service area.
This may stop majority of issues, barring few exceptions.
Some more brainstorming is required for better understanding and precise implementation.
Regards,
Rajesh Panwala
For Smartlink Solutions Pvt Ltd
+91-9227886001
+91-9426110781
On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru stsuruma@bbix.net wrote:
Dear Colleagues,
I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team..
I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals.
Many participants support the intent of the proposal but felt that implementation would be challenging.
(comment details)
- It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses.
- I think this proposal would be useful if the concept of leasing is
accurately defined.
- Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement.
Regards,
Satoru Tsurumaki / JPOPF Steering Team
2022年8月26日(金) 17:27 Shaila Sharmin shaila.sharmin.ovi@gmail.com:
Dear SIG members,
A new version of the proposal "prop-148-v002: Clarification - Leasing of Resources is not Acceptable" has been sent to the Policy SIG for review.
Information about earlier versions is available from:
http://www.apnic.net/policy/proposals/prop-148
You are encouraged to express your views on the proposal:
- Do you support or oppose the proposal?
- Is there anything in the proposal that is not clear?
- What changes could be made to this proposal to make it more
effective?
Please find the text of the proposal below.
Regards, Bertrand, Shaila, and Ching-Heng APNIC Policy SIG Chairs
prop-148-v002: Clarification - 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 a 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 delegated by APNIC or an NIR, the justification of the need implies the need to use on their own infrastructure and/or network connectivity services provided directly to customers. As a result, any form of IP address leasing is unacceptable, 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.
APNIC may proactively investigate those cases and also initiate the investigation in case of reports by means of a form, email address or other means developed by APNIC.
If any form of leasing, regardless of when the delegation has been issued, is confirmed by an APNIC investigation, it will be considered a policy violation and revocation may apply against any account holders who are leasing or using them for any purposes not specified in the initial request.
- Advantages / Disadvantages
Advantages: Fulfilling the objective above indicated and making the policy clear.
Disadvantages: None.
- Impact on resource holders
None.
- 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 _______________________________________________ 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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Hi Aftab,
No, didn’t, however I don’t need to do that in order to understand that the same as in other regions, the text in APNIC is not sufficiently clear and we should improve it, regardless of what amount of leasing is happening.
If you have the data, would be nice if you can share it, but I don’t think that will change our view that the policy text should be clear.
Regards,
Jordi
@jordipalet
El 7/9/22, 12:53, "Aftab Siddiqui" aftab.siddiqui@gmail.com escribió:
Hi Jordi,
Have you done any analysis to check how big a problem it is in the APNIC service region? for example check all (or may be a subset of) the allocations and assignments by the APNIC along with their allocated ASN(s) and see if those resources are originating from these ASN(s).
Regards,
Aftab A. Siddiqui
On Wed, 7 Sept 2022 at 20:37, JORDI PALET MARTINEZ via sig-policy sig-policy@lists.apnic.net wrote:
Yes, I definitively agree with that: The most honorable thing will be to return resources that you don’t use for your directly connected customers.
However, not allowing that when the community accepted it long time ago, would have been a failure, because many organizations just look for their own interest instead of the global community one.
In the case of leasing is already not covered by policies, we just want to make sure that it is sufficiently clear.
Regards,
Jordi
@jordipalet
El 2/9/22, 9:23, "Gaurav Kansal" gaurav.kansal@nic.in escribió:
Hello everyone,
In my opinion, even Trading of IPs (leave apart the lease for making dollars) in the name of transfers must be stopped.
If organisation doesn’t need IPs , then those must be returned back so that smaller organisations can get it from the RIR.
Currently, only the one which have millions of dollars can think of getting IPs. In today’s scenario, no one can start the Data Centre, ISP business without investing millions in IPs. Even education and research org doesn’t have an option to get IPs from RIR.
This is like horse trading and isn’t a good practice for the community as a whole.
Regards,
Gaurav Kansal
On 02-Sep-2022, at 12:20, rajesh@smartlinkindia.com wrote:
Dear Team,
As Mr. Satoru, mentioned there are changes, but if carefully implemented in phased manner, unauthorised leasing can be stopped.
For example in first phase, leasing among countries can be stopped, if the owner company doesn't provide any services beyond its home country. For example if a company in India doesn't have any operation in Singapore or Japan , can't lease resources to those companies in Singapore or Japan. This can be verified by taking business registration documents of both lease and lessor.
Once this is done same may be granularized at RIR level, where in country like India, leasing can be restricted to the licensed service area for service provider within their designated service area.
This may stop majority of issues, barring few exceptions.
Some more brainstorming is required for better understanding and precise implementation.
Regards,
Rajesh Panwala
For Smartlink Solutions Pvt Ltd
+91-9227886001
+91-9426110781
On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru stsuruma@bbix.net wrote:
Dear Colleagues,
I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team..
I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals.
Many participants support the intent of the proposal but felt that implementation would be challenging.
(comment details) - It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses. - I think this proposal would be useful if the concept of leasing is accurately defined. - Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement.
Regards,
Satoru Tsurumaki / JPOPF Steering Team
2022年8月26日(金) 17:27 Shaila Sharmin shaila.sharmin.ovi@gmail.com:
Dear SIG members,
A new version of the proposal "prop-148-v002: Clarification - Leasing of Resources is not Acceptable" has been sent to the Policy SIG for review.
Information about earlier versions is available from:
http://www.apnic.net/policy/proposals/prop-148
You are encouraged to express your views on the proposal:
- Do you support or oppose the proposal?
- Is there anything in the proposal that is not clear?
- What changes could be made to this proposal to make it more effective?
Please find the text of the proposal below.
Regards, Bertrand, Shaila, and Ching-Heng APNIC Policy SIG Chairs
prop-148-v002: Clarification - 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 a 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 delegated by APNIC or an NIR, the justification of the need implies the need to use on their own infrastructure and/or network connectivity services provided directly to customers. As a result, any form of IP address leasing is unacceptable, 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.
APNIC may proactively investigate those cases and also initiate the investigation in case of reports by means of a form, email address or other means developed by APNIC.
If any form of leasing, regardless of when the delegation has been issued, is confirmed by an APNIC investigation, it will be considered a policy violation and revocation may apply against any account holders who are leasing or using them for any purposes not specified in the initial request.
- Advantages / Disadvantages
Advantages: Fulfilling the objective above indicated and making the policy clear.
Disadvantages: None.
- Impact on resource holders
None.
- 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 _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.net
Hello Aftab
This is not necessary simply because the proposal does not intend to change anything from what is currently is: IP Leasing is already forbidden. Therefore the proposal only makes it clearer to everything for the avoidance of doubt and reduces the risk of people misusing IP addresses and eventual litigation between the member and the RIR.
Fernando
On 07/09/2022 07:52, Aftab Siddiqui wrote:
Hi Jordi,
Have you done any analysis to check how big a problem it is in the APNIC service region? for example check all (or may be a subset of) the allocations and assignments by the APNIC along with their allocated ASN(s) and see if those resources are originating from these ASN(s).
Regards,
Aftab A. Siddiqui
On Wed, 7 Sept 2022 at 20:37, JORDI PALET MARTINEZ via sig-policy sig-policy@lists.apnic.net wrote:
Yes, I definitively agree with that: The most honorable thing will be to return resources that you don’t use for your directly connected customers. However, not allowing that when the community accepted it long time ago, would have been a failure, because many organizations just look for their own interest instead of the global community one. In the case of leasing is already not covered by policies, we just want to make sure that it is sufficiently clear. Regards, Jordi @jordipalet El 2/9/22, 9:23, "Gaurav Kansal" <gaurav.kansal@nic.in> escribió: Hello everyone, In my opinion, even Trading of IPs (leave apart the lease for making dollars) in the name of transfers must be stopped. If organisation doesn’t need IPs , then those must be returned back so that smaller organisations can get it from the RIR. Currently, only the one which have millions of dollars can think of getting IPs. In today’s scenario, no one can start the Data Centre, ISP business without investing millions in IPs. Even education and research org doesn’t have an option to get IPs from RIR. This is like horse trading and isn’t a good practice for the community as a whole. Regards, Gaurav Kansal On 02-Sep-2022, at 12:20, rajesh@smartlinkindia.com wrote: Dear Team, As Mr. Satoru, mentioned there are changes, but if carefully implemented in phased manner, unauthorised leasing can be stopped. For example in first phase, leasing among countries can be stopped, if the owner company doesn't provide any services beyond its home country. For example if a company in India doesn't have any operation in Singapore or Japan , can't lease resources to those companies in Singapore or Japan. This can be verified by taking business registration documents of both lease and lessor. Once this is done same may be granularized at RIR level, where in country like India, leasing can be restricted to the licensed service area for service provider within their designated service area. This may stop majority of issues, barring few exceptions. Some more brainstorming is required for better understanding and precise implementation. Regards, Rajesh Panwala For Smartlink Solutions Pvt Ltd +91-9227886001 +91-9426110781 On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru <stsuruma@bbix.net> wrote: Dear Colleagues, I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team.. I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals. Many participants support the intent of the proposal but felt that implementation would be challenging. (comment details) - It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses. - I think this proposal would be useful if the concept of leasing is accurately defined. - Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement. Regards, Satoru Tsurumaki / JPOPF Steering Team 2022年8月26日(金) 17:27 Shaila Sharmin <shaila.sharmin.ovi@gmail.com>: > > Dear SIG members, > > A new version of the proposal "prop-148-v002: Clarification - Leasing of > Resources is not Acceptable" has been sent to the Policy SIG for review. > > Information about earlier versions is available from: > > http://www.apnic.net/policy/proposals/prop-148 > > You are encouraged to express your views on the proposal: > > - Do you support or oppose the proposal? > - Is there anything in the proposal that is not clear? > - What changes could be made to this proposal to make it more effective? > > Please find the text of the proposal below. > > Regards, > Bertrand, Shaila, and Ching-Heng > APNIC Policy SIG Chairs > > > ---------------------------------------------------------------------- > prop-148-v002: Clarification - 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 a 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 delegated by APNIC or an NIR, > the justification of the need implies the need to use on their own > infrastructure and/or network connectivity services provided directly to > customers. As a result, any form of IP address leasing is unacceptable, > 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. > > APNIC may proactively investigate those cases and also initiate the > investigation in case of reports by means of a form, email address or > other means developed by APNIC. > > If any form of leasing, regardless of when the delegation has been > issued, is confirmed by an APNIC investigation, it will be considered a > policy violation and revocation may apply against any account holders > who are leasing or using them for any purposes not specified in the > initial request. > > > 5. Advantages / Disadvantages > ----------------------------- > Advantages: > Fulfilling the objective above indicated and making the policy clear. > > Disadvantages: > None. > > > 6. Impact on resource holders > ----------------------------- > None. > > > 7. References > ------------- > https://www.arin.net/participate/policy/proposals/2022/ARIN_prop_308_v2/ > https://politicas.lacnic.net/politicas/detail/id/LAC-2022-2/language/en > _______________________________________________ > sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ > To unsubscribe send an email to sig-policy-leave@lists.apnic.net -- -- Satoru Tsurumaki BBIX, Inc _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.net _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.net <https://amritmahotsav.nic.in/> _______________________________________________ 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. 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Hello,
Per Gaurav’s statement that “only those with millions of dollars can think of getting ips”, this community should oppose this policy.
Because the only way small companies can afford to get ips today is by leasing them. The same way the small company can’t afford to purchase a big office building but instead rents an office. Leasing is the only way to finance IPv4 acquisitions today. No bank or other entity that I am aware of will do it. Purchasing addresses requires full upfront payment, but leasing allow for much smaller monthly payments.
If this community wants to ensure only the largest and richest companies can acquire new addresses, ban leasing.
But if the community tries to ban something with such a large business motivation behind it, it will find itself struggling against a powerful foe.
And for what purpose do we punish the small businesses? Leasing puts addresses in the hands of those who need them to build and operate networks. Isn’t that the primary goal of the RIR system?
Regards,
Mike
El 2/9/22, 9:23, "Gaurav Kansal" <gaurav.kansal@nic.in mailto:gaurav.kansal@nic.in > escribió:
Hello everyone,
In my opinion, even Trading of IPs (leave apart the lease for making dollars) in the name of transfers must be stopped.
If organisation doesn’t need IPs , then those must be returned back so that smaller organisations can get it from the RIR.
Currently, only the one which have millions of dollars can think of getting IPs. In today’s scenario, no one can start the Data Centre, ISP business without investing millions in IPs. Even education and research org doesn’t have an option to get IPs from RIR.
This is like horse trading and isn’t a good practice for the community as a whole.
Regards,
Gaurav Kansal
On 02-Sep-2022, at 12:20, rajesh@smartlinkindia.com mailto:rajesh@smartlinkindia.com wrote:
Dear Team,
As Mr. Satoru, mentioned there are changes, but if carefully implemented in phased manner, unauthorised leasing can be stopped.
For example in first phase, leasing among countries can be stopped, if the owner company doesn't provide any services beyond its home country. For example if a company in India doesn't have any operation in Singapore or Japan , can't lease resources to those companies in Singapore or Japan. This can be verified by taking business registration documents of both lease and lessor.
Once this is done same may be granularized at RIR level, where in country like India, leasing can be restricted to the licensed service area for service provider within their designated service area.
This may stop majority of issues, barring few exceptions.
Some more brainstorming is required for better understanding and precise implementation.
Regards,
Rajesh Panwala
For Smartlink Solutions Pvt Ltd
+91-9227886001
+91-9426110781
On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru <stsuruma@bbix.net mailto:stsuruma@bbix.net > wrote:
Dear Colleagues,
I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team..
I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals.
Many participants support the intent of the proposal but felt that implementation would be challenging.
(comment details) - It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses. - I think this proposal would be useful if the concept of leasing is accurately defined. - Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement.
Regards,
Satoru Tsurumaki / JPOPF Steering Team
2022年8月26日(金) 17:27 Shaila Sharmin <shaila.sharmin.ovi@gmail.com mailto:shaila.sharmin.ovi@gmail.com >:
Dear SIG members,
A new version of the proposal "prop-148-v002: Clarification - Leasing of Resources is not Acceptable" has been sent to the Policy SIG for review.
Information about earlier versions is available from:
http://www.apnic.net/policy/proposals/prop-148
You are encouraged to express your views on the proposal:
- Do you support or oppose the proposal?
- Is there anything in the proposal that is not clear?
- What changes could be made to this proposal to make it more effective?
Please find the text of the proposal below.
Regards, Bertrand, Shaila, and Ching-Heng APNIC Policy SIG Chairs
prop-148-v002: Clarification - 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 )
- Problem statement
RIRs have been conceived to manage, allocate and assign resources according to need, in such a 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 delegated by APNIC or an NIR, the justification of the need implies the need to use on their own infrastructure and/or network connectivity services provided directly to customers. As a result, any form of IP address leasing is unacceptable, 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.
APNIC may proactively investigate those cases and also initiate the investigation in case of reports by means of a form, email address or other means developed by APNIC.
If any form of leasing, regardless of when the delegation has been issued, is confirmed by an APNIC investigation, it will be considered a policy violation and revocation may apply against any account holders who are leasing or using them for any purposes not specified in the initial request.
- Advantages / Disadvantages
Advantages: Fulfilling the objective above indicated and making the policy clear.
Disadvantages: None.
- Impact on resource holders
None.
- 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 _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.net
Actually, I must disagree …
If organizations having unused resources, they need to transfer them or return them to the RIR. If prices keep going high, that could encourage faster IPv6 adoption, then transfer prices will go down, up to “no value”. It takes time, but it is just market.
Those that have more money, have more facilities to do a faster transition and not bother about IPv4.
Regards,
Jordi
@jordipalet
El 7/9/22, 16:05, "Mike Burns" mike@iptrading.com escribió:
Hello,
Per Gaurav’s statement that “only those with millions of dollars can think of getting ips”, this community should oppose this policy.
Because the only way small companies can afford to get ips today is by leasing them. The same way the small company can’t afford to purchase a big office building but instead rents an office. Leasing is the only way to finance IPv4 acquisitions today. No bank or other entity that I am aware of will do it. Purchasing addresses requires full upfront payment, but leasing allow for much smaller monthly payments.
If this community wants to ensure only the largest and richest companies can acquire new addresses, ban leasing.
But if the community tries to ban something with such a large business motivation behind it, it will find itself struggling against a powerful foe.
And for what purpose do we punish the small businesses? Leasing puts addresses in the hands of those who need them to build and operate networks. Isn’t that the primary goal of the RIR system?
Regards,
Mike
El 2/9/22, 9:23, "Gaurav Kansal" gaurav.kansal@nic.in escribió:
Hello everyone,
In my opinion, even Trading of IPs (leave apart the lease for making dollars) in the name of transfers must be stopped.
If organisation doesn’t need IPs , then those must be returned back so that smaller organisations can get it from the RIR.
Currently, only the one which have millions of dollars can think of getting IPs. In today’s scenario, no one can start the Data Centre, ISP business without investing millions in IPs. Even education and research org doesn’t have an option to get IPs from RIR.
This is like horse trading and isn’t a good practice for the community as a whole.
Regards,
Gaurav Kansal
On 02-Sep-2022, at 12:20, rajesh@smartlinkindia.com wrote:
Dear Team,
As Mr. Satoru, mentioned there are changes, but if carefully implemented in phased manner, unauthorised leasing can be stopped.
For example in first phase, leasing among countries can be stopped, if the owner company doesn't provide any services beyond its home country. For example if a company in India doesn't have any operation in Singapore or Japan , can't lease resources to those companies in Singapore or Japan. This can be verified by taking business registration documents of both lease and lessor.
Once this is done same may be granularized at RIR level, where in country like India, leasing can be restricted to the licensed service area for service provider within their designated service area.
This may stop majority of issues, barring few exceptions.
Some more brainstorming is required for better understanding and precise implementation.
Regards,
Rajesh Panwala
For Smartlink Solutions Pvt Ltd
+91-9227886001
+91-9426110781
On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru stsuruma@bbix.net wrote:
Dear Colleagues,
I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team..
I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals.
Many participants support the intent of the proposal but felt that implementation would be challenging.
(comment details) - It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses. - I think this proposal would be useful if the concept of leasing is accurately defined. - Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement.
Regards,
Satoru Tsurumaki / JPOPF Steering Team
2022年8月26日(金) 17:27 Shaila Sharmin shaila.sharmin.ovi@gmail.com:
Dear SIG members,
A new version of the proposal "prop-148-v002: Clarification - Leasing of Resources is not Acceptable" has been sent to the Policy SIG for review.
Information about earlier versions is available from:
http://www.apnic.net/policy/proposals/prop-148
You are encouraged to express your views on the proposal:
- Do you support or oppose the proposal?
- Is there anything in the proposal that is not clear?
- What changes could be made to this proposal to make it more effective?
Please find the text of the proposal below.
Regards, Bertrand, Shaila, and Ching-Heng APNIC Policy SIG Chairs
prop-148-v002: Clarification - 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 a 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 delegated by APNIC or an NIR, the justification of the need implies the need to use on their own infrastructure and/or network connectivity services provided directly to customers. As a result, any form of IP address leasing is unacceptable, 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.
APNIC may proactively investigate those cases and also initiate the investigation in case of reports by means of a form, email address or other means developed by APNIC.
If any form of leasing, regardless of when the delegation has been issued, is confirmed by an APNIC investigation, it will be considered a policy violation and revocation may apply against any account holders who are leasing or using them for any purposes not specified in the initial request.
- Advantages / Disadvantages
Advantages: Fulfilling the objective above indicated and making the policy clear.
Disadvantages: None.
- Impact on resource holders
None.
- 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 _______________________________________________ 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,
It’s plain you feel that we should do all possible to raise the price of IPv4 and make it unattainable for small business in the vain hope that this will drive IPv6 adoption.
I don’t think making IPv4 more difficult to acquire is the job of the RIR system.
You have not addressed the inability of smaller companies to acquire necessary IPv4 blocks if you ban leasing.
Is that something you are comfortable with, in pursuit of the IPv6 grail?
It’s okay with you that this policy prevents small companies from growing?
Regards, Mike
From: JORDI PALET MARTINEZ via sig-policy sig-policy@lists.apnic.net Sent: Wednesday, September 7, 2022 10:11 AM To: sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Actually, I must disagree …
If organizations having unused resources, they need to transfer them or return them to the RIR. If prices keep going high, that could encourage faster IPv6 adoption, then transfer prices will go down, up to “no value”. It takes time, but it is just market.
Those that have more money, have more facilities to do a faster transition and not bother about IPv4.
Regards,
Jordi
@jordipalet
El 7/9/22, 16:05, "Mike Burns" <mike@iptrading.com mailto:mike@iptrading.com > escribió:
Hello,
Per Gaurav’s statement that “only those with millions of dollars can think of getting ips”, this community should oppose this policy.
Because the only way small companies can afford to get ips today is by leasing them. The same way the small company can’t afford to purchase a big office building but instead rents an office. Leasing is the only way to finance IPv4 acquisitions today. No bank or other entity that I am aware of will do it. Purchasing addresses requires full upfront payment, but leasing allow for much smaller monthly payments.
If this community wants to ensure only the largest and richest companies can acquire new addresses, ban leasing.
But if the community tries to ban something with such a large business motivation behind it, it will find itself struggling against a powerful foe.
And for what purpose do we punish the small businesses? Leasing puts addresses in the hands of those who need them to build and operate networks. Isn’t that the primary goal of the RIR system?
Regards,
Mike
El 2/9/22, 9:23, "Gaurav Kansal" <gaurav.kansal@nic.in mailto:gaurav.kansal@nic.in > escribió:
Hello everyone,
In my opinion, even Trading of IPs (leave apart the lease for making dollars) in the name of transfers must be stopped.
If organisation doesn’t need IPs , then those must be returned back so that smaller organisations can get it from the RIR.
Currently, only the one which have millions of dollars can think of getting IPs. In today’s scenario, no one can start the Data Centre, ISP business without investing millions in IPs. Even education and research org doesn’t have an option to get IPs from RIR.
This is like horse trading and isn’t a good practice for the community as a whole.
Regards,
Gaurav Kansal
On 02-Sep-2022, at 12:20, rajesh@smartlinkindia.com mailto:rajesh@smartlinkindia.com wrote:
Dear Team,
As Mr. Satoru, mentioned there are changes, but if carefully implemented in phased manner, unauthorised leasing can be stopped.
For example in first phase, leasing among countries can be stopped, if the owner company doesn't provide any services beyond its home country. For example if a company in India doesn't have any operation in Singapore or Japan , can't lease resources to those companies in Singapore or Japan. This can be verified by taking business registration documents of both lease and lessor.
Once this is done same may be granularized at RIR level, where in country like India, leasing can be restricted to the licensed service area for service provider within their designated service area.
This may stop majority of issues, barring few exceptions.
Some more brainstorming is required for better understanding and precise implementation.
Regards,
Rajesh Panwala
For Smartlink Solutions Pvt Ltd
+91-9227886001
+91-9426110781
On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru <stsuruma@bbix.net mailto:stsuruma@bbix.net > wrote:
Dear Colleagues,
I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team..
I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals.
Many participants support the intent of the proposal but felt that implementation would be challenging.
(comment details) - It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses. - I think this proposal would be useful if the concept of leasing is accurately defined. - Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement.
Regards,
Satoru Tsurumaki / JPOPF Steering Team
2022年8月26日(金) 17:27 Shaila Sharmin <shaila.sharmin.ovi@gmail.com mailto:shaila.sharmin.ovi@gmail.com >:
Dear SIG members,
A new version of the proposal "prop-148-v002: Clarification - Leasing of Resources is not Acceptable" has been sent to the Policy SIG for review.
Information about earlier versions is available from:
http://www.apnic.net/policy/proposals/prop-148
You are encouraged to express your views on the proposal:
- Do you support or oppose the proposal?
- Is there anything in the proposal that is not clear?
- What changes could be made to this proposal to make it more effective?
Please find the text of the proposal below.
Regards, Bertrand, Shaila, and Ching-Heng APNIC Policy SIG Chairs
prop-148-v002: Clarification - 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 )
- Problem statement
RIRs have been conceived to manage, allocate and assign resources according to need, in such a 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 delegated by APNIC or an NIR, the justification of the need implies the need to use on their own infrastructure and/or network connectivity services provided directly to customers. As a result, any form of IP address leasing is unacceptable, 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.
APNIC may proactively investigate those cases and also initiate the investigation in case of reports by means of a form, email address or other means developed by APNIC.
If any form of leasing, regardless of when the delegation has been issued, is confirmed by an APNIC investigation, it will be considered a policy violation and revocation may apply against any account holders who are leasing or using them for any purposes not specified in the initial request.
- Advantages / Disadvantages
Advantages: Fulfilling the objective above indicated and making the policy clear.
Disadvantages: None.
- Impact on resource holders
None.
- 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 _______________________________________________ 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
No, I’m not thinking that anyone should increase the price. I consider that the right thing to do is that if anyone that has unused recourses, should be honest enough with the community to return them to the RIR, unfortunately the world is not so nice.
Smaller ISPs are the ones that have an easier and cheaper transition to IPv6 is they start doing so now, as latest, more expensive. We have seen this already since long time ago. It is their decision. Not doing the transition is already meaning they are risking their own business.
Leasing is against the actual policy. We don’t change that. If you really think it should be changed, the way is not working against this proposal, but making one that change the actual status quo.
Regards,
Jordi
@jordipalet
El 7/9/22, 16:15, "Mike Burns" mike@iptrading.com escribió:
Hi Jordi,
It’s plain you feel that we should do all possible to raise the price of IPv4 and make it unattainable for small business in the vain hope that this will drive IPv6 adoption.
I don’t think making IPv4 more difficult to acquire is the job of the RIR system.
You have not addressed the inability of smaller companies to acquire necessary IPv4 blocks if you ban leasing.
Is that something you are comfortable with, in pursuit of the IPv6 grail?
It’s okay with you that this policy prevents small companies from growing?
Regards, Mike
From: JORDI PALET MARTINEZ via sig-policy sig-policy@lists.apnic.net Sent: Wednesday, September 7, 2022 10:11 AM To: sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Actually, I must disagree …
If organizations having unused resources, they need to transfer them or return them to the RIR. If prices keep going high, that could encourage faster IPv6 adoption, then transfer prices will go down, up to “no value”. It takes time, but it is just market.
Those that have more money, have more facilities to do a faster transition and not bother about IPv4.
Regards,
Jordi
@jordipalet
El 7/9/22, 16:05, "Mike Burns" mike@iptrading.com escribió:
Hello,
Per Gaurav’s statement that “only those with millions of dollars can think of getting ips”, this community should oppose this policy.
Because the only way small companies can afford to get ips today is by leasing them. The same way the small company can’t afford to purchase a big office building but instead rents an office. Leasing is the only way to finance IPv4 acquisitions today. No bank or other entity that I am aware of will do it. Purchasing addresses requires full upfront payment, but leasing allow for much smaller monthly payments.
If this community wants to ensure only the largest and richest companies can acquire new addresses, ban leasing.
But if the community tries to ban something with such a large business motivation behind it, it will find itself struggling against a powerful foe.
And for what purpose do we punish the small businesses? Leasing puts addresses in the hands of those who need them to build and operate networks. Isn’t that the primary goal of the RIR system?
Regards,
Mike
El 2/9/22, 9:23, "Gaurav Kansal" gaurav.kansal@nic.in escribió:
Hello everyone,
In my opinion, even Trading of IPs (leave apart the lease for making dollars) in the name of transfers must be stopped.
If organisation doesn’t need IPs , then those must be returned back so that smaller organisations can get it from the RIR.
Currently, only the one which have millions of dollars can think of getting IPs. In today’s scenario, no one can start the Data Centre, ISP business without investing millions in IPs. Even education and research org doesn’t have an option to get IPs from RIR.
This is like horse trading and isn’t a good practice for the community as a whole.
Regards,
Gaurav Kansal
On 02-Sep-2022, at 12:20, rajesh@smartlinkindia.com wrote:
Dear Team,
As Mr. Satoru, mentioned there are changes, but if carefully implemented in phased manner, unauthorised leasing can be stopped.
For example in first phase, leasing among countries can be stopped, if the owner company doesn't provide any services beyond its home country. For example if a company in India doesn't have any operation in Singapore or Japan , can't lease resources to those companies in Singapore or Japan. This can be verified by taking business registration documents of both lease and lessor.
Once this is done same may be granularized at RIR level, where in country like India, leasing can be restricted to the licensed service area for service provider within their designated service area.
This may stop majority of issues, barring few exceptions.
Some more brainstorming is required for better understanding and precise implementation.
Regards,
Rajesh Panwala
For Smartlink Solutions Pvt Ltd
+91-9227886001
+91-9426110781
On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru stsuruma@bbix.net wrote:
Dear Colleagues,
I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team..
I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals.
Many participants support the intent of the proposal but felt that implementation would be challenging.
(comment details) - It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses. - I think this proposal would be useful if the concept of leasing is accurately defined. - Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement.
Regards,
Satoru Tsurumaki / JPOPF Steering Team
2022年8月26日(金) 17:27 Shaila Sharmin shaila.sharmin.ovi@gmail.com:
Dear SIG members,
A new version of the proposal "prop-148-v002: Clarification - Leasing of Resources is not Acceptable" has been sent to the Policy SIG for review.
Information about earlier versions is available from:
http://www.apnic.net/policy/proposals/prop-148
You are encouraged to express your views on the proposal:
- Do you support or oppose the proposal?
- Is there anything in the proposal that is not clear?
- What changes could be made to this proposal to make it more effective?
Please find the text of the proposal below.
Regards, Bertrand, Shaila, and Ching-Heng APNIC Policy SIG Chairs
prop-148-v002: Clarification - 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 a 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 delegated by APNIC or an NIR, the justification of the need implies the need to use on their own infrastructure and/or network connectivity services provided directly to customers. As a result, any form of IP address leasing is unacceptable, 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.
APNIC may proactively investigate those cases and also initiate the investigation in case of reports by means of a form, email address or other means developed by APNIC.
If any form of leasing, regardless of when the delegation has been issued, is confirmed by an APNIC investigation, it will be considered a policy violation and revocation may apply against any account holders who are leasing or using them for any purposes not specified in the initial request.
- Advantages / Disadvantages
Advantages: Fulfilling the objective above indicated and making the policy clear.
Disadvantages: None.
- Impact on resource holders
None.
- 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 _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.net
If all type of leasings are against the actual policy, It make sense to change the actual policy to allow it.
I dont see any point to move forward with this proposal if the actual policy needs to be changed.
Regards,
Arash
On Thu, 8 Sep 2022, 00:31 JORDI PALET MARTINEZ via sig-policy, < sig-policy@lists.apnic.net> wrote:
No, I’m not thinking that anyone should increase the price. I consider that the right thing to do is that if anyone that has unused recourses, should be honest enough with the community to return them to the RIR, unfortunately the world is not so nice.
Smaller ISPs are the ones that have an easier and cheaper transition to IPv6 is they start doing so now, as latest, more expensive. We have seen this already since long time ago. It is their decision. Not doing the transition is already meaning they are risking their own business.
Leasing is against the actual policy. We don’t change that. If you really think it should be changed, the way is not working against this proposal, but making one that change the actual status quo.
Regards,
Jordi
@jordipalet
El 7/9/22, 16:15, "Mike Burns" mike@iptrading.com escribió:
Hi Jordi,
It’s plain you feel that we should do all possible to raise the price of IPv4 and make it unattainable for small business in the vain hope that this will drive IPv6 adoption.
I don’t think making IPv4 more difficult to acquire is the job of the RIR system.
You have not addressed the inability of smaller companies to acquire necessary IPv4 blocks if you ban leasing.
Is that something you are comfortable with, in pursuit of the IPv6 grail?
It’s okay with you that this policy prevents small companies from growing?
Regards, Mike
*From:* JORDI PALET MARTINEZ via sig-policy sig-policy@lists.apnic.net *Sent:* Wednesday, September 7, 2022 10:11 AM *To:* sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Actually, I must disagree …
If organizations having unused resources, they need to transfer them or return them to the RIR. If prices keep going high, that could encourage faster IPv6 adoption, then transfer prices will go down, up to “no value”. It takes time, but it is just market.
Those that have more money, have more facilities to do a faster transition and not bother about IPv4.
Regards,
Jordi
@jordipalet
El 7/9/22, 16:05, "Mike Burns" mike@iptrading.com escribió:
Hello,
Per Gaurav’s statement that “only those with millions of dollars can think of getting ips”, this community should oppose this policy.
Because the only way small companies can afford to get ips today is by leasing them. The same way the small company can’t afford to purchase a big office building but instead rents an office. Leasing is the only way to finance IPv4 acquisitions today. No bank or other entity that I am aware of will do it. Purchasing addresses requires full upfront payment, but leasing allow for much smaller monthly payments.
If this community wants to ensure only the largest and richest companies can acquire new addresses, ban leasing.
But if the community tries to ban something with such a large business motivation behind it, it will find itself struggling against a powerful foe.
And for what purpose do we punish the small businesses? Leasing puts addresses in the hands of those who need them to build and operate networks. Isn’t that the primary goal of the RIR system?
Regards,
Mike
El 2/9/22, 9:23, "Gaurav Kansal" gaurav.kansal@nic.in escribió:
Hello everyone,
In my opinion, even Trading of IPs (leave apart the lease for making dollars) in the name of transfers must be stopped.
If organisation doesn’t need IPs , then those must be returned back so that smaller organisations can get it from the RIR.
Currently, only the one which have millions of dollars can think of getting IPs. In today’s scenario, no one can start the Data Centre, ISP business without investing millions in IPs. Even education and research org doesn’t have an option to get IPs from RIR.
This is like horse trading and isn’t a good practice for the community as a whole.
Regards,
Gaurav Kansal
On 02-Sep-2022, at 12:20, rajesh@smartlinkindia.com wrote:
Dear Team,
As Mr. Satoru, mentioned there are changes, but if carefully implemented in phased manner, unauthorised leasing can be stopped.
For example in first phase, leasing among countries can be stopped, if the owner company doesn't provide any services beyond its home country. For example if a company in India doesn't have any operation in Singapore or Japan , can't lease resources to those companies in Singapore or Japan. This can be verified by taking business registration documents of both lease and lessor.
Once this is done same may be granularized at RIR level, where in country like India, leasing can be restricted to the licensed service area for service provider within their designated service area.
This may stop majority of issues, barring few exceptions.
Some more brainstorming is required for better understanding and precise implementation.
Regards,
Rajesh Panwala
For Smartlink Solutions Pvt Ltd
+91-9227886001
+91-9426110781
On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru stsuruma@bbix.net wrote:
Dear Colleagues,
I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team..
I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals.
Many participants support the intent of the proposal but felt that implementation would be challenging.
(comment details)
- It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses.
- I think this proposal would be useful if the concept of leasing is
accurately defined.
- Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement.
Regards,
Satoru Tsurumaki / JPOPF Steering Team
2022年8月26日(金) 17:27 Shaila Sharmin shaila.sharmin.ovi@gmail.com:
Dear SIG members,
A new version of the proposal "prop-148-v002: Clarification - Leasing of Resources is not Acceptable" has been sent to the Policy SIG for review.
Information about earlier versions is available from:
http://www.apnic.net/policy/proposals/prop-148
You are encouraged to express your views on the proposal:
- Do you support or oppose the proposal?
- Is there anything in the proposal that is not clear?
- What changes could be made to this proposal to make it more
effective?
Please find the text of the proposal below.
Regards, Bertrand, Shaila, and Ching-Heng APNIC Policy SIG Chairs
prop-148-v002: Clarification - 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 a 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 delegated by APNIC or an NIR, the justification of the need implies the need to use on their own infrastructure and/or network connectivity services provided directly to customers. As a result, any form of IP address leasing is unacceptable, 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.
APNIC may proactively investigate those cases and also initiate the investigation in case of reports by means of a form, email address or other means developed by APNIC.
If any form of leasing, regardless of when the delegation has been issued, is confirmed by an APNIC investigation, it will be considered a policy violation and revocation may apply against any account holders who are leasing or using them for any purposes not specified in the initial request.
- Advantages / Disadvantages
Advantages: Fulfilling the objective above indicated and making the policy clear.
Disadvantages: None.
- Impact on resource holders
None.
- 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 _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.net
--
Satoru Tsurumaki BBIX, Inc _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.net
sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.net
_______________________________________________ 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
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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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This is exactly the opposite.
Allowing IP leasing to happen more than just tottaly divert the propose of IP assignments by RIRs it make it bad specially for smaller companies as it increases the cost for both leasing and transfers in long term. The cost of leasing is based on the transfer and if leasing is allowed then transfer prices will always go up which makes it even harder for smaller companies to go into the market.
Any form of IP leasing without a direct connection relationship to provide a connectivity service makes it more expensive for smaller companies to get IP addresses to operate.
Fernando
On 07/09/2022 11:15, Mike Burns wrote:
Hi Jordi,
It’s plain you feel that we should do all possible to raise the price of IPv4 and make it unattainable for small business in the vain hope that this will drive IPv6 adoption.
I don’t think making IPv4 more difficult to acquire is the job of the RIR system.
You have not addressed the inability of smaller companies to acquire necessary IPv4 blocks if you ban leasing.
Is that something you are comfortable with, in pursuit of the IPv6 grail?
It’s okay with you that this policy prevents small companies from growing?
Regards, Mike
*From:* JORDI PALET MARTINEZ via sig-policy sig-policy@lists.apnic.net *Sent:* Wednesday, September 7, 2022 10:11 AM *To:* sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Actually, I must disagree …
If organizations having unused resources, they need to transfer them or return them to the RIR. If prices keep going high, that could encourage faster IPv6 adoption, then transfer prices will go down, up to “no value”. It takes time, but it is just market.
Those that have more money, have more facilities to do a faster transition and not bother about IPv4.
Regards,
Jordi
@jordipalet
El 7/9/22, 16:05, "Mike Burns" mike@iptrading.com escribió:
Hello,
Per Gaurav’s statement that “only those with millions of dollars can think of getting ips”, this community should oppose this policy.
Because the only way small companies can afford to get ips today is by leasing them. The same way the small company can’t afford to purchase a big office building but instead rents an office. Leasing is the only way to finance IPv4 acquisitions today. No bank or other entity that I am aware of will do it. Purchasing addresses requires full upfront payment, but leasing allow for much smaller monthly payments.
If this community wants to ensure only the largest and richest companies can acquire new addresses, ban leasing.
But if the community tries to ban something with such a large business motivation behind it, it will find itself struggling against a powerful foe.
And for what purpose do we punish the small businesses? Leasing puts addresses in the hands of those who need them to build and operate networks. Isn’t that the primary goal of the RIR system?
Regards,
Mike
El 2/9/22, 9:23, "Gaurav Kansal" gaurav.kansal@nic.in escribió:
Hello everyone,
In my opinion, even Trading of IPs (leave apart the lease for making dollars) in the name of transfers must be stopped.
If organisation doesn’t need IPs , then those must be returned back so that smaller organisations can get it from the RIR.
Currently, only the one which have millions of dollars can think of getting IPs. In today’s scenario, no one can start the Data Centre, ISP business without investing millions in IPs. Even education and research org doesn’t have an option to get IPs from RIR.
This is like horse trading and isn’t a good practice for the community as a whole.
Regards,
Gaurav Kansal
On 02-Sep-2022, at 12:20, rajesh@smartlinkindia.com wrote: Dear Team, As Mr. Satoru, mentioned there are changes, but if carefully implemented in phased manner, unauthorised leasing can be stopped. For example in first phase, leasing among countries can be stopped, if the owner company doesn't provide any services beyond its home country. For example if a company in India doesn't have any operation in Singapore or Japan , can't lease resources to those companies in Singapore or Japan. This can be verified by taking business registration documents of both lease and lessor. Once this is done same may be granularized at RIR level, where in country like India, leasing can be restricted to the licensed service area for service provider within their designated service area. This may stop majority of issues, barring few exceptions. Some more brainstorming is required for better understanding and precise implementation. Regards, Rajesh Panwala For Smartlink Solutions Pvt Ltd +91-9227886001 +91-9426110781 On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru <stsuruma@bbix.net> wrote: Dear Colleagues, I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team.. I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals. Many participants support the intent of the proposal but felt that implementation would be challenging. (comment details) - It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses. - I think this proposal would be useful if the concept of leasing is accurately defined. - Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement. Regards, Satoru Tsurumaki / JPOPF Steering Team 2022年8月26日(金) 17:27 Shaila Sharmin <shaila.sharmin.ovi@gmail.com>: > > Dear SIG members, > > A new version of the proposal "prop-148-v002: Clarification - Leasing of > Resources is not Acceptable" has been sent to the Policy SIG for review. > > Information about earlier versions is available from: > > http://www.apnic.net/policy/proposals/prop-148 > > You are encouraged to express your views on the proposal: > > - Do you support or oppose the proposal? > - Is there anything in the proposal that is not clear? > - What changes could be made to this proposal to make it more effective? > > Please find the text of the proposal below. > > Regards, > Bertrand, Shaila, and Ching-Heng > APNIC Policy SIG Chairs > > > ---------------------------------------------------------------------- > prop-148-v002: Clarification - 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 a 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 delegated by APNIC or an NIR, > the justification of the need implies the need to use on their own > infrastructure and/or network connectivity services provided directly to > customers. As a result, any form of IP address leasing is unacceptable, > 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. > > APNIC may proactively investigate those cases and also initiate the > investigation in case of reports by means of a form, email address or > other means developed by APNIC. > > If any form of leasing, regardless of when the delegation has been > issued, is confirmed by an APNIC investigation, it will be considered a > policy violation and revocation may apply against any account holders > who are leasing or using them for any purposes not specified in the > initial request. > > > 5. Advantages / Disadvantages > ----------------------------- > Advantages: > Fulfilling the objective above indicated and making the policy clear. > > Disadvantages: > None. > > > 6. Impact on resource holders > ----------------------------- > None. > > > 7. References > ------------- > https://www.arin.net/participate/policy/proposals/2022/ARIN_prop_308_v2/ > https://politicas.lacnic.net/politicas/detail/id/LAC-2022-2/language/en > _______________________________________________ > sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ > To unsubscribe send an email to sig-policy-leave@lists.apnic.net -- -- Satoru Tsurumaki BBIX, Inc _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.net _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.net_______________________________________________ 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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Hi Fernando,
So your argument is that banning leasing actually helps smaller companies in their quest for IPv4?
Are you aware that RIPE has allowed leasing for many years but is still a functioning RIR whose IPv4 sale prices are not more expensive despite the history of leasing there?
Can you reconcile that with your argument that leasing will raise prices for both leasing and transfers?
Are you aware that it’s not always possible to get IPv4 blocks from the company that is providing you with connectivity?
Regards, Mike
From: Fernando Frediani fhfrediani@gmail.com Sent: Wednesday, September 7, 2022 11:27 AM To: sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
This is exactly the opposite.
Allowing IP leasing to happen more than just tottaly divert the propose of IP assignments by RIRs it make it bad specially for smaller companies as it increases the cost for both leasing and transfers in long term. The cost of leasing is based on the transfer and if leasing is allowed then transfer prices will always go up which makes it even harder for smaller companies to go into the market.
Any form of IP leasing without a direct connection relationship to provide a connectivity service makes it more expensive for smaller companies to get IP addresses to operate.
Fernando
On 07/09/2022 11:15, Mike Burns wrote:
Hi Jordi,
It’s plain you feel that we should do all possible to raise the price of IPv4 and make it unattainable for small business in the vain hope that this will drive IPv6 adoption.
I don’t think making IPv4 more difficult to acquire is the job of the RIR system.
You have not addressed the inability of smaller companies to acquire necessary IPv4 blocks if you ban leasing.
Is that something you are comfortable with, in pursuit of the IPv6 grail?
It’s okay with you that this policy prevents small companies from growing?
Regards, Mike
From: JORDI PALET MARTINEZ via sig-policy mailto:sig-policy@lists.apnic.net sig-policy@lists.apnic.net Sent: Wednesday, September 7, 2022 10:11 AM To: sig-policy@lists.apnic.net mailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Actually, I must disagree …
If organizations having unused resources, they need to transfer them or return them to the RIR. If prices keep going high, that could encourage faster IPv6 adoption, then transfer prices will go down, up to “no value”. It takes time, but it is just market.
Those that have more money, have more facilities to do a faster transition and not bother about IPv4.
Regards,
Jordi
@jordipalet
El 7/9/22, 16:05, "Mike Burns" <mike@iptrading.com mailto:mike@iptrading.com > escribió:
Hello,
Per Gaurav’s statement that “only those with millions of dollars can think of getting ips”, this community should oppose this policy.
Because the only way small companies can afford to get ips today is by leasing them. The same way the small company can’t afford to purchase a big office building but instead rents an office. Leasing is the only way to finance IPv4 acquisitions today. No bank or other entity that I am aware of will do it. Purchasing addresses requires full upfront payment, but leasing allow for much smaller monthly payments.
If this community wants to ensure only the largest and richest companies can acquire new addresses, ban leasing.
But if the community tries to ban something with such a large business motivation behind it, it will find itself struggling against a powerful foe.
And for what purpose do we punish the small businesses? Leasing puts addresses in the hands of those who need them to build and operate networks. Isn’t that the primary goal of the RIR system?
Regards,
Mike
El 2/9/22, 9:23, "Gaurav Kansal" <gaurav.kansal@nic.in mailto:gaurav.kansal@nic.in > escribió:
Hello everyone,
In my opinion, even Trading of IPs (leave apart the lease for making dollars) in the name of transfers must be stopped.
If organisation doesn’t need IPs , then those must be returned back so that smaller organisations can get it from the RIR.
Currently, only the one which have millions of dollars can think of getting IPs. In today’s scenario, no one can start the Data Centre, ISP business without investing millions in IPs. Even education and research org doesn’t have an option to get IPs from RIR.
This is like horse trading and isn’t a good practice for the community as a whole.
Regards,
Gaurav Kansal
On 02-Sep-2022, at 12:20, rajesh@smartlinkindia.com mailto:rajesh@smartlinkindia.com wrote:
Dear Team,
As Mr. Satoru, mentioned there are changes, but if carefully implemented in phased manner, unauthorised leasing can be stopped.
For example in first phase, leasing among countries can be stopped, if the owner company doesn't provide any services beyond its home country. For example if a company in India doesn't have any operation in Singapore or Japan , can't lease resources to those companies in Singapore or Japan. This can be verified by taking business registration documents of both lease and lessor.
Once this is done same may be granularized at RIR level, where in country like India, leasing can be restricted to the licensed service area for service provider within their designated service area.
This may stop majority of issues, barring few exceptions.
Some more brainstorming is required for better understanding and precise implementation.
Regards,
Rajesh Panwala
For Smartlink Solutions Pvt Ltd
+91-9227886001
+91-9426110781
On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru <stsuruma@bbix.net mailto:stsuruma@bbix.net > wrote:
Dear Colleagues,
I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team..
I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals.
Many participants support the intent of the proposal but felt that implementation would be challenging.
(comment details) - It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses. - I think this proposal would be useful if the concept of leasing is accurately defined. - Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement.
Regards,
Satoru Tsurumaki / JPOPF Steering Team
2022年8月26日(金) 17:27 Shaila Sharmin <shaila.sharmin.ovi@gmail.com mailto:shaila.sharmin.ovi@gmail.com >:
Dear SIG members,
A new version of the proposal "prop-148-v002: Clarification - Leasing of Resources is not Acceptable" has been sent to the Policy SIG for review.
Information about earlier versions is available from:
http://www.apnic.net/policy/proposals/prop-148
You are encouraged to express your views on the proposal:
- Do you support or oppose the proposal?
- Is there anything in the proposal that is not clear?
- What changes could be made to this proposal to make it more effective?
Please find the text of the proposal below.
Regards, Bertrand, Shaila, and Ching-Heng APNIC Policy SIG Chairs
prop-148-v002: Clarification - 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 )
- Problem statement
RIRs have been conceived to manage, allocate and assign resources according to need, in such a 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 delegated by APNIC or an NIR, the justification of the need implies the need to use on their own infrastructure and/or network connectivity services provided directly to customers. As a result, any form of IP address leasing is unacceptable, 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.
APNIC may proactively investigate those cases and also initiate the investigation in case of reports by means of a form, email address or other means developed by APNIC.
If any form of leasing, regardless of when the delegation has been issued, is confirmed by an APNIC investigation, it will be considered a policy violation and revocation may apply against any account holders who are leasing or using them for any purposes not specified in the initial request.
- Advantages / Disadvantages
Advantages: Fulfilling the objective above indicated and making the policy clear.
Disadvantages: None.
- Impact on resource holders
None.
- 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 _______________________________________________ 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
IP Leasing is already banned in most RIRs and should stay as is.
But yes it does help as it doesn't push even further up IPv4 pricing and makes it easier for these small companies to get IPv4 via the proper and allowed way which are transfers. Other then diverting totally the propose o IPv4 Allocation, Leasing market contributes significantly to price increasing fueling the market with more demand for that type of very wrong thing.
RIPE is normally not a good example for certain policies which don't seem to have receptivity in discussions on all other RIRs.
There are still mechanisms that allow companies to get IP addressing either directly from the RIR, via Transfers which is a pretty common way or from the Upstream providers. People may not have got used yet to learn to live with less address and they may believe they need a bunch of address.
IP Leasing will never help small companies. The ones who really benefit from it are the IP broker companies who profit from them and also the resource holders which don't justify anymore to keep those addresses and are also profiting from something that should have been re-assigned directly to those who really need and justify for them in order to build Internet Infrastructure and Connectivity and instead are leasing a asset they don't own.
Fernando
On 07/09/2022 12:39, Mike Burns wrote:
Hi Fernando,
So your argument is that banning leasing actually helps smaller companies in their quest for IPv4?
Are you aware that RIPE has allowed leasing for many years but is still a functioning RIR whose IPv4 sale prices are not more expensive despite the history of leasing there?
Can you reconcile that with your argument that leasing will raise prices for both leasing and transfers?
Are you aware that it’s not always possible to get IPv4 blocks from the company that is providing you with connectivity?
Regards, Mike
*From:* Fernando Frediani fhfrediani@gmail.com *Sent:* Wednesday, September 7, 2022 11:27 AM *To:* sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
This is exactly the opposite.
Allowing IP leasing to happen more than just tottaly divert the propose of IP assignments by RIRs it make it bad specially for smaller companies as it increases the cost for both leasing and transfers in long term. The cost of leasing is based on the transfer and if leasing is allowed then transfer prices will always go up which makes it even harder for smaller companies to go into the market.
Any form of IP leasing without a direct connection relationship to provide a connectivity service makes it more expensive for smaller companies to get IP addresses to operate.
Fernando
On 07/09/2022 11:15, Mike Burns wrote:
Hi Jordi, It’s plain you feel that we should do all possible to raise the price of IPv4 and make it unattainable for small business in the vain hope that this will drive IPv6 adoption. I don’t think making IPv4 more difficult to acquire is the job of the RIR system. You have not addressed the inability of smaller companies to acquire necessary IPv4 blocks if you ban leasing. Is that something you are comfortable with, in pursuit of the IPv6 grail? It’s okay with you that this policy prevents small companies from growing? Regards, Mike *From:* JORDI PALET MARTINEZ via sig-policy <sig-policy@lists.apnic.net> <mailto:sig-policy@lists.apnic.net> *Sent:* Wednesday, September 7, 2022 10:11 AM *To:* sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable Actually, I must disagree … If organizations having unused resources, they need to transfer them or return them to the RIR. If prices keep going high, that could encourage faster IPv6 adoption, then transfer prices will go down, up to “no value”. It takes time, but it is just market. Those that have more money, have more facilities to do a faster transition and not bother about IPv4. Regards, Jordi @jordipalet El 7/9/22, 16:05, "Mike Burns" <mike@iptrading.com> escribió: Hello, Per Gaurav’s statement that “only those with millions of dollars can think of getting ips”, this community should oppose this policy. Because the only way small companies can afford to get ips today is by leasing them. The same way the small company can’t afford to purchase a big office building but instead rents an office. Leasing is the only way to finance IPv4 acquisitions today. No bank or other entity that I am aware of will do it. Purchasing addresses requires full upfront payment, but leasing allow for much smaller monthly payments. If this community wants to ensure only the largest and richest companies can acquire new addresses, ban leasing. But if the community tries to ban something with such a large business motivation behind it, it will find itself struggling against a powerful foe. And for what purpose do we punish the small businesses? Leasing puts addresses in the hands of those who need them to build and operate networks. Isn’t that the primary goal of the RIR system? Regards, Mike El 2/9/22, 9:23, "Gaurav Kansal" <gaurav.kansal@nic.in> escribió: Hello everyone, In my opinion, even Trading of IPs (leave apart the lease for making dollars) in the name of transfers must be stopped. If organisation doesn’t need IPs , then those must be returned back so that smaller organisations can get it from the RIR. Currently, only the one which have millions of dollars can think of getting IPs. In today’s scenario, no one can start the Data Centre, ISP business without investing millions in IPs. Even education and research org doesn’t have an option to get IPs from RIR. This is like horse trading and isn’t a good practice for the community as a whole. Regards, Gaurav Kansal On 02-Sep-2022, at 12:20, rajesh@smartlinkindia.com wrote: Dear Team, As Mr. Satoru, mentioned there are changes, but if carefully implemented in phased manner, unauthorised leasing can be stopped. For example in first phase, leasing among countries can be stopped, if the owner company doesn't provide any services beyond its home country. For example if a company in India doesn't have any operation in Singapore or Japan , can't lease resources to those companies in Singapore or Japan. This can be verified by taking business registration documents of both lease and lessor. Once this is done same may be granularized at RIR level, where in country like India, leasing can be restricted to the licensed service area for service provider within their designated service area. This may stop majority of issues, barring few exceptions. Some more brainstorming is required for better understanding and precise implementation. Regards, Rajesh Panwala For Smartlink Solutions Pvt Ltd +91-9227886001 +91-9426110781 On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru <stsuruma@bbix.net> wrote: Dear Colleagues, I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team.. I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals. Many participants support the intent of the proposal but felt that implementation would be challenging. (comment details) - It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses. - I think this proposal would be useful if the concept of leasing is accurately defined. - Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement. Regards, Satoru Tsurumaki / JPOPF Steering Team 2022年8月26日(金) 17:27 Shaila Sharmin <shaila.sharmin.ovi@gmail.com>: > > Dear SIG members, > > A new version of the proposal "prop-148-v002: Clarification - Leasing of > Resources is not Acceptable" has been sent to the Policy SIG for review. > > Information about earlier versions is available from: > > http://www.apnic.net/policy/proposals/prop-148 > > You are encouraged to express your views on the proposal: > > - Do you support or oppose the proposal? > - Is there anything in the proposal that is not clear? > - What changes could be made to this proposal to make it more effective? > > Please find the text of the proposal below. > > Regards, > Bertrand, Shaila, and Ching-Heng > APNIC Policy SIG Chairs > > > ---------------------------------------------------------------------- > prop-148-v002: Clarification - 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 a 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 delegated by APNIC or an NIR, > the justification of the need implies the need to use on their own > infrastructure and/or network connectivity services provided directly to > customers. As a result, any form of IP address leasing is unacceptable, > 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. > > APNIC may proactively investigate those cases and also initiate the > investigation in case of reports by means of a form, email address or > other means developed by APNIC. > > If any form of leasing, regardless of when the delegation has been > issued, is confirmed by an APNIC investigation, it will be considered a > policy violation and revocation may apply against any account holders > who are leasing or using them for any purposes not specified in the > initial request. > > > 5. Advantages / Disadvantages > ----------------------------- > Advantages: > Fulfilling the objective above indicated and making the policy clear. > > Disadvantages: > None. > > > 6. Impact on resource holders > ----------------------------- > None. > > > 7. References > ------------- > https://www.arin.net/participate/policy/proposals/2022/ARIN_prop_308_v2/ > https://politicas.lacnic.net/politicas/detail/id/LAC-2022-2/language/en > _______________________________________________ > sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ > To unsubscribe send an email to sig-policy-leave@lists.apnic.net -- -- Satoru Tsurumaki BBIX, Inc _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.net _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.net <https://amritmahotsav.nic.in/> _______________________________________________ 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. ********************************************** 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 tosig-policy-leave@lists.apnic.net
Hi Fernando,
Do you understand my argument that smaller business cannot afford the full upfront payment but can afford monthly lease payments?
Please address that simple argument by telling me how the small business benefits by not having the lease option, but only having the purchase option.
Regards, Mike
From: Fernando Frediani fhfrediani@gmail.com Sent: Wednesday, September 7, 2022 1:01 PM To: sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
IP Leasing is already banned in most RIRs and should stay as is.
But yes it does help as it doesn't push even further up IPv4 pricing and makes it easier for these small companies to get IPv4 via the proper and allowed way which are transfers. Other then diverting totally the propose o IPv4 Allocation, Leasing market contributes significantly to price increasing fueling the market with more demand for that type of very wrong thing.
RIPE is normally not a good example for certain policies which don't seem to have receptivity in discussions on all other RIRs.
There are still mechanisms that allow companies to get IP addressing either directly from the RIR, via Transfers which is a pretty common way or from the Upstream providers. People may not have got used yet to learn to live with less address and they may believe they need a bunch of address.
IP Leasing will never help small companies. The ones who really benefit from it are the IP broker companies who profit from them and also the resource holders which don't justify anymore to keep those addresses and are also profiting from something that should have been re-assigned directly to those who really need and justify for them in order to build Internet Infrastructure and Connectivity and instead are leasing a asset they don't own.
Fernando
On 07/09/2022 12:39, Mike Burns wrote:
Hi Fernando,
So your argument is that banning leasing actually helps smaller companies in their quest for IPv4?
Are you aware that RIPE has allowed leasing for many years but is still a functioning RIR whose IPv4 sale prices are not more expensive despite the history of leasing there?
Can you reconcile that with your argument that leasing will raise prices for both leasing and transfers?
Are you aware that it’s not always possible to get IPv4 blocks from the company that is providing you with connectivity?
Regards, Mike
From: Fernando Frediani mailto:fhfrediani@gmail.com fhfrediani@gmail.com Sent: Wednesday, September 7, 2022 11:27 AM To: sig-policy@lists.apnic.net mailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
This is exactly the opposite.
Allowing IP leasing to happen more than just tottaly divert the propose of IP assignments by RIRs it make it bad specially for smaller companies as it increases the cost for both leasing and transfers in long term. The cost of leasing is based on the transfer and if leasing is allowed then transfer prices will always go up which makes it even harder for smaller companies to go into the market.
Any form of IP leasing without a direct connection relationship to provide a connectivity service makes it more expensive for smaller companies to get IP addresses to operate.
Fernando
On 07/09/2022 11:15, Mike Burns wrote:
Hi Jordi,
It’s plain you feel that we should do all possible to raise the price of IPv4 and make it unattainable for small business in the vain hope that this will drive IPv6 adoption.
I don’t think making IPv4 more difficult to acquire is the job of the RIR system.
You have not addressed the inability of smaller companies to acquire necessary IPv4 blocks if you ban leasing.
Is that something you are comfortable with, in pursuit of the IPv6 grail?
It’s okay with you that this policy prevents small companies from growing?
Regards, Mike
From: JORDI PALET MARTINEZ via sig-policy mailto:sig-policy@lists.apnic.net sig-policy@lists.apnic.net Sent: Wednesday, September 7, 2022 10:11 AM To: sig-policy@lists.apnic.net mailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Actually, I must disagree …
If organizations having unused resources, they need to transfer them or return them to the RIR. If prices keep going high, that could encourage faster IPv6 adoption, then transfer prices will go down, up to “no value”. It takes time, but it is just market.
Those that have more money, have more facilities to do a faster transition and not bother about IPv4.
Regards,
Jordi
@jordipalet
El 7/9/22, 16:05, "Mike Burns" <mike@iptrading.com mailto:mike@iptrading.com > escribió:
Hello,
Per Gaurav’s statement that “only those with millions of dollars can think of getting ips”, this community should oppose this policy.
Because the only way small companies can afford to get ips today is by leasing them. The same way the small company can’t afford to purchase a big office building but instead rents an office. Leasing is the only way to finance IPv4 acquisitions today. No bank or other entity that I am aware of will do it. Purchasing addresses requires full upfront payment, but leasing allow for much smaller monthly payments.
If this community wants to ensure only the largest and richest companies can acquire new addresses, ban leasing.
But if the community tries to ban something with such a large business motivation behind it, it will find itself struggling against a powerful foe.
And for what purpose do we punish the small businesses? Leasing puts addresses in the hands of those who need them to build and operate networks. Isn’t that the primary goal of the RIR system?
Regards,
Mike
El 2/9/22, 9:23, "Gaurav Kansal" <gaurav.kansal@nic.in mailto:gaurav.kansal@nic.in > escribió:
Hello everyone,
In my opinion, even Trading of IPs (leave apart the lease for making dollars) in the name of transfers must be stopped.
If organisation doesn’t need IPs , then those must be returned back so that smaller organisations can get it from the RIR.
Currently, only the one which have millions of dollars can think of getting IPs. In today’s scenario, no one can start the Data Centre, ISP business without investing millions in IPs. Even education and research org doesn’t have an option to get IPs from RIR.
This is like horse trading and isn’t a good practice for the community as a whole.
Regards,
Gaurav Kansal
On 02-Sep-2022, at 12:20, rajesh@smartlinkindia.com mailto:rajesh@smartlinkindia.com wrote:
Dear Team,
As Mr. Satoru, mentioned there are changes, but if carefully implemented in phased manner, unauthorised leasing can be stopped.
For example in first phase, leasing among countries can be stopped, if the owner company doesn't provide any services beyond its home country. For example if a company in India doesn't have any operation in Singapore or Japan , can't lease resources to those companies in Singapore or Japan. This can be verified by taking business registration documents of both lease and lessor.
Once this is done same may be granularized at RIR level, where in country like India, leasing can be restricted to the licensed service area for service provider within their designated service area.
This may stop majority of issues, barring few exceptions.
Some more brainstorming is required for better understanding and precise implementation.
Regards,
Rajesh Panwala
For Smartlink Solutions Pvt Ltd
+91-9227886001
+91-9426110781
On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru <stsuruma@bbix.net mailto:stsuruma@bbix.net > wrote:
Dear Colleagues,
I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team..
I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals.
Many participants support the intent of the proposal but felt that implementation would be challenging.
(comment details) - It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses. - I think this proposal would be useful if the concept of leasing is accurately defined. - Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement.
Regards,
Satoru Tsurumaki / JPOPF Steering Team
2022年8月26日(金) 17:27 Shaila Sharmin <shaila.sharmin.ovi@gmail.com mailto:shaila.sharmin.ovi@gmail.com >:
Dear SIG members,
A new version of the proposal "prop-148-v002: Clarification - Leasing of Resources is not Acceptable" has been sent to the Policy SIG for review.
Information about earlier versions is available from:
http://www.apnic.net/policy/proposals/prop-148
You are encouraged to express your views on the proposal:
- Do you support or oppose the proposal?
- Is there anything in the proposal that is not clear?
- What changes could be made to this proposal to make it more effective?
Please find the text of the proposal below.
Regards, Bertrand, Shaila, and Ching-Heng APNIC Policy SIG Chairs
prop-148-v002: Clarification - 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 )
- Problem statement
RIRs have been conceived to manage, allocate and assign resources according to need, in such a 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 delegated by APNIC or an NIR, the justification of the need implies the need to use on their own infrastructure and/or network connectivity services provided directly to customers. As a result, any form of IP address leasing is unacceptable, 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.
APNIC may proactively investigate those cases and also initiate the investigation in case of reports by means of a form, email address or other means developed by APNIC.
If any form of leasing, regardless of when the delegation has been issued, is confirmed by an APNIC investigation, it will be considered a policy violation and revocation may apply against any account holders who are leasing or using them for any purposes not specified in the initial request.
- Advantages / Disadvantages
Advantages: Fulfilling the objective above indicated and making the policy clear.
Disadvantages: None.
- Impact on resource holders
None.
- 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 _______________________________________________ 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
Do you understand the argument that certain drugs can alleviate certain pains but they remain forbidden because they cause a major damage to society in long term and there are alternatives for people be able to still live without have to use those type of damageable mechanisms. Companies can also live without that and still have other legally allowed mechanisms.
This discussion is unnecessary for this policy discussion as what it proposes is to make something *already forbidden* clear in to the text, not to discuss if leasing should exist or not.
If anyone opposes it please take attention to provide arguments and suggestions on how to address the issues raised about what the proposal really proposes.
Regards Fernando
On 07/09/2022 14:12, Mike Burns wrote:
Hi Fernando,
Do you understand my argument that smaller business cannot afford the full upfront payment but can afford monthly lease payments?
Please address that simple argument by telling me how the small business benefits by not having the lease option, but only having the purchase option.
Regards, Mike
*From:* Fernando Frediani fhfrediani@gmail.com *Sent:* Wednesday, September 7, 2022 1:01 PM *To:* sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
IP Leasing is already banned in most RIRs and should stay as is.
But yes it does help as it doesn't push even further up IPv4 pricing and makes it easier for these small companies to get IPv4 via the proper and allowed way which are transfers. Other then diverting totally the propose o IPv4 Allocation, Leasing market contributes significantly to price increasing fueling the market with more demand for that type of very wrong thing.
RIPE is normally not a good example for certain policies which don't seem to have receptivity in discussions on all other RIRs.
There are still mechanisms that allow companies to get IP addressing either directly from the RIR, via Transfers which is a pretty common way or from the Upstream providers. People may not have got used yet to learn to live with less address and they may believe they need a bunch of address.
IP Leasing will never help small companies. The ones who really benefit from it are the IP broker companies who profit from them and also the resource holders which don't justify anymore to keep those addresses and are also profiting from something that should have been re-assigned directly to those who really need and justify for them in order to build Internet Infrastructure and Connectivity and instead are leasing a asset they don't own.
Fernando
On 07/09/2022 12:39, Mike Burns wrote:
Hi Fernando, So your argument is that banning leasing actually helps smaller companies in their quest for IPv4? Are you aware that RIPE has allowed leasing for many years but is still a functioning RIR whose IPv4 sale prices are not more expensive despite the history of leasing there? Can you reconcile that with your argument that leasing will raise prices for both leasing and transfers? Are you aware that it’s not always possible to get IPv4 blocks from the company that is providing you with connectivity? Regards, Mike *From:* Fernando Frediani <fhfrediani@gmail.com> <mailto:fhfrediani@gmail.com> *Sent:* Wednesday, September 7, 2022 11:27 AM *To:* sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable This is exactly the opposite. Allowing IP leasing to happen more than just tottaly divert the propose of IP assignments by RIRs it make it bad specially for smaller companies as it increases the cost for both leasing and transfers in long term. The cost of leasing is based on the transfer and if leasing is allowed then transfer prices will always go up which makes it even harder for smaller companies to go into the market. Any form of IP leasing without a direct connection relationship to provide a connectivity service makes it more expensive for smaller companies to get IP addresses to operate. Fernando On 07/09/2022 11:15, Mike Burns wrote: Hi Jordi, It’s plain you feel that we should do all possible to raise the price of IPv4 and make it unattainable for small business in the vain hope that this will drive IPv6 adoption. I don’t think making IPv4 more difficult to acquire is the job of the RIR system. You have not addressed the inability of smaller companies to acquire necessary IPv4 blocks if you ban leasing. Is that something you are comfortable with, in pursuit of the IPv6 grail? It’s okay with you that this policy prevents small companies from growing? Regards, Mike *From:* JORDI PALET MARTINEZ via sig-policy <sig-policy@lists.apnic.net> <mailto:sig-policy@lists.apnic.net> *Sent:* Wednesday, September 7, 2022 10:11 AM *To:* sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable Actually, I must disagree … If organizations having unused resources, they need to transfer them or return them to the RIR. If prices keep going high, that could encourage faster IPv6 adoption, then transfer prices will go down, up to “no value”. It takes time, but it is just market. Those that have more money, have more facilities to do a faster transition and not bother about IPv4. Regards, Jordi @jordipalet El 7/9/22, 16:05, "Mike Burns" <mike@iptrading.com> escribió: Hello, Per Gaurav’s statement that “only those with millions of dollars can think of getting ips”, this community should oppose this policy. Because the only way small companies can afford to get ips today is by leasing them. The same way the small company can’t afford to purchase a big office building but instead rents an office. Leasing is the only way to finance IPv4 acquisitions today. No bank or other entity that I am aware of will do it. Purchasing addresses requires full upfront payment, but leasing allow for much smaller monthly payments. If this community wants to ensure only the largest and richest companies can acquire new addresses, ban leasing. But if the community tries to ban something with such a large business motivation behind it, it will find itself struggling against a powerful foe. And for what purpose do we punish the small businesses? Leasing puts addresses in the hands of those who need them to build and operate networks. Isn’t that the primary goal of the RIR system? Regards, Mike El 2/9/22, 9:23, "Gaurav Kansal" <gaurav.kansal@nic.in> escribió: Hello everyone, In my opinion, even Trading of IPs (leave apart the lease for making dollars) in the name of transfers must be stopped. If organisation doesn’t need IPs , then those must be returned back so that smaller organisations can get it from the RIR. Currently, only the one which have millions of dollars can think of getting IPs. In today’s scenario, no one can start the Data Centre, ISP business without investing millions in IPs. Even education and research org doesn’t have an option to get IPs from RIR. This is like horse trading and isn’t a good practice for the community as a whole. Regards, Gaurav Kansal On 02-Sep-2022, at 12:20, rajesh@smartlinkindia.com wrote: Dear Team, As Mr. Satoru, mentioned there are changes, but if carefully implemented in phased manner, unauthorised leasing can be stopped. For example in first phase, leasing among countries can be stopped, if the owner company doesn't provide any services beyond its home country. For example if a company in India doesn't have any operation in Singapore or Japan , can't lease resources to those companies in Singapore or Japan. This can be verified by taking business registration documents of both lease and lessor. Once this is done same may be granularized at RIR level, where in country like India, leasing can be restricted to the licensed service area for service provider within their designated service area. This may stop majority of issues, barring few exceptions. Some more brainstorming is required for better understanding and precise implementation. Regards, Rajesh Panwala For Smartlink Solutions Pvt Ltd +91-9227886001 +91-9426110781 On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru <stsuruma@bbix.net> wrote: Dear Colleagues, I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team.. I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals. Many participants support the intent of the proposal but felt that implementation would be challenging. (comment details) - It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses. - I think this proposal would be useful if the concept of leasing is accurately defined. - Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement. Regards, Satoru Tsurumaki / JPOPF Steering Team 2022年8月26日(金) 17:27 Shaila Sharmin <shaila.sharmin.ovi@gmail.com>: > > Dear SIG members, > > A new version of the proposal "prop-148-v002: Clarification - Leasing of > Resources is not Acceptable" has been sent to the Policy SIG for review. > > Information about earlier versions is available from: > > http://www.apnic.net/policy/proposals/prop-148 > > You are encouraged to express your views on the proposal: > > - Do you support or oppose the proposal? > - Is there anything in the proposal that is not clear? > - What changes could be made to this proposal to make it more effective? > > Please find the text of the proposal below. > > Regards, > Bertrand, Shaila, and Ching-Heng > APNIC Policy SIG Chairs > > > ---------------------------------------------------------------------- > prop-148-v002: Clarification - 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 a 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 delegated by APNIC or an NIR, > the justification of the need implies the need to use on their own > infrastructure and/or network connectivity services provided directly to > customers. As a result, any form of IP address leasing is unacceptable, > 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. > > APNIC may proactively investigate those cases and also initiate the > investigation in case of reports by means of a form, email address or > other means developed by APNIC. > > If any form of leasing, regardless of when the delegation has been > issued, is confirmed by an APNIC investigation, it will be considered a > policy violation and revocation may apply against any account holders > who are leasing or using them for any purposes not specified in the > initial request. > > > 5. Advantages / Disadvantages > ----------------------------- > Advantages: > Fulfilling the objective above indicated and making the policy clear. > > Disadvantages: > None. > > > 6. Impact on resource holders > ----------------------------- > None. > > > 7. References > ------------- > https://www.arin.net/participate/policy/proposals/2022/ARIN_prop_308_v2/ > https://politicas.lacnic.net/politicas/detail/id/LAC-2022-2/language/en > _______________________________________________ > sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ > To unsubscribe send an email to sig-policy-leave@lists.apnic.net -- -- Satoru Tsurumaki BBIX, Inc _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.net _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.net <https://amritmahotsav.nic.in/> _______________________________________________ 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. ********************************************** 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 tosig-policy-leave@lists.apnic.net
My consistent contention is that:
(a) this policy does not need to exist. It is already adequately addressed by the current membership agreement (b) the policy attempts to overreach the stated aims of the policy, perhaps unintentionally. This is a bad consequence of poorly worded policies, and we should not permit this. (c) the policy will create additional confusion by attempting to introduce new language that even in the discussions playing out over the last 24 hours have shown differences in opinions on what various "terms" would mean (d) the real benefit of this policy has not been adequately quantified (e) it is not clear to me that it "makes anything clearer" at all.
In our opinion, this policy does not bring value to the internet community, and in my opinion should not be adopted. An alternate text is not required to be proposed as it should not be granted consensus and should not proceed.
If the authors of the policy feel strongly about this matter, I would willingly review a new policy that looks at the utilisation and return of unused resources; but that is not what this policy claims to be about.
This policy should not be approved by the SIG with consensus.
Kind regards, Andrew
On Thu, 8 Sept 2022 at 06:33, Fernando Frediani fhfrediani@gmail.com wrote:
Do you understand the argument that certain drugs can alleviate certain pains but they remain forbidden because they cause a major damage to society in long term and there are alternatives for people be able to still live without have to use those type of damageable mechanisms. Companies can also live without that and still have other legally allowed mechanisms.
This discussion is unnecessary for this policy discussion as what it proposes is to make something *already forbidden* clear in to the text, not to discuss if leasing should exist or not.
If anyone opposes it please take attention to provide arguments and suggestions on how to address the issues raised about what the proposal really proposes.
Regards Fernando On 07/09/2022 14:12, Mike Burns wrote:
Hi Fernando,
Do you understand my argument that smaller business cannot afford the full upfront payment but can afford monthly lease payments?
Please address that simple argument by telling me how the small business benefits by not having the lease option, but only having the purchase option.
Regards, Mike
*From:* Fernando Frediani fhfrediani@gmail.com fhfrediani@gmail.com *Sent:* Wednesday, September 7, 2022 1:01 PM *To:* sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
IP Leasing is already banned in most RIRs and should stay as is.
But yes it does help as it doesn't push even further up IPv4 pricing and makes it easier for these small companies to get IPv4 via the proper and allowed way which are transfers. Other then diverting totally the propose o IPv4 Allocation, Leasing market contributes significantly to price increasing fueling the market with more demand for that type of very wrong thing.
RIPE is normally not a good example for certain policies which don't seem to have receptivity in discussions on all other RIRs.
There are still mechanisms that allow companies to get IP addressing either directly from the RIR, via Transfers which is a pretty common way or from the Upstream providers. People may not have got used yet to learn to live with less address and they may believe they need a bunch of address.
IP Leasing will never help small companies. The ones who really benefit from it are the IP broker companies who profit from them and also the resource holders which don't justify anymore to keep those addresses and are also profiting from something that should have been re-assigned directly to those who really need and justify for them in order to build Internet Infrastructure and Connectivity and instead are leasing a asset they don't own.
Fernando
On 07/09/2022 12:39, Mike Burns wrote:
Hi Fernando,
So your argument is that banning leasing actually helps smaller companies in their quest for IPv4?
Are you aware that RIPE has allowed leasing for many years but is still a functioning RIR whose IPv4 sale prices are not more expensive despite the history of leasing there?
Can you reconcile that with your argument that leasing will raise prices for both leasing and transfers?
Are you aware that it’s not always possible to get IPv4 blocks from the company that is providing you with connectivity?
Regards, Mike
*From:* Fernando Frediani fhfrediani@gmail.com fhfrediani@gmail.com *Sent:* Wednesday, September 7, 2022 11:27 AM *To:* sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
This is exactly the opposite.
Allowing IP leasing to happen more than just tottaly divert the propose of IP assignments by RIRs it make it bad specially for smaller companies as it increases the cost for both leasing and transfers in long term. The cost of leasing is based on the transfer and if leasing is allowed then transfer prices will always go up which makes it even harder for smaller companies to go into the market.
Any form of IP leasing without a direct connection relationship to provide a connectivity service makes it more expensive for smaller companies to get IP addresses to operate.
Fernando
On 07/09/2022 11:15, Mike Burns wrote:
Hi Jordi,
It’s plain you feel that we should do all possible to raise the price of IPv4 and make it unattainable for small business in the vain hope that this will drive IPv6 adoption.
I don’t think making IPv4 more difficult to acquire is the job of the RIR system.
You have not addressed the inability of smaller companies to acquire necessary IPv4 blocks if you ban leasing.
Is that something you are comfortable with, in pursuit of the IPv6 grail?
It’s okay with you that this policy prevents small companies from growing?
Regards, Mike
*From:* JORDI PALET MARTINEZ via sig-policy sig-policy@lists.apnic.net sig-policy@lists.apnic.net *Sent:* Wednesday, September 7, 2022 10:11 AM *To:* sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Actually, I must disagree …
If organizations having unused resources, they need to transfer them or return them to the RIR. If prices keep going high, that could encourage faster IPv6 adoption, then transfer prices will go down, up to “no value”. It takes time, but it is just market.
Those that have more money, have more facilities to do a faster transition and not bother about IPv4.
Regards,
Jordi
@jordipalet
El 7/9/22, 16:05, "Mike Burns" mike@iptrading.com escribió:
Hello,
Per Gaurav’s statement that “only those with millions of dollars can think of getting ips”, this community should oppose this policy.
Because the only way small companies can afford to get ips today is by leasing them. The same way the small company can’t afford to purchase a big office building but instead rents an office. Leasing is the only way to finance IPv4 acquisitions today. No bank or other entity that I am aware of will do it. Purchasing addresses requires full upfront payment, but leasing allow for much smaller monthly payments.
If this community wants to ensure only the largest and richest companies can acquire new addresses, ban leasing.
But if the community tries to ban something with such a large business motivation behind it, it will find itself struggling against a powerful foe.
And for what purpose do we punish the small businesses? Leasing puts addresses in the hands of those who need them to build and operate networks. Isn’t that the primary goal of the RIR system?
Regards,
Mike
El 2/9/22, 9:23, "Gaurav Kansal" gaurav.kansal@nic.in escribió:
Hello everyone,
In my opinion, even Trading of IPs (leave apart the lease for making dollars) in the name of transfers must be stopped.
If organisation doesn’t need IPs , then those must be returned back so that smaller organisations can get it from the RIR.
Currently, only the one which have millions of dollars can think of getting IPs. In today’s scenario, no one can start the Data Centre, ISP business without investing millions in IPs. Even education and research org doesn’t have an option to get IPs from RIR.
This is like horse trading and isn’t a good practice for the community as a whole.
Regards,
Gaurav Kansal
On 02-Sep-2022, at 12:20, rajesh@smartlinkindia.com wrote:
Dear Team,
As Mr. Satoru, mentioned there are changes, but if carefully implemented in phased manner, unauthorised leasing can be stopped.
For example in first phase, leasing among countries can be stopped, if the owner company doesn't provide any services beyond its home country. For example if a company in India doesn't have any operation in Singapore or Japan , can't lease resources to those companies in Singapore or Japan. This can be verified by taking business registration documents of both lease and lessor.
Once this is done same may be granularized at RIR level, where in country like India, leasing can be restricted to the licensed service area for service provider within their designated service area.
This may stop majority of issues, barring few exceptions.
Some more brainstorming is required for better understanding and precise implementation.
Regards,
Rajesh Panwala
For Smartlink Solutions Pvt Ltd
+91-9227886001
+91-9426110781
On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru stsuruma@bbix.net wrote:
Dear Colleagues,
I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team..
I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals.
Many participants support the intent of the proposal but felt that implementation would be challenging.
(comment details)
- It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses.
- I think this proposal would be useful if the concept of leasing is
accurately defined.
- Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement.
Regards,
Satoru Tsurumaki / JPOPF Steering Team
2022年8月26日(金) 17:27 Shaila Sharmin shaila.sharmin.ovi@gmail.com:
Dear SIG members,
A new version of the proposal "prop-148-v002: Clarification - Leasing of Resources is not Acceptable" has been sent to the Policy SIG for review.
Information about earlier versions is available from:
http://www.apnic.net/policy/proposals/prop-148
You are encouraged to express your views on the proposal:
- Do you support or oppose the proposal?
- Is there anything in the proposal that is not clear?
- What changes could be made to this proposal to make it more
effective?
Please find the text of the proposal below.
Regards, Bertrand, Shaila, and Ching-Heng APNIC Policy SIG Chairs
prop-148-v002: Clarification - 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 a 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 delegated by APNIC or an NIR, the justification of the need implies the need to use on their own infrastructure and/or network connectivity services provided directly to customers. As a result, any form of IP address leasing is unacceptable, 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.
APNIC may proactively investigate those cases and also initiate the investigation in case of reports by means of a form, email address or other means developed by APNIC.
If any form of leasing, regardless of when the delegation has been issued, is confirmed by an APNIC investigation, it will be considered a policy violation and revocation may apply against any account holders who are leasing or using them for any purposes not specified in the initial request.
- Advantages / Disadvantages
Advantages: Fulfilling the objective above indicated and making the policy clear.
Disadvantages: None.
- Impact on resource holders
None.
- 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 _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.net
--
Satoru Tsurumaki BBIX, Inc _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.net
sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.net
_______________________________________________ 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.
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
sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.net
Hi Andrew,
If you think that “leasing is not allowed” is already in the current membership agreement, but at the same time you believe that there is lack of definition of leasing, how come then the membership agreement can be well interpreted?
As I already said, I believe leasing is a very clear english word and in english I don’t think there is a missinterpretation and the policy manual must be interpreted in english. Otherwise, we will need to define every term we use in the manual, which is a non-sense.
Despite that, I’ve watched at the recent webinar video (tks Sunny for the link!) and I believe we can improve the policy text, so no doubts remain.
I’ve already proposed it yesterday:
Leasing in this context must be interpreted as “Providing Internet Number Resources for a price (paid in any form) or even for free, when not tied to a direct connectivity service”.
I think this resolves the doubs of everyone or can we improve it?
This also match to what was Brett said in the webinar, if I got it correctly. We never understood leasing when there is connectivity service associated to it. It was clear since minute one in the proposal:
“As a result, any form of IP address leasing is unacceptable, nor does it justify the need, *if it is not part of a set of services based, at the very least, on direct connectivity*.”
When you provide connectivity, the addresses are part of that service, regardless if they are charged togheter or separated.
So once more, anyone believes this definition is not sufficient?
Leasing in this context must be interpreted as “Providing Internet Number Resources for a price (paid in any form) or even for free, when not tied to a direct connectivity service”.
Regards,
Jordi
@jordipalet
El 7/9/22, 22:40, "Andrew Yager" andrew@rwts.com.au escribió:
My consistent contention is that:
(a) this policy does not need to exist. It is already adequately addressed by the current membership agreement
(b) the policy attempts to overreach the stated aims of the policy, perhaps unintentionally. This is a bad consequence of poorly worded policies, and we should not permit this.
(c) the policy will create additional confusion by attempting to introduce new language that even in the discussions playing out over the last 24 hours have shown differences in opinions on what various "terms" would mean
(d) the real benefit of this policy has not been adequately quantified
(e) it is not clear to me that it "makes anything clearer" at all.
In our opinion, this policy does not bring value to the internet community, and in my opinion should not be adopted. An alternate text is not required to be proposed as it should not be granted consensus and should not proceed.
If the authors of the policy feel strongly about this matter, I would willingly review a new policy that looks at the utilisation and return of unused resources; but that is not what this policy claims to be about.
This policy should not be approved by the SIG with consensus.
Kind regards,
Andrew
On Thu, 8 Sept 2022 at 06:33, Fernando Frediani fhfrediani@gmail.com wrote:
Do you understand the argument that certain drugs can alleviate certain pains but they remain forbidden because they cause a major damage to society in long term and there are alternatives for people be able to still live without have to use those type of damageable mechanisms. Companies can also live without that and still have other legally allowed mechanisms.
This discussion is unnecessary for this policy discussion as what it proposes is to make something *already forbidden* clear in to the text, not to discuss if leasing should exist or not.
If anyone opposes it please take attention to provide arguments and suggestions on how to address the issues raised about what the proposal really proposes.
Regards Fernando
On 07/09/2022 14:12, Mike Burns wrote:
Hi Fernando,
Do you understand my argument that smaller business cannot afford the full upfront payment but can afford monthly lease payments?
Please address that simple argument by telling me how the small business benefits by not having the lease option, but only having the purchase option.
Regards, Mike
From: Fernando Frediani fhfrediani@gmail.com Sent: Wednesday, September 7, 2022 1:01 PM To: sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
IP Leasing is already banned in most RIRs and should stay as is.
But yes it does help as it doesn't push even further up IPv4 pricing and makes it easier for these small companies to get IPv4 via the proper and allowed way which are transfers. Other then diverting totally the propose o IPv4 Allocation, Leasing market contributes significantly to price increasing fueling the market with more demand for that type of very wrong thing.
RIPE is normally not a good example for certain policies which don't seem to have receptivity in discussions on all other RIRs.
There are still mechanisms that allow companies to get IP addressing either directly from the RIR, via Transfers which is a pretty common way or from the Upstream providers. People may not have got used yet to learn to live with less address and they may believe they need a bunch of address.
IP Leasing will never help small companies. The ones who really benefit from it are the IP broker companies who profit from them and also the resource holders which don't justify anymore to keep those addresses and are also profiting from something that should have been re-assigned directly to those who really need and justify for them in order to build Internet Infrastructure and Connectivity and instead are leasing a asset they don't own.
Fernando
On 07/09/2022 12:39, Mike Burns wrote:
Hi Fernando,
So your argument is that banning leasing actually helps smaller companies in their quest for IPv4?
Are you aware that RIPE has allowed leasing for many years but is still a functioning RIR whose IPv4 sale prices are not more expensive despite the history of leasing there?
Can you reconcile that with your argument that leasing will raise prices for both leasing and transfers?
Are you aware that it’s not always possible to get IPv4 blocks from the company that is providing you with connectivity?
Regards, Mike
From: Fernando Frediani fhfrediani@gmail.com Sent: Wednesday, September 7, 2022 11:27 AM To: sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
This is exactly the opposite.
Allowing IP leasing to happen more than just tottaly divert the propose of IP assignments by RIRs it make it bad specially for smaller companies as it increases the cost for both leasing and transfers in long term. The cost of leasing is based on the transfer and if leasing is allowed then transfer prices will always go up which makes it even harder for smaller companies to go into the market.
Any form of IP leasing without a direct connection relationship to provide a connectivity service makes it more expensive for smaller companies to get IP addresses to operate.
Fernando
On 07/09/2022 11:15, Mike Burns wrote:
Hi Jordi,
It’s plain you feel that we should do all possible to raise the price of IPv4 and make it unattainable for small business in the vain hope that this will drive IPv6 adoption.
I don’t think making IPv4 more difficult to acquire is the job of the RIR system.
You have not addressed the inability of smaller companies to acquire necessary IPv4 blocks if you ban leasing.
Is that something you are comfortable with, in pursuit of the IPv6 grail?
It’s okay with you that this policy prevents small companies from growing?
Regards, Mike
From: JORDI PALET MARTINEZ via sig-policy sig-policy@lists.apnic.net Sent: Wednesday, September 7, 2022 10:11 AM To: sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Actually, I must disagree …
If organizations having unused resources, they need to transfer them or return them to the RIR. If prices keep going high, that could encourage faster IPv6 adoption, then transfer prices will go down, up to “no value”. It takes time, but it is just market.
Those that have more money, have more facilities to do a faster transition and not bother about IPv4.
Regards,
Jordi
@jordipalet
El 7/9/22, 16:05, "Mike Burns" mike@iptrading.com escribió:
Hello,
Per Gaurav’s statement that “only those with millions of dollars can think of getting ips”, this community should oppose this policy.
Because the only way small companies can afford to get ips today is by leasing them. The same way the small company can’t afford to purchase a big office building but instead rents an office. Leasing is the only way to finance IPv4 acquisitions today. No bank or other entity that I am aware of will do it. Purchasing addresses requires full upfront payment, but leasing allow for much smaller monthly payments.
If this community wants to ensure only the largest and richest companies can acquire new addresses, ban leasing.
But if the community tries to ban something with such a large business motivation behind it, it will find itself struggling against a powerful foe.
And for what purpose do we punish the small businesses? Leasing puts addresses in the hands of those who need them to build and operate networks. Isn’t that the primary goal of the RIR system?
Regards,
Mike
El 2/9/22, 9:23, "Gaurav Kansal" gaurav.kansal@nic.in escribió:
Hello everyone,
In my opinion, even Trading of IPs (leave apart the lease for making dollars) in the name of transfers must be stopped.
If organisation doesn’t need IPs , then those must be returned back so that smaller organisations can get it from the RIR.
Currently, only the one which have millions of dollars can think of getting IPs. In today’s scenario, no one can start the Data Centre, ISP business without investing millions in IPs. Even education and research org doesn’t have an option to get IPs from RIR.
This is like horse trading and isn’t a good practice for the community as a whole.
Regards,
Gaurav Kansal
On 02-Sep-2022, at 12:20, rajesh@smartlinkindia.com wrote:
Dear Team,
As Mr. Satoru, mentioned there are changes, but if carefully implemented in phased manner, unauthorised leasing can be stopped.
For example in first phase, leasing among countries can be stopped, if the owner company doesn't provide any services beyond its home country. For example if a company in India doesn't have any operation in Singapore or Japan , can't lease resources to those companies in Singapore or Japan. This can be verified by taking business registration documents of both lease and lessor.
Once this is done same may be granularized at RIR level, where in country like India, leasing can be restricted to the licensed service area for service provider within their designated service area.
This may stop majority of issues, barring few exceptions.
Some more brainstorming is required for better understanding and precise implementation.
Regards,
Rajesh Panwala
For Smartlink Solutions Pvt Ltd
+91-9227886001
+91-9426110781
On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru stsuruma@bbix.net wrote:
Dear Colleagues,
I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team..
I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals.
Many participants support the intent of the proposal but felt that implementation would be challenging.
(comment details) - It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses. - I think this proposal would be useful if the concept of leasing is accurately defined. - Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement.
Regards,
Satoru Tsurumaki / JPOPF Steering Team
2022年8月26日(金) 17:27 Shaila Sharmin shaila.sharmin.ovi@gmail.com:
Dear SIG members,
A new version of the proposal "prop-148-v002: Clarification - Leasing of Resources is not Acceptable" has been sent to the Policy SIG for review.
Information about earlier versions is available from:
http://www.apnic.net/policy/proposals/prop-148
You are encouraged to express your views on the proposal:
- Do you support or oppose the proposal?
- Is there anything in the proposal that is not clear?
- What changes could be made to this proposal to make it more effective?
Please find the text of the proposal below.
Regards, Bertrand, Shaila, and Ching-Heng APNIC Policy SIG Chairs
prop-148-v002: Clarification - 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 a 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 delegated by APNIC or an NIR, the justification of the need implies the need to use on their own infrastructure and/or network connectivity services provided directly to customers. As a result, any form of IP address leasing is unacceptable, 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.
APNIC may proactively investigate those cases and also initiate the investigation in case of reports by means of a form, email address or other means developed by APNIC.
If any form of leasing, regardless of when the delegation has been issued, is confirmed by an APNIC investigation, it will be considered a policy violation and revocation may apply against any account holders who are leasing or using them for any purposes not specified in the initial request.
- Advantages / Disadvantages
Advantages: Fulfilling the objective above indicated and making the policy clear.
Disadvantages: None.
- Impact on resource holders
None.
- 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 _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.net
We’re going around in circles.
The membership agreement already provided the allowed use of resources. It’s clear about these.
Your proposed definition introduces new words like “direct connectivity” which also need to be defined.
And then there is an additional question on whether that is the correct definition and in the line of the communities understanding. To start with, what is direct? You’ve stated who announces them is irrelevant, but you are implying the measure of this by virtue of a connectivity announcement.
Again, I do not believe this proposal is necessary and do not believe it should be adopted. Merely restating the same points without ever addressing the concerns of need or practical objections from many has done nothing to sway me.
I do not believe this proposal should be granted consensus. If you submit a new version I’ll consider it then based on the new wording, but based on comments provided so far I do not see a likely scenario where any of the proposals you are suggesting change my position.
Andrew
Get Outlook for iOShttps://aka.ms/o0ukef ________________________________ From: JORDI PALET MARTINEZ via sig-policy sig-policy@lists.apnic.net Sent: Thursday, September 8, 2022 8:42:59 PM To: sig-policy@lists.apnic.net sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Hi Andrew,
If you think that “leasing is not allowed” is already in the current membership agreement, but at the same time you believe that there is lack of definition of leasing, how come then the membership agreement can be well interpreted?
As I already said, I believe leasing is a very clear english word and in english I don’t think there is a missinterpretation and the policy manual must be interpreted in english. Otherwise, we will need to define every term we use in the manual, which is a non-sense.
Despite that, I’ve watched at the recent webinar video (tks Sunny for the link!) and I believe we can improve the policy text, so no doubts remain.
I’ve already proposed it yesterday:
Leasing in this context must be interpreted as “Providing Internet Number Resources for a price (paid in any form) or even for free, when not tied to a direct connectivity service”.
I think this resolves the doubs of everyone or can we improve it?
This also match to what was Brett said in the webinar, if I got it correctly. We never understood leasing when there is connectivity service associated to it. It was clear since minute one in the proposal:
“As a result, any form of IP address leasing is unacceptable, nor does it justify the need, *if it is not part of a set of services based, at the very least, on direct connectivity*.”
When you provide connectivity, the addresses are part of that service, regardless if they are charged togheter or separated.
So once more, anyone believes this definition is not sufficient?
Leasing in this context must be interpreted as “Providing Internet Number Resources for a price (paid in any form) or even for free, when not tied to a direct connectivity service”.
Regards,
Jordi
@jordipalet
El 7/9/22, 22:40, "Andrew Yager" <andrew@rwts.com.aumailto:andrew@rwts.com.au> escribió:
My consistent contention is that:
(a) this policy does not need to exist. It is already adequately addressed by the current membership agreement
(b) the policy attempts to overreach the stated aims of the policy, perhaps unintentionally. This is a bad consequence of poorly worded policies, and we should not permit this.
(c) the policy will create additional confusion by attempting to introduce new language that even in the discussions playing out over the last 24 hours have shown differences in opinions on what various "terms" would mean
(d) the real benefit of this policy has not been adequately quantified
(e) it is not clear to me that it "makes anything clearer" at all.
In our opinion, this policy does not bring value to the internet community, and in my opinion should not be adopted. An alternate text is not required to be proposed as it should not be granted consensus and should not proceed.
If the authors of the policy feel strongly about this matter, I would willingly review a new policy that looks at the utilisation and return of unused resources; but that is not what this policy claims to be about.
This policy should not be approved by the SIG with consensus.
Kind regards,
Andrew
On Thu, 8 Sept 2022 at 06:33, Fernando Frediani <fhfrediani@gmail.commailto:fhfrediani@gmail.com> wrote:
Do you understand the argument that certain drugs can alleviate certain pains but they remain forbidden because they cause a major damage to society in long term and there are alternatives for people be able to still live without have to use those type of damageable mechanisms. Companies can also live without that and still have other legally allowed mechanisms.
This discussion is unnecessary for this policy discussion as what it proposes is to make something *already forbidden* clear in to the text, not to discuss if leasing should exist or not.
If anyone opposes it please take attention to provide arguments and suggestions on how to address the issues raised about what the proposal really proposes.
Regards Fernando
On 07/09/2022 14:12, Mike Burns wrote:
Hi Fernando,
Do you understand my argument that smaller business cannot afford the full upfront payment but can afford monthly lease payments?
Please address that simple argument by telling me how the small business benefits by not having the lease option, but only having the purchase option.
Regards, Mike
From: Fernando Frediani fhfrediani@gmail.commailto:fhfrediani@gmail.com Sent: Wednesday, September 7, 2022 1:01 PM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
IP Leasing is already banned in most RIRs and should stay as is.
But yes it does help as it doesn't push even further up IPv4 pricing and makes it easier for these small companies to get IPv4 via the proper and allowed way which are transfers. Other then diverting totally the propose o IPv4 Allocation, Leasing market contributes significantly to price increasing fueling the market with more demand for that type of very wrong thing.
RIPE is normally not a good example for certain policies which don't seem to have receptivity in discussions on all other RIRs.
There are still mechanisms that allow companies to get IP addressing either directly from the RIR, via Transfers which is a pretty common way or from the Upstream providers. People may not have got used yet to learn to live with less address and they may believe they need a bunch of address.
IP Leasing will never help small companies. The ones who really benefit from it are the IP broker companies who profit from them and also the resource holders which don't justify anymore to keep those addresses and are also profiting from something that should have been re-assigned directly to those who really need and justify for them in order to build Internet Infrastructure and Connectivity and instead are leasing a asset they don't own.
Fernando
On 07/09/2022 12:39, Mike Burns wrote:
Hi Fernando,
So your argument is that banning leasing actually helps smaller companies in their quest for IPv4?
Are you aware that RIPE has allowed leasing for many years but is still a functioning RIR whose IPv4 sale prices are not more expensive despite the history of leasing there?
Can you reconcile that with your argument that leasing will raise prices for both leasing and transfers?
Are you aware that it’s not always possible to get IPv4 blocks from the company that is providing you with connectivity?
Regards, Mike
From: Fernando Frediani fhfrediani@gmail.commailto:fhfrediani@gmail.com Sent: Wednesday, September 7, 2022 11:27 AM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
This is exactly the opposite.
Allowing IP leasing to happen more than just tottaly divert the propose of IP assignments by RIRs it make it bad specially for smaller companies as it increases the cost for both leasing and transfers in long term. The cost of leasing is based on the transfer and if leasing is allowed then transfer prices will always go up which makes it even harder for smaller companies to go into the market.
Any form of IP leasing without a direct connection relationship to provide a connectivity service makes it more expensive for smaller companies to get IP addresses to operate.
Fernando
On 07/09/2022 11:15, Mike Burns wrote:
Hi Jordi,
It’s plain you feel that we should do all possible to raise the price of IPv4 and make it unattainable for small business in the vain hope that this will drive IPv6 adoption.
I don’t think making IPv4 more difficult to acquire is the job of the RIR system.
You have not addressed the inability of smaller companies to acquire necessary IPv4 blocks if you ban leasing.
Is that something you are comfortable with, in pursuit of the IPv6 grail?
It’s okay with you that this policy prevents small companies from growing?
Regards, Mike
From: JORDI PALET MARTINEZ via sig-policy sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Sent: Wednesday, September 7, 2022 10:11 AM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Actually, I must disagree …
If organizations having unused resources, they need to transfer them or return them to the RIR. If prices keep going high, that could encourage faster IPv6 adoption, then transfer prices will go down, up to “no value”. It takes time, but it is just market.
Those that have more money, have more facilities to do a faster transition and not bother about IPv4.
Regards,
Jordi
@jordipalet
El 7/9/22, 16:05, "Mike Burns" <mike@iptrading.commailto:mike@iptrading.com> escribió:
Hello,
Per Gaurav’s statement that “only those with millions of dollars can think of getting ips”, this community should oppose this policy.
Because the only way small companies can afford to get ips today is by leasing them. The same way the small company can’t afford to purchase a big office building but instead rents an office. Leasing is the only way to finance IPv4 acquisitions today. No bank or other entity that I am aware of will do it. Purchasing addresses requires full upfront payment, but leasing allow for much smaller monthly payments.
If this community wants to ensure only the largest and richest companies can acquire new addresses, ban leasing.
But if the community tries to ban something with such a large business motivation behind it, it will find itself struggling against a powerful foe.
And for what purpose do we punish the small businesses? Leasing puts addresses in the hands of those who need them to build and operate networks. Isn’t that the primary goal of the RIR system?
Regards,
Mike
El 2/9/22, 9:23, "Gaurav Kansal" <gaurav.kansal@nic.inmailto:gaurav.kansal@nic.in> escribió:
Hello everyone,
In my opinion, even Trading of IPs (leave apart the lease for making dollars) in the name of transfers must be stopped.
If organisation doesn’t need IPs , then those must be returned back so that smaller organisations can get it from the RIR.
Currently, only the one which have millions of dollars can think of getting IPs. In today’s scenario, no one can start the Data Centre, ISP business without investing millions in IPs. Even education and research org doesn’t have an option to get IPs from RIR.
This is like horse trading and isn’t a good practice for the community as a whole.
Regards,
Gaurav Kansal
On 02-Sep-2022, at 12:20, rajesh@smartlinkindia.commailto:rajesh@smartlinkindia.com wrote:
Dear Team,
As Mr. Satoru, mentioned there are changes, but if carefully implemented in phased manner, unauthorised leasing can be stopped.
For example in first phase, leasing among countries can be stopped, if the owner company doesn't provide any services beyond its home country. For example if a company in India doesn't have any operation in Singapore or Japan , can't lease resources to those companies in Singapore or Japan. This can be verified by taking business registration documents of both lease and lessor.
Once this is done same may be granularized at RIR level, where in country like India, leasing can be restricted to the licensed service area for service provider within their designated service area.
This may stop majority of issues, barring few exceptions.
Some more brainstorming is required for better understanding and precise implementation.
Regards,
Rajesh Panwala
For Smartlink Solutions Pvt Ltd
+91-9227886001
+91-9426110781
On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru <stsuruma@bbix.netmailto:stsuruma@bbix.net> wrote:
Dear Colleagues,
I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team..
I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals.
Many participants support the intent of the proposal but felt that implementation would be challenging.
(comment details) - It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses. - I think this proposal would be useful if the concept of leasing is accurately defined. - Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement.
Regards,
Satoru Tsurumaki / JPOPF Steering Team
2022年8月26日(金) 17:27 Shaila Sharmin <shaila.sharmin.ovi@gmail.commailto:shaila.sharmin.ovi@gmail.com>:
Dear SIG members,
A new version of the proposal "prop-148-v002: Clarification - Leasing of Resources is not Acceptable" has been sent to the Policy SIG for review.
Information about earlier versions is available from:
http://www.apnic.net/policy/proposals/prop-148
You are encouraged to express your views on the proposal:
- Do you support or oppose the proposal?
- Is there anything in the proposal that is not clear?
- What changes could be made to this proposal to make it more effective?
Please find the text of the proposal below.
Regards, Bertrand, Shaila, and Ching-Heng APNIC Policy SIG Chairs
prop-148-v002: Clarification - Leasing of Resources is not Acceptable
Proposer: Jordi Palet Martinez (jordi.palet@theipv6company.comAnupammailto:jordi.palet@theipv6company.comAnupam) Amrita Choudhury (amritachoudhury@ccaoi.inmailto:amritachoudhury@ccaoi.in) Fernando Frediani (fhfredani@gmail.commailto:fhfredani@gmail.com)
- Problem statement
RIRs have been conceived to manage, allocate and assign resources according to need, in such a 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 delegated by APNIC or an NIR, the justification of the need implies the need to use on their own infrastructure and/or network connectivity services provided directly to customers. As a result, any form of IP address leasing is unacceptable, 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.
APNIC may proactively investigate those cases and also initiate the investigation in case of reports by means of a form, email address or other means developed by APNIC.
If any form of leasing, regardless of when the delegation has been issued, is confirmed by an APNIC investigation, it will be considered a policy violation and revocation may apply against any account holders who are leasing or using them for any purposes not specified in the initial request.
- Advantages / Disadvantages
Advantages: Fulfilling the objective above indicated and making the policy clear.
Disadvantages: None.
- Impact on resource holders
None.
- 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 _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.netmailto:sig-policy-leave@lists.apnic.net
-- -- Satoru Tsurumaki BBIX, Inc _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.netmailto:sig-policy-leave@lists.apnic.net
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Alas, Fernando, there is no alternative “drug” for people to live without IPv4.
Banning leasing hurts the smallest and poorest of companies most.
And you cannot elucidate any “major damages” suffered where leasing has actually, in reality, occurred for many years at RIPE.
Yet you use this evidence-free assertion as your major argument against leasing.
That some kind of serious damage will occur to the RIR system.
As a broker who as to talk to actual, real companies in need, who can’t afford to pay upfront, can you tell me what I should say when they ask me why leasing is forbidden? If I say it’s to avoid “major damages” and they ask what they are, can you tell me?
What major damages?
Regards, Mike
From: Fernando Frediani fhfrediani@gmail.com Sent: Wednesday, September 7, 2022 4:33 PM To: sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Do you understand the argument that certain drugs can alleviate certain pains but they remain forbidden because they cause a major damage to society in long term and there are alternatives for people be able to still live without have to use those type of damageable mechanisms. Companies can also live without that and still have other legally allowed mechanisms.
This discussion is unnecessary for this policy discussion as what it proposes is to make something *already forbidden* clear in to the text, not to discuss if leasing should exist or not.
If anyone opposes it please take attention to provide arguments and suggestions on how to address the issues raised about what the proposal really proposes.
Regards Fernando
On 07/09/2022 14:12, Mike Burns wrote:
Hi Fernando,
Do you understand my argument that smaller business cannot afford the full upfront payment but can afford monthly lease payments?
Please address that simple argument by telling me how the small business benefits by not having the lease option, but only having the purchase option.
Regards, Mike
From: Fernando Frediani mailto:fhfrediani@gmail.com fhfrediani@gmail.com Sent: Wednesday, September 7, 2022 1:01 PM To: sig-policy@lists.apnic.net mailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
IP Leasing is already banned in most RIRs and should stay as is.
But yes it does help as it doesn't push even further up IPv4 pricing and makes it easier for these small companies to get IPv4 via the proper and allowed way which are transfers. Other then diverting totally the propose o IPv4 Allocation, Leasing market contributes significantly to price increasing fueling the market with more demand for that type of very wrong thing.
RIPE is normally not a good example for certain policies which don't seem to have receptivity in discussions on all other RIRs.
There are still mechanisms that allow companies to get IP addressing either directly from the RIR, via Transfers which is a pretty common way or from the Upstream providers. People may not have got used yet to learn to live with less address and they may believe they need a bunch of address.
IP Leasing will never help small companies. The ones who really benefit from it are the IP broker companies who profit from them and also the resource holders which don't justify anymore to keep those addresses and are also profiting from something that should have been re-assigned directly to those who really need and justify for them in order to build Internet Infrastructure and Connectivity and instead are leasing a asset they don't own.
Fernando
On 07/09/2022 12:39, Mike Burns wrote:
Hi Fernando,
So your argument is that banning leasing actually helps smaller companies in their quest for IPv4?
Are you aware that RIPE has allowed leasing for many years but is still a functioning RIR whose IPv4 sale prices are not more expensive despite the history of leasing there?
Can you reconcile that with your argument that leasing will raise prices for both leasing and transfers?
Are you aware that it’s not always possible to get IPv4 blocks from the company that is providing you with connectivity?
Regards, Mike
From: Fernando Frediani mailto:fhfrediani@gmail.com fhfrediani@gmail.com Sent: Wednesday, September 7, 2022 11:27 AM To: sig-policy@lists.apnic.net mailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
This is exactly the opposite.
Allowing IP leasing to happen more than just tottaly divert the propose of IP assignments by RIRs it make it bad specially for smaller companies as it increases the cost for both leasing and transfers in long term. The cost of leasing is based on the transfer and if leasing is allowed then transfer prices will always go up which makes it even harder for smaller companies to go into the market.
Any form of IP leasing without a direct connection relationship to provide a connectivity service makes it more expensive for smaller companies to get IP addresses to operate.
Fernando
On 07/09/2022 11:15, Mike Burns wrote:
Hi Jordi,
It’s plain you feel that we should do all possible to raise the price of IPv4 and make it unattainable for small business in the vain hope that this will drive IPv6 adoption.
I don’t think making IPv4 more difficult to acquire is the job of the RIR system.
You have not addressed the inability of smaller companies to acquire necessary IPv4 blocks if you ban leasing.
Is that something you are comfortable with, in pursuit of the IPv6 grail?
It’s okay with you that this policy prevents small companies from growing?
Regards, Mike
From: JORDI PALET MARTINEZ via sig-policy mailto:sig-policy@lists.apnic.net sig-policy@lists.apnic.net Sent: Wednesday, September 7, 2022 10:11 AM To: sig-policy@lists.apnic.net mailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Actually, I must disagree …
If organizations having unused resources, they need to transfer them or return them to the RIR. If prices keep going high, that could encourage faster IPv6 adoption, then transfer prices will go down, up to “no value”. It takes time, but it is just market.
Those that have more money, have more facilities to do a faster transition and not bother about IPv4.
Regards,
Jordi
@jordipalet
El 7/9/22, 16:05, "Mike Burns" <mike@iptrading.com mailto:mike@iptrading.com > escribió:
Hello,
Per Gaurav’s statement that “only those with millions of dollars can think of getting ips”, this community should oppose this policy.
Because the only way small companies can afford to get ips today is by leasing them. The same way the small company can’t afford to purchase a big office building but instead rents an office. Leasing is the only way to finance IPv4 acquisitions today. No bank or other entity that I am aware of will do it. Purchasing addresses requires full upfront payment, but leasing allow for much smaller monthly payments.
If this community wants to ensure only the largest and richest companies can acquire new addresses, ban leasing.
But if the community tries to ban something with such a large business motivation behind it, it will find itself struggling against a powerful foe.
And for what purpose do we punish the small businesses? Leasing puts addresses in the hands of those who need them to build and operate networks. Isn’t that the primary goal of the RIR system?
Regards,
Mike
El 2/9/22, 9:23, "Gaurav Kansal" <gaurav.kansal@nic.in mailto:gaurav.kansal@nic.in > escribió:
Hello everyone,
In my opinion, even Trading of IPs (leave apart the lease for making dollars) in the name of transfers must be stopped.
If organisation doesn’t need IPs , then those must be returned back so that smaller organisations can get it from the RIR.
Currently, only the one which have millions of dollars can think of getting IPs. In today’s scenario, no one can start the Data Centre, ISP business without investing millions in IPs. Even education and research org doesn’t have an option to get IPs from RIR.
This is like horse trading and isn’t a good practice for the community as a whole.
Regards,
Gaurav Kansal
On 02-Sep-2022, at 12:20, rajesh@smartlinkindia.com mailto:rajesh@smartlinkindia.com wrote:
Dear Team,
As Mr. Satoru, mentioned there are changes, but if carefully implemented in phased manner, unauthorised leasing can be stopped.
For example in first phase, leasing among countries can be stopped, if the owner company doesn't provide any services beyond its home country. For example if a company in India doesn't have any operation in Singapore or Japan , can't lease resources to those companies in Singapore or Japan. This can be verified by taking business registration documents of both lease and lessor.
Once this is done same may be granularized at RIR level, where in country like India, leasing can be restricted to the licensed service area for service provider within their designated service area.
This may stop majority of issues, barring few exceptions.
Some more brainstorming is required for better understanding and precise implementation.
Regards,
Rajesh Panwala
For Smartlink Solutions Pvt Ltd
+91-9227886001
+91-9426110781
On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru <stsuruma@bbix.net mailto:stsuruma@bbix.net > wrote:
Dear Colleagues,
I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team..
I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals.
Many participants support the intent of the proposal but felt that implementation would be challenging.
(comment details) - It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses. - I think this proposal would be useful if the concept of leasing is accurately defined. - Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement.
Regards,
Satoru Tsurumaki / JPOPF Steering Team
2022年8月26日(金) 17:27 Shaila Sharmin <shaila.sharmin.ovi@gmail.com mailto:shaila.sharmin.ovi@gmail.com >:
Dear SIG members,
A new version of the proposal "prop-148-v002: Clarification - Leasing of Resources is not Acceptable" has been sent to the Policy SIG for review.
Information about earlier versions is available from:
http://www.apnic.net/policy/proposals/prop-148
You are encouraged to express your views on the proposal:
- Do you support or oppose the proposal?
- Is there anything in the proposal that is not clear?
- What changes could be made to this proposal to make it more effective?
Please find the text of the proposal below.
Regards, Bertrand, Shaila, and Ching-Heng APNIC Policy SIG Chairs
prop-148-v002: Clarification - 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 )
- Problem statement
RIRs have been conceived to manage, allocate and assign resources according to need, in such a 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 delegated by APNIC or an NIR, the justification of the need implies the need to use on their own infrastructure and/or network connectivity services provided directly to customers. As a result, any form of IP address leasing is unacceptable, 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.
APNIC may proactively investigate those cases and also initiate the investigation in case of reports by means of a form, email address or other means developed by APNIC.
If any form of leasing, regardless of when the delegation has been issued, is confirmed by an APNIC investigation, it will be considered a policy violation and revocation may apply against any account holders who are leasing or using them for any purposes not specified in the initial request.
- Advantages / Disadvantages
Advantages: Fulfilling the objective above indicated and making the policy clear.
Disadvantages: None.
- Impact on resource holders
None.
- 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 _______________________________________________ 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
Just wanted to chime in here and follow up on Mike's point (and those of several others).
What APNIC has done by its previous conduct is create a scarce asset collected in the hands of a number of large providers, with increasingly less being issued to small providers. As with any scarce asset in human history, this necessarily creates all the prerequisites for a fee market.
Just like real estate, vehicles and other commodities, leasing is a natural evolution of scarcity in an asset class with direct utility. Right now, IPv4 blocks are like houses - some own them, but some don't have the capital resources to outright own the amount they need. Simply looking at the prices which IPv4 blocks are going for on the open market will make it clear that many smaller businesses are priced out.
Leasing represents a viable option for companies to access the blocks they need and pay manageable, monthly or yearly payments for the use of those blocks. Many businesses are reliant on these currently.
Saying that APNIC will outright ban leasing and that this will somehow benefit businesses is abjectly false. Not only will it disrupt many current business operations, but there is no guarantee that a market with more perverse incentives won't emerge afterwards.
In our view, APNIC has already demonstrated by its statements and conduct with this policy that they have little grasp on how (and why) asset markets evolve. They've also done nothing to dissuade us that the new 'status quo' after this policy change won't be worse than the current one - which operates relatively fine.
Practically, for APNIC to say there will be no meaningful damage to current users and businesses (who are APNIC members in their own right) it must answer the following questions:
* What alternative does APNIC propose to the current IPv4 market and particularly, leasing options available to smaller companies and new entrants? * How will terminating leases currently on foot result in a better outcome for the businesses currently relying on them? * How will new IPv4 addresses be allocated, what timeframes and costs will be involved in this allocation? * Can APNIC give guarantees to current lessees who are reliant on IPv4 address leases that they can continue to access those addresses or will have replacements of similar value, at less cost, instantly after the change is made? * Is APNIC prepared to be held liable in lawsuits or a class action for the damages incurred by this policy change? Has it considered this risk and informed members accordingly?
It appears that those that will not be affected by this policy or those who already have large IPv4 blocks are some of the largest proponents of it - which makes sense. It is easy to vote for a change if it's only others that will be affected.
However, there are a large number of SME businesses out there who rely on these leases to run their operations. For them, this isn't just some merely intellectual exercise. Rather, it's a question of hundreds of thousands, or even millions, of dollars.
It's their ability to remain operational. It's their employees' livelihoods and those of their families. It's a core part of how they operate and for many, the foundation which they've built their business on.
This policy change seems to almost be a 'policy for policies sake'. It is clear that the repercussions of this were either not considered, or not even known, as the policy notes listed 'nil' negative effects. That this is the opinion of APNIC (and it seems, of a significant portion of the community) is incredibly concerning, because it couldn't be further from the truth.
Many real businesses will be affected by this, with real people. And the flippancy with which many within APNIC are treating this proposal shows a concerning lack of empathy towards that - and a failure to grasp the nature of IPv4 addresses as a modern asset class.
Without the above questions answered, I don't see how this policy vote can go ahead - and I would implore everyone considering this policy to reject it outright. There may be issues with the current IPv4 paradigm but this is definitely not the solution.
Kind Regards
Matt Shearing Chief Executive Officer [https://www.oneqode.com/img/email-pin.png] Brisbane, Australia (AEST) • matt@oneqode.commailto:matt@oneqode.com • +61 406 778 038 [OneQode™]https://www.oneqode.com/
[Follow us on LinkedIn]https://www.linkedin.com/company/oneqode/
From: Mike Burns mike@iptrading.com Sent: Thursday, 8 September 2022 6:52 AM To: 'Fernando Frediani' fhfrediani@gmail.com; sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Alas, Fernando, there is no alternative “drug” for people to live without IPv4. Banning leasing hurts the smallest and poorest of companies most.
And you cannot elucidate any “major damages” suffered where leasing has actually, in reality, occurred for many years at RIPE. Yet you use this evidence-free assertion as your major argument against leasing. That some kind of serious damage will occur to the RIR system.
As a broker who as to talk to actual, real companies in need, who can’t afford to pay upfront, can you tell me what I should say when they ask me why leasing is forbidden? If I say it’s to avoid “major damages” and they ask what they are, can you tell me?
What major damages?
Regards, Mike
From: Fernando Frediani <fhfrediani@gmail.commailto:fhfrediani@gmail.com> Sent: Wednesday, September 7, 2022 4:33 PM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Do you understand the argument that certain drugs can alleviate certain pains but they remain forbidden because they cause a major damage to society in long term and there are alternatives for people be able to still live without have to use those type of damageable mechanisms. Companies can also live without that and still have other legally allowed mechanisms.
This discussion is unnecessary for this policy discussion as what it proposes is to make something *already forbidden* clear in to the text, not to discuss if leasing should exist or not.
If anyone opposes it please take attention to provide arguments and suggestions on how to address the issues raised about what the proposal really proposes.
Regards Fernando On 07/09/2022 14:12, Mike Burns wrote: Hi Fernando,
Do you understand my argument that smaller business cannot afford the full upfront payment but can afford monthly lease payments?
Please address that simple argument by telling me how the small business benefits by not having the lease option, but only having the purchase option.
Regards, Mike
From: Fernando Frediani fhfrediani@gmail.commailto:fhfrediani@gmail.com Sent: Wednesday, September 7, 2022 1:01 PM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
IP Leasing is already banned in most RIRs and should stay as is.
But yes it does help as it doesn't push even further up IPv4 pricing and makes it easier for these small companies to get IPv4 via the proper and allowed way which are transfers. Other then diverting totally the propose o IPv4 Allocation, Leasing market contributes significantly to price increasing fueling the market with more demand for that type of very wrong thing.
RIPE is normally not a good example for certain policies which don't seem to have receptivity in discussions on all other RIRs.
There are still mechanisms that allow companies to get IP addressing either directly from the RIR, via Transfers which is a pretty common way or from the Upstream providers. People may not have got used yet to learn to live with less address and they may believe they need a bunch of address.
IP Leasing will never help small companies. The ones who really benefit from it are the IP broker companies who profit from them and also the resource holders which don't justify anymore to keep those addresses and are also profiting from something that should have been re-assigned directly to those who really need and justify for them in order to build Internet Infrastructure and Connectivity and instead are leasing a asset they don't own.
Fernando On 07/09/2022 12:39, Mike Burns wrote: Hi Fernando,
So your argument is that banning leasing actually helps smaller companies in their quest for IPv4?
Are you aware that RIPE has allowed leasing for many years but is still a functioning RIR whose IPv4 sale prices are not more expensive despite the history of leasing there?
Can you reconcile that with your argument that leasing will raise prices for both leasing and transfers?
Are you aware that it’s not always possible to get IPv4 blocks from the company that is providing you with connectivity?
Regards, Mike
From: Fernando Frediani fhfrediani@gmail.commailto:fhfrediani@gmail.com Sent: Wednesday, September 7, 2022 11:27 AM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
This is exactly the opposite.
Allowing IP leasing to happen more than just tottaly divert the propose of IP assignments by RIRs it make it bad specially for smaller companies as it increases the cost for both leasing and transfers in long term. The cost of leasing is based on the transfer and if leasing is allowed then transfer prices will always go up which makes it even harder for smaller companies to go into the market.
Any form of IP leasing without a direct connection relationship to provide a connectivity service makes it more expensive for smaller companies to get IP addresses to operate.
Fernando On 07/09/2022 11:15, Mike Burns wrote: Hi Jordi,
It’s plain you feel that we should do all possible to raise the price of IPv4 and make it unattainable for small business in the vain hope that this will drive IPv6 adoption.
I don’t think making IPv4 more difficult to acquire is the job of the RIR system.
You have not addressed the inability of smaller companies to acquire necessary IPv4 blocks if you ban leasing. Is that something you are comfortable with, in pursuit of the IPv6 grail? It’s okay with you that this policy prevents small companies from growing?
Regards, Mike
From: JORDI PALET MARTINEZ via sig-policy sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Sent: Wednesday, September 7, 2022 10:11 AM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Actually, I must disagree …
If organizations having unused resources, they need to transfer them or return them to the RIR. If prices keep going high, that could encourage faster IPv6 adoption, then transfer prices will go down, up to “no value”. It takes time, but it is just market.
Those that have more money, have more facilities to do a faster transition and not bother about IPv4.
Regards, Jordi @jordipalet
El 7/9/22, 16:05, "Mike Burns" <mike@iptrading.commailto:mike@iptrading.com> escribió:
Hello,
Per Gaurav’s statement that “only those with millions of dollars can think of getting ips”, this community should oppose this policy.
Because the only way small companies can afford to get ips today is by leasing them. The same way the small company can’t afford to purchase a big office building but instead rents an office. Leasing is the only way to finance IPv4 acquisitions today. No bank or other entity that I am aware of will do it. Purchasing addresses requires full upfront payment, but leasing allow for much smaller monthly payments.
If this community wants to ensure only the largest and richest companies can acquire new addresses, ban leasing.
But if the community tries to ban something with such a large business motivation behind it, it will find itself struggling against a powerful foe.
And for what purpose do we punish the small businesses? Leasing puts addresses in the hands of those who need them to build and operate networks. Isn’t that the primary goal of the RIR system?
Regards, Mike
El 2/9/22, 9:23, "Gaurav Kansal" <gaurav.kansal@nic.inmailto:gaurav.kansal@nic.in> escribió:
Hello everyone,
In my opinion, even Trading of IPs (leave apart the lease for making dollars) in the name of transfers must be stopped. If organisation doesn’t need IPs , then those must be returned back so that smaller organisations can get it from the RIR.
Currently, only the one which have millions of dollars can think of getting IPs. In today’s scenario, no one can start the Data Centre, ISP business without investing millions in IPs. Even education and research org doesn’t have an option to get IPs from RIR.
This is like horse trading and isn’t a good practice for the community as a whole.
Regards, Gaurav Kansal
On 02-Sep-2022, at 12:20, rajesh@smartlinkindia.commailto:rajesh@smartlinkindia.com wrote:
Dear Team,
As Mr. Satoru, mentioned there are changes, but if carefully implemented in phased manner, unauthorised leasing can be stopped.
For example in first phase, leasing among countries can be stopped, if the owner company doesn't provide any services beyond its home country. For example if a company in India doesn't have any operation in Singapore or Japan , can't lease resources to those companies in Singapore or Japan. This can be verified by taking business registration documents of both lease and lessor. Once this is done same may be granularized at RIR level, where in country like India, leasing can be restricted to the licensed service area for service provider within their designated service area. This may stop majority of issues, barring few exceptions. Some more brainstorming is required for better understanding and precise implementation.
Regards,
Rajesh Panwala For Smartlink Solutions Pvt Ltd +91-9227886001 +91-9426110781
On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru <stsuruma@bbix.netmailto:stsuruma@bbix.net> wrote: Dear Colleagues,
I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team..
I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals.
Many participants support the intent of the proposal but felt that implementation would be challenging.
(comment details) - It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses. - I think this proposal would be useful if the concept of leasing is accurately defined. - Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement.
Regards,
Satoru Tsurumaki / JPOPF Steering Team
2022年8月26日(金) 17:27 Shaila Sharmin <shaila.sharmin.ovi@gmail.commailto:shaila.sharmin.ovi@gmail.com>:
Dear SIG members,
A new version of the proposal "prop-148-v002: Clarification - Leasing of Resources is not Acceptable" has been sent to the Policy SIG for review.
Information about earlier versions is available from:
http://www.apnic.net/policy/proposals/prop-148
You are encouraged to express your views on the proposal:
- Do you support or oppose the proposal?
- Is there anything in the proposal that is not clear?
- What changes could be made to this proposal to make it more effective?
Please find the text of the proposal below.
Regards, Bertrand, Shaila, and Ching-Heng APNIC Policy SIG Chairs
prop-148-v002: Clarification - Leasing of Resources is not Acceptable
Proposer: Jordi Palet Martinez (jordi.palet@theipv6company.comAnupammailto:jordi.palet@theipv6company.comAnupam) Amrita Choudhury (amritachoudhury@ccaoi.inmailto:amritachoudhury@ccaoi.in) Fernando Frediani (fhfredani@gmail.commailto:fhfredani@gmail.com)
- Problem statement
RIRs have been conceived to manage, allocate and assign resources according to need, in such a 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 delegated by APNIC or an NIR, the justification of the need implies the need to use on their own infrastructure and/or network connectivity services provided directly to customers. As a result, any form of IP address leasing is unacceptable, 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.
APNIC may proactively investigate those cases and also initiate the investigation in case of reports by means of a form, email address or other means developed by APNIC.
If any form of leasing, regardless of when the delegation has been issued, is confirmed by an APNIC investigation, it will be considered a policy violation and revocation may apply against any account holders who are leasing or using them for any purposes not specified in the initial request.
- Advantages / Disadvantages
Advantages: Fulfilling the objective above indicated and making the policy clear.
Disadvantages: None.
- Impact on resource holders
None.
- 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 _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.netmailto:sig-policy-leave@lists.apnic.net
-- -- Satoru Tsurumaki BBIX, Inc _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.netmailto:sig-policy-leave@lists.apnic.net _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.netmailto:sig-policy-leave@lists.apnic.net
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Unfortunately this shows a tentative to discuss something with lack of enough important information about the topic and also there was not proper follow of most of this thread discussion.
First Internet Resources are not irrevocable assets that anyone who holds them can do whatever they like as if they own them. Unfortunately many people in this industry still don't know, but the fact that organizations hold a resource assigned to them does not mean they own it and therefore they must operate them under certain rules otherwise they risk to have them revoked, therefore they cannot be treated as an asset you purchased and may do whatever you like with it. If you purchase a server or a router it is yours and you sell or lease it for whatever amount you wish, but not with internet resources because you don't own them.
It is unimportant that anything APNIC may do against those who using IPv4 blocks illegally and may have them revoked because they should never have used in that way in first instance. A while back, when they became members they have signed a contract agreeing they would use the resources according to the rules. Therefore if someone decided to do out of what has been previously agreed they did it in their own risk and cannot allege they are "being affected".
Regardless how market evolves APNIC has full rights to revoke resources from members who are misusing resources not in accordance with the contracts they have signed and agreed. And by doing that APNIC is protecting community interests in detriment to individual and very specific interests that wants to use internet resources for proposes they were never conceived for.
Seems that people still didn't accept IPv4 exhaustion and keep hoping for something that will never come instead of learn once for all how to deal with it. There are ways to get blocks, for example via transfers and other specific methods, but the scenario many were used for decades doesn't exist anymore and still seems people keep trying to make up stuff to benefit their own specific interest in detriment of everybody else and of the fairness with everybody involved. If a company doesn't have enough money to afford a transfer I am sorry, but that is the new reality for a while. Learn how to deal with it and use other alternatives available like getting from upstreams - who provide connectivity - until there is budget to get address via a transfer for example. And not less important, stop hiding from IPv6 saying that will not revolve.
APNIC has all rights to fight in courts and is fully legally covered to enforce what members using internet resources signed and agreed for. Hardly judges will overwrite such agreement because they fell sorry that some people still didn't accept and learned to live with IPv4 exhaustion. No 'difficult' scenario gives the right to a member to void a contract they signed and agreed and win that in court.
These 'emotional arguments' of people and companies that will suffer if no leasing is allowed is a common argument from organizations who profit from IP leasing and don't build any internet connectivity and is already old one. If people keep insisting in doing things out of the rules sooner or later they will have to pay the price and they should know the risk before they even started.
IP addresses were not made to be rented from a resource holder who don't need them anymore to one that needs and could get them directly from the RIR. Regardless of the most noble reason, going against the rules doesn't make they valid.
Fernando
On 07/09/2022 22:49, Matthew Shearing wrote:
Just wanted to chime in here and follow up on Mike's point (and those of several others).
What APNIC has done by its previous conduct is create a scarce asset collected in the hands of a number of large providers, with increasingly less being issued to small providers. As with any scarce asset in human history, this necessarily creates all the prerequisites for a fee market.
Just like real estate, vehicles and other commodities, leasing is a natural evolution of scarcity in an asset class with direct utility. Right now, IPv4 blocks are like houses - some own them, but some don't have the capital resources to outright own the amount they need. Simply looking at the prices which IPv4 blocks are going for on the open market will make it clear that many smaller businesses are priced out.
Leasing represents a viable option for companies to access the blocks they need and pay manageable, monthly or yearly payments for the use of those blocks. Many businesses are reliant on these currently.
Saying that APNIC will outright ban leasing and that this will somehow benefit businesses is abjectly false. Not only will it disrupt many current business operations, but there is no guarantee that a market with more perverse incentives won't emerge afterwards.
In our view, APNIC has already demonstrated by its statements and conduct with this policy that they have little grasp on how (and why) asset markets evolve. They've also done nothing to dissuade us that the new 'status quo' after this policy change won't be worse than the current one - which operates relatively fine.
Practically, for APNIC to say there will be no meaningful damage to current users and businesses (who are APNIC members in their own right) it must answer the following questions:
- What alternative does APNIC propose to the current IPv4 market and particularly, leasing options available to smaller companies and new entrants?
- How will terminating leases currently on foot result in a better outcome for the businesses currently relying on them?
- How will new IPv4 addresses be allocated, what timeframes and costs will be involved in this allocation?
- Can APNIC give guarantees to current lessees who are reliant on IPv4 address leases that they can continue to access those addresses or will have replacements of similar value, at less cost, instantly after the change is made?
- Is APNIC prepared to be held liable in lawsuits or a class action for the damages incurred by this policy change? Has it considered this risk and informed members accordingly?
It appears that those that will not be affected by this policy or those who already have large IPv4 blocks are some of the largest proponents of it - which makes sense. It is easy to vote for a change if it's only others that will be affected.
However, there are a large number of SME businesses out there who rely on these leases to run their operations. For them, this isn't just some merely intellectual exercise. Rather, it's a question of hundreds of thousands, or even millions, of dollars.
It's their ability to remain operational. It's their employees' livelihoods and those of their families. It's a core part of how they operate and for many, the foundation which they've built their business on.
This policy change seems to almost be a /'policy for policies sake'/. It is clear that the repercussions of this were either not considered, or not even known, as the policy notes listed 'nil' negative effects. That this is the opinion of APNIC (and it seems, of a significant portion of the community) is incredibly concerning, because it couldn't be further from the truth.
Many real businesses will be affected by this, with real people. And the flippancy with which many within APNIC are treating this proposal shows a concerning lack of empathy towards that - and a failure to grasp the nature of IPv4 addresses as a modern asset class.
Without the above questions answered, I don't see how this policy vote can go ahead - and I would implore everyone considering this policy to reject it outright. There may be issues with the current IPv4 paradigm but this is definitely not the solution.
Kind Regards
*Matt Shearing* *Chief Executive Officer*
Brisbane, Australia (AEST) • matt@oneqode.com mailto:matt@oneqode.com • +61 406 778 038
OneQode™ https://www.oneqode.com/
Follow us on LinkedIn https://www.linkedin.com/company/oneqode/
*From:* Mike Burns mike@iptrading.com *Sent:* Thursday, 8 September 2022 6:52 AM *To:* 'Fernando Frediani' fhfrediani@gmail.com; sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Alas, Fernando, there is no alternative “drug” for people to live without IPv4.
Banning leasing hurts the smallest and poorest of companies most.
And you cannot elucidate any “major damages” suffered where leasing has actually, in reality, occurred for many years at RIPE.
Yet you use this evidence-free assertion as your major argument against leasing.
That some kind of serious damage will occur to the RIR system.
As a broker who as to talk to actual, real companies in need, who can’t afford to pay upfront, can you tell me what I should say when they ask me why leasing is forbidden? If I say it’s to avoid “major damages” and they ask what they are, can you tell me?
What major damages?
Regards, Mike
*From:* Fernando Frediani fhfrediani@gmail.com *Sent:* Wednesday, September 7, 2022 4:33 PM *To:* sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Do you understand the argument that certain drugs can alleviate certain pains but they remain forbidden because they cause a major damage to society in long term and there are alternatives for people be able to still live without have to use those type of damageable mechanisms. Companies can also live without that and still have other legally allowed mechanisms.
This discussion is unnecessary for this policy discussion as what it proposes is to make something *already forbidden* clear in to the text, not to discuss if leasing should exist or not.
If anyone opposes it please take attention to provide arguments and suggestions on how to address the issues raised about what the proposal really proposes.
Regards Fernando
On 07/09/2022 14:12, Mike Burns wrote:
Hi Fernando, Do you understand my argument that smaller business cannot afford the full upfront payment but can afford monthly lease payments? Please address that simple argument by telling me how the small business benefits by not having the lease option, but only having the purchase option. Regards, Mike *From:* Fernando Frediani <fhfrediani@gmail.com> <mailto:fhfrediani@gmail.com> *Sent:* Wednesday, September 7, 2022 1:01 PM *To:* sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable IP Leasing is already banned in most RIRs and should stay as is. But yes it does help as it doesn't push even further up IPv4 pricing and makes it easier for these small companies to get IPv4 via the proper and allowed way which are transfers. Other then diverting totally the propose o IPv4 Allocation, Leasing market contributes significantly to price increasing fueling the market with more demand for that type of very wrong thing. RIPE is normally not a good example for certain policies which don't seem to have receptivity in discussions on all other RIRs. There are still mechanisms that allow companies to get IP addressing either directly from the RIR, via Transfers which is a pretty common way or from the Upstream providers. People may not have got used yet to learn to live with less address and they may believe they need a bunch of address. IP Leasing will never help small companies. The ones who really benefit from it are the IP broker companies who profit from them and also the resource holders which don't justify anymore to keep those addresses and are also profiting from something that should have been re-assigned directly to those who really need and justify for them in order to build Internet Infrastructure and Connectivity and instead are leasing a asset they don't own. Fernando On 07/09/2022 12:39, Mike Burns wrote: Hi Fernando, So your argument is that banning leasing actually helps smaller companies in their quest for IPv4? Are you aware that RIPE has allowed leasing for many years but is still a functioning RIR whose IPv4 sale prices are not more expensive despite the history of leasing there? Can you reconcile that with your argument that leasing will raise prices for both leasing and transfers? Are you aware that it’s not always possible to get IPv4 blocks from the company that is providing you with connectivity? Regards, Mike *From:* Fernando Frediani <fhfrediani@gmail.com> <mailto:fhfrediani@gmail.com> *Sent:* Wednesday, September 7, 2022 11:27 AM *To:* sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable This is exactly the opposite. Allowing IP leasing to happen more than just tottaly divert the propose of IP assignments by RIRs it make it bad specially for smaller companies as it increases the cost for both leasing and transfers in long term. The cost of leasing is based on the transfer and if leasing is allowed then transfer prices will always go up which makes it even harder for smaller companies to go into the market. Any form of IP leasing without a direct connection relationship to provide a connectivity service makes it more expensive for smaller companies to get IP addresses to operate. Fernando On 07/09/2022 11:15, Mike Burns wrote: Hi Jordi, It’s plain you feel that we should do all possible to raise the price of IPv4 and make it unattainable for small business in the vain hope that this will drive IPv6 adoption. I don’t think making IPv4 more difficult to acquire is the job of the RIR system. You have not addressed the inability of smaller companies to acquire necessary IPv4 blocks if you ban leasing. Is that something you are comfortable with, in pursuit of the IPv6 grail? It’s okay with you that this policy prevents small companies from growing? Regards, Mike *From:* JORDI PALET MARTINEZ via sig-policy <sig-policy@lists.apnic.net> <mailto:sig-policy@lists.apnic.net> *Sent:* Wednesday, September 7, 2022 10:11 AM *To:* sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable Actually, I must disagree … If organizations having unused resources, they need to transfer them or return them to the RIR. If prices keep going high, that could encourage faster IPv6 adoption, then transfer prices will go down, up to “no value”. It takes time, but it is just market. Those that have more money, have more facilities to do a faster transition and not bother about IPv4. Regards, Jordi @jordipalet El 7/9/22, 16:05, "Mike Burns" <mike@iptrading.com> escribió: Hello, Per Gaurav’s statement that “only those with millions of dollars can think of getting ips”, this community should oppose this policy. Because the only way small companies can afford to get ips today is by leasing them. The same way the small company can’t afford to purchase a big office building but instead rents an office. Leasing is the only way to finance IPv4 acquisitions today. No bank or other entity that I am aware of will do it. Purchasing addresses requires full upfront payment, but leasing allow for much smaller monthly payments. If this community wants to ensure only the largest and richest companies can acquire new addresses, ban leasing. But if the community tries to ban something with such a large business motivation behind it, it will find itself struggling against a powerful foe. And for what purpose do we punish the small businesses? Leasing puts addresses in the hands of those who need them to build and operate networks. Isn’t that the primary goal of the RIR system? Regards, Mike El 2/9/22, 9:23, "Gaurav Kansal" <gaurav.kansal@nic.in> escribió: Hello everyone, In my opinion, even Trading of IPs (leave apart the lease for making dollars) in the name of transfers must be stopped. If organisation doesn’t need IPs , then those must be returned back so that smaller organisations can get it from the RIR. Currently, only the one which have millions of dollars can think of getting IPs. In today’s scenario, no one can start the Data Centre, ISP business without investing millions in IPs. Even education and research org doesn’t have an option to get IPs from RIR. This is like horse trading and isn’t a good practice for the community as a whole. Regards, Gaurav Kansal On 02-Sep-2022, at 12:20, rajesh@smartlinkindia.com wrote: Dear Team, As Mr. Satoru, mentioned there are changes, but if carefully implemented in phased manner, unauthorised leasing can be stopped. For example in first phase, leasing among countries can be stopped, if the owner company doesn't provide any services beyond its home country. For example if a company in India doesn't have any operation in Singapore or Japan , can't lease resources to those companies in Singapore or Japan. This can be verified by taking business registration documents of both lease and lessor. Once this is done same may be granularized at RIR level, where in country like India, leasing can be restricted to the licensed service area for service provider within their designated service area. This may stop majority of issues, barring few exceptions. Some more brainstorming is required for better understanding and precise implementation. Regards, Rajesh Panwala For Smartlink Solutions Pvt Ltd +91-9227886001 +91-9426110781 On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru <stsuruma@bbix.net> wrote: Dear Colleagues, I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team.. I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals. Many participants support the intent of the proposal but felt that implementation would be challenging. (comment details) - It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses. - I think this proposal would be useful if the concept of leasing is accurately defined. - Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement. Regards, Satoru Tsurumaki / JPOPF Steering Team 2022年8月26日(金) 17:27 Shaila Sharmin <shaila.sharmin.ovi@gmail.com>: > > Dear SIG members, > > A new version of the proposal "prop-148-v002: Clarification - Leasing of > Resources is not Acceptable" has been sent to the Policy SIG for review. > > Information about earlier versions is available from: > > http://www.apnic.net/policy/proposals/prop-148 > > You are encouraged to express your views on the proposal: > > - Do you support or oppose the proposal? > - Is there anything in the proposal that is not clear? > - What changes could be made to this proposal to make it more effective? > > Please find the text of the proposal below. > > Regards, > Bertrand, Shaila, and Ching-Heng > APNIC Policy SIG Chairs > > > ---------------------------------------------------------------------- > prop-148-v002: Clarification - 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 a 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 delegated by APNIC or an NIR, > the justification of the need implies the need to use on their own > infrastructure and/or network connectivity services provided directly to > customers. As a result, any form of IP address leasing is unacceptable, > 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. > > APNIC may proactively investigate those cases and also initiate the > investigation in case of reports by means of a form, email address or > other means developed by APNIC. > > If any form of leasing, regardless of when the delegation has been > issued, is confirmed by an APNIC investigation, it will be considered a > policy violation and revocation may apply against any account holders > who are leasing or using them for any purposes not specified in the > initial request. > > > 5. Advantages / Disadvantages > ----------------------------- > Advantages: > Fulfilling the objective above indicated and making the policy clear. > > Disadvantages: > None. > > > 6. Impact on resource holders > ----------------------------- > None. > > > 7. References > ------------- > https://www.arin.net/participate/policy/proposals/2022/ARIN_prop_308_v2/ > https://politicas.lacnic.net/politicas/detail/id/LAC-2022-2/language/en > _______________________________________________ > sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ > To unsubscribe send an email to sig-policy-leave@lists.apnic.net -- -- Satoru Tsurumaki BBIX, Inc _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.net _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.net <https://amritmahotsav.nic.in/> _______________________________________________ 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. ********************************************** 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 tosig-policy-leave@lists.apnic.net
IP addresses were made to allow devices to communicate with each other. They are a technical construct.
The processes the internet community built to allow the distribution and management of these is an interesting question.
But regardless - this policy, in its current form, if it is only to clarify the existing member agreement, is not necessary. Leasing, as acknowledged by you, is already prohibited. While I agree with Mike and others observations about the impact on small providers - it doesn’t change today what the APNIC member agreement says.
The point is - if this policy is not seeking to do anything new (which you have said) - this policy has no need to exist.
If this policy is seeking to clarify the existing member agreement, that’s fine - but it should then clarify it by actually defining all the terms.
And in fact, leasing is permitted in some situations today.
This policy is only going to confuse this further.
I do not think this policy has merit as it stands and do not believe it provides any value to the APNIC region. Other, alternate policies designed to specifically address particular, well defined behaviours - where these is material evidence that the current framework is ineffective at addressing may have merit. But as noted, there is no quantified description of the problem this seeks to solve; and no evidence has been provided to date that this policy actually has a need to be addressed.
Certainly, if there is some - now is the time to provide the details.
Andrew
Get Outlook for iOShttps://aka.ms/o0ukef ________________________________ From: Fernando Frediani fhfrediani@gmail.com Sent: Thursday, September 8, 2022 12:14:42 PM To: sig-policy@lists.apnic.net sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Unfortunately this shows a tentative to discuss something with lack of enough important information about the topic and also there was not proper follow of most of this thread discussion.
First Internet Resources are not irrevocable assets that anyone who holds them can do whatever they like as if they own them. Unfortunately many people in this industry still don't know, but the fact that organizations hold a resource assigned to them does not mean they own it and therefore they must operate them under certain rules otherwise they risk to have them revoked, therefore they cannot be treated as an asset you purchased and may do whatever you like with it. If you purchase a server or a router it is yours and you sell or lease it for whatever amount you wish, but not with internet resources because you don't own them.
It is unimportant that anything APNIC may do against those who using IPv4 blocks illegally and may have them revoked because they should never have used in that way in first instance. A while back, when they became members they have signed a contract agreeing they would use the resources according to the rules. Therefore if someone decided to do out of what has been previously agreed they did it in their own risk and cannot allege they are "being affected".
Regardless how market evolves APNIC has full rights to revoke resources from members who are misusing resources not in accordance with the contracts they have signed and agreed. And by doing that APNIC is protecting community interests in detriment to individual and very specific interests that wants to use internet resources for proposes they were never conceived for.
Seems that people still didn't accept IPv4 exhaustion and keep hoping for something that will never come instead of learn once for all how to deal with it. There are ways to get blocks, for example via transfers and other specific methods, but the scenario many were used for decades doesn't exist anymore and still seems people keep trying to make up stuff to benefit their own specific interest in detriment of everybody else and of the fairness with everybody involved. If a company doesn't have enough money to afford a transfer I am sorry, but that is the new reality for a while. Learn how to deal with it and use other alternatives available like getting from upstreams - who provide connectivity - until there is budget to get address via a transfer for example. And not less important, stop hiding from IPv6 saying that will not revolve.
APNIC has all rights to fight in courts and is fully legally covered to enforce what members using internet resources signed and agreed for. Hardly judges will overwrite such agreement because they fell sorry that some people still didn't accept and learned to live with IPv4 exhaustion. No 'difficult' scenario gives the right to a member to void a contract they signed and agreed and win that in court.
These 'emotional arguments' of people and companies that will suffer if no leasing is allowed is a common argument from organizations who profit from IP leasing and don't build any internet connectivity and is already old one. If people keep insisting in doing things out of the rules sooner or later they will have to pay the price and they should know the risk before they even started.
IP addresses were not made to be rented from a resource holder who don't need them anymore to one that needs and could get them directly from the RIR. Regardless of the most noble reason, going against the rules doesn't make they valid.
Fernando
On 07/09/2022 22:49, Matthew Shearing wrote:
Just wanted to chime in here and follow up on Mike's point (and those of several others).
What APNIC has done by its previous conduct is create a scarce asset collected in the hands of a number of large providers, with increasingly less being issued to small providers. As with any scarce asset in human history, this necessarily creates all the prerequisites for a fee market.
Just like real estate, vehicles and other commodities, leasing is a natural evolution of scarcity in an asset class with direct utility. Right now, IPv4 blocks are like houses - some own them, but some don't have the capital resources to outright own the amount they need. Simply looking at the prices which IPv4 blocks are going for on the open market will make it clear that many smaller businesses are priced out.
Leasing represents a viable option for companies to access the blocks they need and pay manageable, monthly or yearly payments for the use of those blocks. Many businesses are reliant on these currently.
Saying that APNIC will outright ban leasing and that this will somehow benefit businesses is abjectly false. Not only will it disrupt many current business operations, but there is no guarantee that a market with more perverse incentives won't emerge afterwards.
In our view, APNIC has already demonstrated by its statements and conduct with this policy that they have little grasp on how (and why) asset markets evolve. They've also done nothing to dissuade us that the new 'status quo' after this policy change won't be worse than the current one - which operates relatively fine.
Practically, for APNIC to say there will be no meaningful damage to current users and businesses (who are APNIC members in their own right) it must answer the following questions:
* What alternative does APNIC propose to the current IPv4 market and particularly, leasing options available to smaller companies and new entrants? * How will terminating leases currently on foot result in a better outcome for the businesses currently relying on them? * How will new IPv4 addresses be allocated, what timeframes and costs will be involved in this allocation? * Can APNIC give guarantees to current lessees who are reliant on IPv4 address leases that they can continue to access those addresses or will have replacements of similar value, at less cost, instantly after the change is made? * Is APNIC prepared to be held liable in lawsuits or a class action for the damages incurred by this policy change? Has it considered this risk and informed members accordingly?
It appears that those that will not be affected by this policy or those who already have large IPv4 blocks are some of the largest proponents of it - which makes sense. It is easy to vote for a change if it's only others that will be affected.
However, there are a large number of SME businesses out there who rely on these leases to run their operations. For them, this isn't just some merely intellectual exercise. Rather, it's a question of hundreds of thousands, or even millions, of dollars.
It's their ability to remain operational. It's their employees' livelihoods and those of their families. It's a core part of how they operate and for many, the foundation which they've built their business on.
This policy change seems to almost be a 'policy for policies sake'. It is clear that the repercussions of this were either not considered, or not even known, as the policy notes listed 'nil' negative effects. That this is the opinion of APNIC (and it seems, of a significant portion of the community) is incredibly concerning, because it couldn't be further from the truth.
Many real businesses will be affected by this, with real people. And the flippancy with which many within APNIC are treating this proposal shows a concerning lack of empathy towards that - and a failure to grasp the nature of IPv4 addresses as a modern asset class.
Without the above questions answered, I don't see how this policy vote can go ahead - and I would implore everyone considering this policy to reject it outright. There may be issues with the current IPv4 paradigm but this is definitely not the solution.
Kind Regards
Matt Shearing Chief Executive Officer
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From: Mike Burns mike@iptrading.commailto:mike@iptrading.com Sent: Thursday, 8 September 2022 6:52 AM To: 'Fernando Frediani' fhfrediani@gmail.commailto:fhfrediani@gmail.com; sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Alas, Fernando, there is no alternative “drug” for people to live without IPv4.
Banning leasing hurts the smallest and poorest of companies most.
And you cannot elucidate any “major damages” suffered where leasing has actually, in reality, occurred for many years at RIPE.
Yet you use this evidence-free assertion as your major argument against leasing.
That some kind of serious damage will occur to the RIR system.
As a broker who as to talk to actual, real companies in need, who can’t afford to pay upfront, can you tell me what I should say when they ask me why leasing is forbidden? If I say it’s to avoid “major damages” and they ask what they are, can you tell me?
What major damages?
Regards, Mike
From: Fernando Frediani <fhfrediani@gmail.commailto:fhfrediani@gmail.com> Sent: Wednesday, September 7, 2022 4:33 PM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Do you understand the argument that certain drugs can alleviate certain pains but they remain forbidden because they cause a major damage to society in long term and there are alternatives for people be able to still live without have to use those type of damageable mechanisms. Companies can also live without that and still have other legally allowed mechanisms.
This discussion is unnecessary for this policy discussion as what it proposes is to make something *already forbidden* clear in to the text, not to discuss if leasing should exist or not.
If anyone opposes it please take attention to provide arguments and suggestions on how to address the issues raised about what the proposal really proposes.
Regards Fernando
On 07/09/2022 14:12, Mike Burns wrote:
Hi Fernando,
Do you understand my argument that smaller business cannot afford the full upfront payment but can afford monthly lease payments?
Please address that simple argument by telling me how the small business benefits by not having the lease option, but only having the purchase option.
Regards, Mike
From: Fernando Frediani fhfrediani@gmail.commailto:fhfrediani@gmail.com Sent: Wednesday, September 7, 2022 1:01 PM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
IP Leasing is already banned in most RIRs and should stay as is.
But yes it does help as it doesn't push even further up IPv4 pricing and makes it easier for these small companies to get IPv4 via the proper and allowed way which are transfers. Other then diverting totally the propose o IPv4 Allocation, Leasing market contributes significantly to price increasing fueling the market with more demand for that type of very wrong thing.
RIPE is normally not a good example for certain policies which don't seem to have receptivity in discussions on all other RIRs.
There are still mechanisms that allow companies to get IP addressing either directly from the RIR, via Transfers which is a pretty common way or from the Upstream providers. People may not have got used yet to learn to live with less address and they may believe they need a bunch of address.
IP Leasing will never help small companies. The ones who really benefit from it are the IP broker companies who profit from them and also the resource holders which don't justify anymore to keep those addresses and are also profiting from something that should have been re-assigned directly to those who really need and justify for them in order to build Internet Infrastructure and Connectivity and instead are leasing a asset they don't own.
Fernando
On 07/09/2022 12:39, Mike Burns wrote:
Hi Fernando,
So your argument is that banning leasing actually helps smaller companies in their quest for IPv4?
Are you aware that RIPE has allowed leasing for many years but is still a functioning RIR whose IPv4 sale prices are not more expensive despite the history of leasing there?
Can you reconcile that with your argument that leasing will raise prices for both leasing and transfers?
Are you aware that it’s not always possible to get IPv4 blocks from the company that is providing you with connectivity?
Regards, Mike
From: Fernando Frediani fhfrediani@gmail.commailto:fhfrediani@gmail.com Sent: Wednesday, September 7, 2022 11:27 AM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
This is exactly the opposite.
Allowing IP leasing to happen more than just tottaly divert the propose of IP assignments by RIRs it make it bad specially for smaller companies as it increases the cost for both leasing and transfers in long term. The cost of leasing is based on the transfer and if leasing is allowed then transfer prices will always go up which makes it even harder for smaller companies to go into the market.
Any form of IP leasing without a direct connection relationship to provide a connectivity service makes it more expensive for smaller companies to get IP addresses to operate.
Fernando
On 07/09/2022 11:15, Mike Burns wrote:
Hi Jordi,
It’s plain you feel that we should do all possible to raise the price of IPv4 and make it unattainable for small business in the vain hope that this will drive IPv6 adoption.
I don’t think making IPv4 more difficult to acquire is the job of the RIR system.
You have not addressed the inability of smaller companies to acquire necessary IPv4 blocks if you ban leasing.
Is that something you are comfortable with, in pursuit of the IPv6 grail?
It’s okay with you that this policy prevents small companies from growing?
Regards, Mike
From: JORDI PALET MARTINEZ via sig-policy sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Sent: Wednesday, September 7, 2022 10:11 AM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Actually, I must disagree …
If organizations having unused resources, they need to transfer them or return them to the RIR. If prices keep going high, that could encourage faster IPv6 adoption, then transfer prices will go down, up to “no value”. It takes time, but it is just market.
Those that have more money, have more facilities to do a faster transition and not bother about IPv4.
Regards,
Jordi
@jordipalet
El 7/9/22, 16:05, "Mike Burns" <mike@iptrading.commailto:mike@iptrading.com> escribió:
Hello,
Per Gaurav’s statement that “only those with millions of dollars can think of getting ips”, this community should oppose this policy.
Because the only way small companies can afford to get ips today is by leasing them. The same way the small company can’t afford to purchase a big office building but instead rents an office. Leasing is the only way to finance IPv4 acquisitions today. No bank or other entity that I am aware of will do it. Purchasing addresses requires full upfront payment, but leasing allow for much smaller monthly payments.
If this community wants to ensure only the largest and richest companies can acquire new addresses, ban leasing.
But if the community tries to ban something with such a large business motivation behind it, it will find itself struggling against a powerful foe.
And for what purpose do we punish the small businesses? Leasing puts addresses in the hands of those who need them to build and operate networks. Isn’t that the primary goal of the RIR system?
Regards,
Mike
El 2/9/22, 9:23, "Gaurav Kansal" <gaurav.kansal@nic.inmailto:gaurav.kansal@nic.in> escribió:
Hello everyone,
In my opinion, even Trading of IPs (leave apart the lease for making dollars) in the name of transfers must be stopped.
If organisation doesn’t need IPs , then those must be returned back so that smaller organisations can get it from the RIR.
Currently, only the one which have millions of dollars can think of getting IPs. In today’s scenario, no one can start the Data Centre, ISP business without investing millions in IPs. Even education and research org doesn’t have an option to get IPs from RIR.
This is like horse trading and isn’t a good practice for the community as a whole.
Regards,
Gaurav Kansal
On 02-Sep-2022, at 12:20, rajesh@smartlinkindia.commailto:rajesh@smartlinkindia.com wrote:
Dear Team,
As Mr. Satoru, mentioned there are changes, but if carefully implemented in phased manner, unauthorised leasing can be stopped.
For example in first phase, leasing among countries can be stopped, if the owner company doesn't provide any services beyond its home country. For example if a company in India doesn't have any operation in Singapore or Japan , can't lease resources to those companies in Singapore or Japan. This can be verified by taking business registration documents of both lease and lessor.
Once this is done same may be granularized at RIR level, where in country like India, leasing can be restricted to the licensed service area for service provider within their designated service area.
This may stop majority of issues, barring few exceptions.
Some more brainstorming is required for better understanding and precise implementation.
Regards,
Rajesh Panwala
For Smartlink Solutions Pvt Ltd
+91-9227886001
+91-9426110781
On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru <stsuruma@bbix.netmailto:stsuruma@bbix.net> wrote:
Dear Colleagues,
I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team..
I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals.
Many participants support the intent of the proposal but felt that implementation would be challenging.
(comment details) - It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses. - I think this proposal would be useful if the concept of leasing is accurately defined. - Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement.
Regards,
Satoru Tsurumaki / JPOPF Steering Team
2022年8月26日(金) 17:27 Shaila Sharmin <shaila.sharmin.ovi@gmail.commailto:shaila.sharmin.ovi@gmail.com>:
Dear SIG members,
A new version of the proposal "prop-148-v002: Clarification - Leasing of Resources is not Acceptable" has been sent to the Policy SIG for review.
Information about earlier versions is available from:
http://www.apnic.net/policy/proposals/prop-148
You are encouraged to express your views on the proposal:
- Do you support or oppose the proposal?
- Is there anything in the proposal that is not clear?
- What changes could be made to this proposal to make it more effective?
Please find the text of the proposal below.
Regards, Bertrand, Shaila, and Ching-Heng APNIC Policy SIG Chairs
prop-148-v002: Clarification - Leasing of Resources is not Acceptable
Proposer: Jordi Palet Martinez (jordi.palet@theipv6company.comAnupammailto:jordi.palet@theipv6company.comAnupam) Amrita Choudhury (amritachoudhury@ccaoi.inmailto:amritachoudhury@ccaoi.in) Fernando Frediani (fhfredani@gmail.commailto:fhfredani@gmail.com)
- Problem statement
RIRs have been conceived to manage, allocate and assign resources according to need, in such a 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 delegated by APNIC or an NIR, the justification of the need implies the need to use on their own infrastructure and/or network connectivity services provided directly to customers. As a result, any form of IP address leasing is unacceptable, 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.
APNIC may proactively investigate those cases and also initiate the investigation in case of reports by means of a form, email address or other means developed by APNIC.
If any form of leasing, regardless of when the delegation has been issued, is confirmed by an APNIC investigation, it will be considered a policy violation and revocation may apply against any account holders who are leasing or using them for any purposes not specified in the initial request.
- Advantages / Disadvantages
Advantages: Fulfilling the objective above indicated and making the policy clear.
Disadvantages: None.
- Impact on resource holders
None.
- 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 _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.netmailto:sig-policy-leave@lists.apnic.net
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On 07/09/2022 23:28, Andrew Yager wrote:
<clip>
And in fact, leasing is permitted in some situations today.
In order to advance further you have to detail them so we all can understand what situations are these and find out if the proposal is really trying to deny them or not, and most important, if there are improvements to the text to make sure only and only what is intended in the proposal goes into the policy text.
This policy is only going to confuse this further.
I do not think this policy has merit as it stands and do not believe it provides any value to the APNIC region. Other, alternate policies designed to specifically address particular, well defined behaviours - where these is material evidence that the current framework is ineffective at addressing may have merit. But as noted, there is no quantified description of the problem this seeks to solve; and no evidence has been provided to date that this policy actually has a need to be addressed.
Confuse what exactly ? Please be specific. What specific words or phrase in the text is confusing and needs improvement ? If you recognize leasing it already not allowed in APNIC region as already confirmed in this discussion so where lacks merit for making it clear to all members in the policy text ?
Fernando
Certainly, if there is some - now is the time to provide the details.
Andrew
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*From:* Fernando Frediani fhfrediani@gmail.com *Sent:* Thursday, September 8, 2022 12:14:42 PM *To:* sig-policy@lists.apnic.net sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Unfortunately this shows a tentative to discuss something with lack of enough important information about the topic and also there was not proper follow of most of this thread discussion.
First Internet Resources are not irrevocable assets that anyone who holds them can do whatever they like as if they own them. Unfortunately many people in this industry still don't know, but the fact that organizations hold a resource assigned to them does not mean they own it and therefore they must operate them under certain rules otherwise they risk to have them revoked, therefore they cannot be treated as an asset you purchased and may do whatever you like with it. If you purchase a server or a router it is yours and you sell or lease it for whatever amount you wish, but not with internet resources because you don't own them.
It is unimportant that anything APNIC may do against those who using IPv4 blocks illegally and may have them revoked because they should never have used in that way in first instance. A while back, when they became members they have signed a contract agreeing they would use the resources according to the rules. Therefore if someone decided to do out of what has been previously agreed they did it in their own risk and cannot allege they are "being affected".
Regardless how market evolves APNIC has full rights to revoke resources from members who are misusing resources not in accordance with the contracts they have signed and agreed. And by doing that APNIC is protecting community interests in detriment to individual and very specific interests that wants to use internet resources for proposes they were never conceived for.
Seems that people still didn't accept IPv4 exhaustion and keep hoping for something that will never come instead of learn once for all how to deal with it. There are ways to get blocks, for example via transfers and other specific methods, but the scenario many were used for decades doesn't exist anymore and still seems people keep trying to make up stuff to benefit their own specific interest in detriment of everybody else and of the fairness with everybody involved. If a company doesn't have enough money to afford a transfer I am sorry, but that is the new reality for a while. Learn how to deal with it and use other alternatives available like getting from upstreams - who provide connectivity - until there is budget to get address via a transfer for example. And not less important, stop hiding from IPv6 saying that will not revolve.
APNIC has all rights to fight in courts and is fully legally covered to enforce what members using internet resources signed and agreed for. Hardly judges will overwrite such agreement because they fell sorry that some people still didn't accept and learned to live with IPv4 exhaustion. No 'difficult' scenario gives the right to a member to void a contract they signed and agreed and win that in court.
These 'emotional arguments' of people and companies that will suffer if no leasing is allowed is a common argument from organizations who profit from IP leasing and don't build any internet connectivity and is already old one. If people keep insisting in doing things out of the rules sooner or later they will have to pay the price and they should know the risk before they even started.
IP addresses were not made to be rented from a resource holder who don't need them anymore to one that needs and could get them directly from the RIR. Regardless of the most noble reason, going against the rules doesn't make they valid.
Fernando
On 07/09/2022 22:49, Matthew Shearing wrote:
Just wanted to chime in here and follow up on Mike's point (and those of several others).
What APNIC has done by its previous conduct is create a scarce asset collected in the hands of a number of large providers, with increasingly less being issued to small providers. As with any scarce asset in human history, this necessarily creates all the prerequisites for a fee market.
Just like real estate, vehicles and other commodities, leasing is a natural evolution of scarcity in an asset class with direct utility. Right now, IPv4 blocks are like houses - some own them, but some don't have the capital resources to outright own the amount they need. Simply looking at the prices which IPv4 blocks are going for on the open market will make it clear that many smaller businesses are priced out.
Leasing represents a viable option for companies to access the blocks they need and pay manageable, monthly or yearly payments for the use of those blocks. Many businesses are reliant on these currently.
Saying that APNIC will outright ban leasing and that this will somehow benefit businesses is abjectly false. Not only will it disrupt many current business operations, but there is no guarantee that a market with more perverse incentives won't emerge afterwards.
In our view, APNIC has already demonstrated by its statements and conduct with this policy that they have little grasp on how (and why) asset markets evolve. They've also done nothing to dissuade us that the new 'status quo' after this policy change won't be worse than the current one - which operates relatively fine.
Practically, for APNIC to say there will be no meaningful damage to current users and businesses (who are APNIC members in their own right) it must answer the following questions:
- What alternative does APNIC propose to the current IPv4 market and particularly, leasing options available to smaller companies and new entrants?
- How will terminating leases currently on foot result in a better outcome for the businesses currently relying on them?
- How will new IPv4 addresses be allocated, what timeframes and costs will be involved in this allocation?
- Can APNIC give guarantees to current lessees who are reliant on IPv4 address leases that they can continue to access those addresses or will have replacements of similar value, at less cost, instantly after the change is made?
- Is APNIC prepared to be held liable in lawsuits or a class action for the damages incurred by this policy change? Has it considered this risk and informed members accordingly?
It appears that those that will not be affected by this policy or those who already have large IPv4 blocks are some of the largest proponents of it - which makes sense. It is easy to vote for a change if it's only others that will be affected.
However, there are a large number of SME businesses out there who rely on these leases to run their operations. For them, this isn't just some merely intellectual exercise. Rather, it's a question of hundreds of thousands, or even millions, of dollars.
It's their ability to remain operational. It's their employees' livelihoods and those of their families. It's a core part of how they operate and for many, the foundation which they've built their business on.
This policy change seems to almost be a /'policy for policies sake'/. It is clear that the repercussions of this were either not considered, or not even known, as the policy notes listed 'nil' negative effects. That this is the opinion of APNIC (and it seems, of a significant portion of the community) is incredibly concerning, because it couldn't be further from the truth.
Many real businesses will be affected by this, with real people. And the flippancy with which many within APNIC are treating this proposal shows a concerning lack of empathy towards that - and a failure to grasp the nature of IPv4 addresses as a modern asset class.
Without the above questions answered, I don't see how this policy vote can go ahead - and I would implore everyone considering this policy to reject it outright. There may be issues with the current IPv4 paradigm but this is definitely not the solution.
Kind Regards
*Matt Shearing* *Chief Executive Officer*
Brisbane, Australia (AEST) • matt@oneqode.com mailto:matt@oneqode.com • +61 406 778 038
OneQode™ https://www.oneqode.com/
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*From:* Mike Burns mike@iptrading.com mailto:mike@iptrading.com *Sent:* Thursday, 8 September 2022 6:52 AM *To:* 'Fernando Frediani' fhfrediani@gmail.com mailto:fhfrediani@gmail.com; sig-policy@lists.apnic.net mailto:sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Alas, Fernando, there is no alternative “drug” for people to live without IPv4.
Banning leasing hurts the smallest and poorest of companies most.
And you cannot elucidate any “major damages” suffered where leasing has actually, in reality, occurred for many years at RIPE.
Yet you use this evidence-free assertion as your major argument against leasing.
That some kind of serious damage will occur to the RIR system.
As a broker who as to talk to actual, real companies in need, who can’t afford to pay upfront, can you tell me what I should say when they ask me why leasing is forbidden? If I say it’s to avoid “major damages” and they ask what they are, can you tell me?
What major damages?
Regards, Mike
*From:* Fernando Frediani <fhfrediani@gmail.com mailto:fhfrediani@gmail.com> *Sent:* Wednesday, September 7, 2022 4:33 PM *To:* sig-policy@lists.apnic.net mailto:sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Do you understand the argument that certain drugs can alleviate certain pains but they remain forbidden because they cause a major damage to society in long term and there are alternatives for people be able to still live without have to use those type of damageable mechanisms. Companies can also live without that and still have other legally allowed mechanisms.
This discussion is unnecessary for this policy discussion as what it proposes is to make something *already forbidden* clear in to the text, not to discuss if leasing should exist or not.
If anyone opposes it please take attention to provide arguments and suggestions on how to address the issues raised about what the proposal really proposes.
Regards Fernando
On 07/09/2022 14:12, Mike Burns wrote:
Hi Fernando, Do you understand my argument that smaller business cannot afford the full upfront payment but can afford monthly lease payments? Please address that simple argument by telling me how the small business benefits by not having the lease option, but only having the purchase option. Regards, Mike *From:* Fernando Frediani <fhfrediani@gmail.com> <mailto:fhfrediani@gmail.com> *Sent:* Wednesday, September 7, 2022 1:01 PM *To:* sig-policy@lists.apnic.net <mailto:sig-policy@lists.apnic.net> *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable IP Leasing is already banned in most RIRs and should stay as is. But yes it does help as it doesn't push even further up IPv4 pricing and makes it easier for these small companies to get IPv4 via the proper and allowed way which are transfers. Other then diverting totally the propose o IPv4 Allocation, Leasing market contributes significantly to price increasing fueling the market with more demand for that type of very wrong thing. RIPE is normally not a good example for certain policies which don't seem to have receptivity in discussions on all other RIRs. There are still mechanisms that allow companies to get IP addressing either directly from the RIR, via Transfers which is a pretty common way or from the Upstream providers. People may not have got used yet to learn to live with less address and they may believe they need a bunch of address. IP Leasing will never help small companies. The ones who really benefit from it are the IP broker companies who profit from them and also the resource holders which don't justify anymore to keep those addresses and are also profiting from something that should have been re-assigned directly to those who really need and justify for them in order to build Internet Infrastructure and Connectivity and instead are leasing a asset they don't own. Fernando On 07/09/2022 12:39, Mike Burns wrote: Hi Fernando, So your argument is that banning leasing actually helps smaller companies in their quest for IPv4? Are you aware that RIPE has allowed leasing for many years but is still a functioning RIR whose IPv4 sale prices are not more expensive despite the history of leasing there? Can you reconcile that with your argument that leasing will raise prices for both leasing and transfers? Are you aware that it’s not always possible to get IPv4 blocks from the company that is providing you with connectivity? Regards, Mike *From:* Fernando Frediani <fhfrediani@gmail.com> <mailto:fhfrediani@gmail.com> *Sent:* Wednesday, September 7, 2022 11:27 AM *To:* sig-policy@lists.apnic.net <mailto:sig-policy@lists.apnic.net> *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable This is exactly the opposite. Allowing IP leasing to happen more than just tottaly divert the propose of IP assignments by RIRs it make it bad specially for smaller companies as it increases the cost for both leasing and transfers in long term. The cost of leasing is based on the transfer and if leasing is allowed then transfer prices will always go up which makes it even harder for smaller companies to go into the market. Any form of IP leasing without a direct connection relationship to provide a connectivity service makes it more expensive for smaller companies to get IP addresses to operate. Fernando On 07/09/2022 11:15, Mike Burns wrote: Hi Jordi, It’s plain you feel that we should do all possible to raise the price of IPv4 and make it unattainable for small business in the vain hope that this will drive IPv6 adoption. I don’t think making IPv4 more difficult to acquire is the job of the RIR system. You have not addressed the inability of smaller companies to acquire necessary IPv4 blocks if you ban leasing. Is that something you are comfortable with, in pursuit of the IPv6 grail? It’s okay with you that this policy prevents small companies from growing? Regards, Mike *From:* JORDI PALET MARTINEZ via sig-policy <sig-policy@lists.apnic.net> <mailto:sig-policy@lists.apnic.net> *Sent:* Wednesday, September 7, 2022 10:11 AM *To:* sig-policy@lists.apnic.net <mailto:sig-policy@lists.apnic.net> *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable Actually, I must disagree … If organizations having unused resources, they need to transfer them or return them to the RIR. If prices keep going high, that could encourage faster IPv6 adoption, then transfer prices will go down, up to “no value”. It takes time, but it is just market. Those that have more money, have more facilities to do a faster transition and not bother about IPv4. Regards, Jordi @jordipalet El 7/9/22, 16:05, "Mike Burns" <mike@iptrading.com <mailto:mike@iptrading.com>> escribió: Hello, Per Gaurav’s statement that “only those with millions of dollars can think of getting ips”, this community should oppose this policy. Because the only way small companies can afford to get ips today is by leasing them. The same way the small company can’t afford to purchase a big office building but instead rents an office. Leasing is the only way to finance IPv4 acquisitions today. No bank or other entity that I am aware of will do it. Purchasing addresses requires full upfront payment, but leasing allow for much smaller monthly payments. If this community wants to ensure only the largest and richest companies can acquire new addresses, ban leasing. But if the community tries to ban something with such a large business motivation behind it, it will find itself struggling against a powerful foe. And for what purpose do we punish the small businesses? Leasing puts addresses in the hands of those who need them to build and operate networks. Isn’t that the primary goal of the RIR system? Regards, Mike El 2/9/22, 9:23, "Gaurav Kansal" <gaurav.kansal@nic.in <mailto:gaurav.kansal@nic.in>> escribió: Hello everyone, In my opinion, even Trading of IPs (leave apart the lease for making dollars) in the name of transfers must be stopped. If organisation doesn’t need IPs , then those must be returned back so that smaller organisations can get it from the RIR. Currently, only the one which have millions of dollars can think of getting IPs. In today’s scenario, no one can start the Data Centre, ISP business without investing millions in IPs. Even education and research org doesn’t have an option to get IPs from RIR. This is like horse trading and isn’t a good practice for the community as a whole. Regards, Gaurav Kansal On 02-Sep-2022, at 12:20, rajesh@smartlinkindia.com <mailto:rajesh@smartlinkindia.com> wrote: Dear Team, As Mr. Satoru, mentioned there are changes, but if carefully implemented in phased manner, unauthorised leasing can be stopped. For example in first phase, leasing among countries can be stopped, if the owner company doesn't provide any services beyond its home country. For example if a company in India doesn't have any operation in Singapore or Japan , can't lease resources to those companies in Singapore or Japan. This can be verified by taking business registration documents of both lease and lessor. Once this is done same may be granularized at RIR level, where in country like India, leasing can be restricted to the licensed service area for service provider within their designated service area. This may stop majority of issues, barring few exceptions. Some more brainstorming is required for better understanding and precise implementation. Regards, Rajesh Panwala For Smartlink Solutions Pvt Ltd +91-9227886001 +91-9426110781 On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru <stsuruma@bbix.net <mailto:stsuruma@bbix.net>> wrote: Dear Colleagues, I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team.. I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals. Many participants support the intent of the proposal but felt that implementation would be challenging. (comment details) - It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses. - I think this proposal would be useful if the concept of leasing is accurately defined. - Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement. Regards, Satoru Tsurumaki / JPOPF Steering Team 2022年8月26日(金) 17:27 Shaila Sharmin <shaila.sharmin.ovi@gmail.com <mailto:shaila.sharmin.ovi@gmail.com>>: > > Dear SIG members, > > A new version of the proposal "prop-148-v002: Clarification - Leasing of > Resources is not Acceptable" has been sent to the Policy SIG for review. > > Information about earlier versions is available from: > > http://www.apnic.net/policy/proposals/prop-148 <http://www.apnic.net/policy/proposals/prop-148> > > You are encouraged to express your views on the proposal: > > - Do you support or oppose the proposal? > - Is there anything in the proposal that is not clear? > - What changes could be made to this proposal to make it more effective? > > Please find the text of the proposal below. > > Regards, > Bertrand, Shaila, and Ching-Heng > APNIC Policy SIG Chairs > > > ---------------------------------------------------------------------- > prop-148-v002: Clarification - 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 a 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 delegated by APNIC or an NIR, > the justification of the need implies the need to use on their own > infrastructure and/or network connectivity services provided directly to > customers. As a result, any form of IP address leasing is unacceptable, > 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. > > APNIC may proactively investigate those cases and also initiate the > investigation in case of reports by means of a form, email address or > other means developed by APNIC. > > If any form of leasing, regardless of when the delegation has been > issued, is confirmed by an APNIC investigation, it will be considered a > policy violation and revocation may apply against any account holders > who are leasing or using them for any purposes not specified in the > initial request. > > > 5. Advantages / Disadvantages > ----------------------------- > Advantages: > Fulfilling the objective above indicated and making the policy clear. > > Disadvantages: > None. > > > 6. Impact on resource holders > ----------------------------- > None. > > > 7. References > ------------- > https://www.arin.net/participate/policy/proposals/2022/ARIN_prop_308_v2/ <https://www.arin.net/participate/policy/proposals/2022/ARIN_prop_308_v2/> > https://politicas.lacnic.net/politicas/detail/id/LAC-2022-2/language/en <https://politicas.lacnic.net/politicas/detail/id/LAC-2022-2/language/en> > _______________________________________________ > sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ <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> -- -- Satoru Tsurumaki BBIX, Inc _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ <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> _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ <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> <https://amritmahotsav.nic.in/> _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ <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> ********************************************** IPv4 is over Are you ready for the new Internet ? http://www.theipv6company.com <http://www.theipv6company.com> The IPv6 Company This electronic message contains information which may be privileged or confidential. 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Fernando, very simply – if it was already against the rules, why this policy? There should be no need for clarification if this was already ‘illegal’ or ‘against the rules’ as you say. What is the point of this policy if it’s already clear?
Further, you keep talking about IPv4 exhaustion and that we need to ‘deal with it’. The fact there exists a leasing market in the first place means that there are plenty of unused IPv4 resources. Otherwise, there would be no IPv4 addresses to lease.
If APNIC wants to tackle ‘misuse’, that is also fine. However, why not start with those who have plenty of IP space? Why not build in guarantees that APNIC it revokes space from a large holder, any lessees currently using that space will get access to those IPv4 addresses, as they are the ones using them? Why is none of this even being discussed? It’s incredibly obvious this policy hurts mainly the smaller companies, by going after leases, not the big holdings themselves.
By saying ‘there are ways to get blocks’ also tells me very clearly that you’ve either not tried recently, or you’re just willfully ignorant. For many companies, leasing is the only feasible ways to get blocks because we are priced out.
Ideologically, we are all in agreement that an IPv6 world would be amazing. Unfortunately, those of us running businesses need to exist here in the real world, not in your imaginary world where we get everything we would like. If you want to help change that, we’ll all be here, cheering you on. Until then, businesses like ours don’t have the luxury of sitting around wishing – we’ve got customers we need to serve and employees we need to pay.
These ‘emotional’ arguments are common because they are real. They are for businesses that exist in the real world, in an IP environment that APNIC (and other registrars) created. APNIC allowed the leasing paradigm to occur and did nothing about it. This is not some new thing – it is a mature market that has existed for a long time.
It is incredibly irresponsible for APNIC to try and roll it back now, after many years of inaction, and disingenuous for people like you to somehow claim businesses that are just trying to do the best they can in the environment we currently have are somehow at fault. This problem can be laid squarely at the feet of APNIC – and for that reason, it can and will be held liable by those damaged if any changes are made now.
This policy is approaching everything from the wrong direction. Its implementation will punish the smallest businesses while doing nothing about the largest legacy holders. If APNIC is serious about the IPv4 allocation issue, it should start with the swathes of latent resources and move backwards. This should be tempered by protections and policies which ensure smaller businesses aren’t ruined in the process. Maybe once that is solved, in several years time, it will be time to revisit this topic. For now though, this is far too premature.
The reality is this – for many of us, leasing is right now the only viable option. Taking that away without proposing any kind of genuine alternatives (ie not the handwavium generalisations you’ve been engaging in) is reckless and will result in incredible damage to members who have simply been doing their best in an environment APNIC created in the first place.
Cheers,
Matt Shearing Chief Executive Officer [https://www.oneqode.com/img/email-pin.png] Brisbane, Australia (AEST) • matt@oneqode.commailto:matt@oneqode.com • +61 406 778 038 [OneQode™]https://www.oneqode.com/
[Follow us on LinkedIn]https://www.linkedin.com/company/oneqode/
From: Fernando Frediani fhfrediani@gmail.com Sent: Thursday, 8 September 2022 12:15 PM To: sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Unfortunately this shows a tentative to discuss something with lack of enough important information about the topic and also there was not proper follow of most of this thread discussion.
First Internet Resources are not irrevocable assets that anyone who holds them can do whatever they like as if they own them. Unfortunately many people in this industry still don't know, but the fact that organizations hold a resource assigned to them does not mean they own it and therefore they must operate them under certain rules otherwise they risk to have them revoked, therefore they cannot be treated as an asset you purchased and may do whatever you like with it. If you purchase a server or a router it is yours and you sell or lease it for whatever amount you wish, but not with internet resources because you don't own them.
It is unimportant that anything APNIC may do against those who using IPv4 blocks illegally and may have them revoked because they should never have used in that way in first instance. A while back, when they became members they have signed a contract agreeing they would use the resources according to the rules. Therefore if someone decided to do out of what has been previously agreed they did it in their own risk and cannot allege they are "being affected".
Regardless how market evolves APNIC has full rights to revoke resources from members who are misusing resources not in accordance with the contracts they have signed and agreed. And by doing that APNIC is protecting community interests in detriment to individual and very specific interests that wants to use internet resources for proposes they were never conceived for.
Seems that people still didn't accept IPv4 exhaustion and keep hoping for something that will never come instead of learn once for all how to deal with it. There are ways to get blocks, for example via transfers and other specific methods, but the scenario many were used for decades doesn't exist anymore and still seems people keep trying to make up stuff to benefit their own specific interest in detriment of everybody else and of the fairness with everybody involved. If a company doesn't have enough money to afford a transfer I am sorry, but that is the new reality for a while. Learn how to deal with it and use other alternatives available like getting from upstreams - who provide connectivity - until there is budget to get address via a transfer for example. And not less important, stop hiding from IPv6 saying that will not revolve.
APNIC has all rights to fight in courts and is fully legally covered to enforce what members using internet resources signed and agreed for. Hardly judges will overwrite such agreement because they fell sorry that some people still didn't accept and learned to live with IPv4 exhaustion. No 'difficult' scenario gives the right to a member to void a contract they signed and agreed and win that in court.
These 'emotional arguments' of people and companies that will suffer if no leasing is allowed is a common argument from organizations who profit from IP leasing and don't build any internet connectivity and is already old one. If people keep insisting in doing things out of the rules sooner or later they will have to pay the price and they should know the risk before they even started.
IP addresses were not made to be rented from a resource holder who don't need them anymore to one that needs and could get them directly from the RIR. Regardless of the most noble reason, going against the rules doesn't make they valid.
Fernando On 07/09/2022 22:49, Matthew Shearing wrote: Just wanted to chime in here and follow up on Mike's point (and those of several others).
What APNIC has done by its previous conduct is create a scarce asset collected in the hands of a number of large providers, with increasingly less being issued to small providers. As with any scarce asset in human history, this necessarily creates all the prerequisites for a fee market.
Just like real estate, vehicles and other commodities, leasing is a natural evolution of scarcity in an asset class with direct utility. Right now, IPv4 blocks are like houses - some own them, but some don't have the capital resources to outright own the amount they need. Simply looking at the prices which IPv4 blocks are going for on the open market will make it clear that many smaller businesses are priced out.
Leasing represents a viable option for companies to access the blocks they need and pay manageable, monthly or yearly payments for the use of those blocks. Many businesses are reliant on these currently.
Saying that APNIC will outright ban leasing and that this will somehow benefit businesses is abjectly false. Not only will it disrupt many current business operations, but there is no guarantee that a market with more perverse incentives won't emerge afterwards.
In our view, APNIC has already demonstrated by its statements and conduct with this policy that they have little grasp on how (and why) asset markets evolve. They've also done nothing to dissuade us that the new 'status quo' after this policy change won't be worse than the current one - which operates relatively fine.
Practically, for APNIC to say there will be no meaningful damage to current users and businesses (who are APNIC members in their own right) it must answer the following questions:
1. What alternative does APNIC propose to the current IPv4 market and particularly, leasing options available to smaller companies and new entrants? 2. How will terminating leases currently on foot result in a better outcome for the businesses currently relying on them? 3. How will new IPv4 addresses be allocated, what timeframes and costs will be involved in this allocation? 4. Can APNIC give guarantees to current lessees who are reliant on IPv4 address leases that they can continue to access those addresses or will have replacements of similar value, at less cost, instantly after the change is made? 5. Is APNIC prepared to be held liable in lawsuits or a class action for the damages incurred by this policy change? Has it considered this risk and informed members accordingly?
It appears that those that will not be affected by this policy or those who already have large IPv4 blocks are some of the largest proponents of it - which makes sense. It is easy to vote for a change if it's only others that will be affected.
However, there are a large number of SME businesses out there who rely on these leases to run their operations. For them, this isn't just some merely intellectual exercise. Rather, it's a question of hundreds of thousands, or even millions, of dollars.
It's their ability to remain operational. It's their employees' livelihoods and those of their families. It's a core part of how they operate and for many, the foundation which they've built their business on.
This policy change seems to almost be a 'policy for policies sake'. It is clear that the repercussions of this were either not considered, or not even known, as the policy notes listed 'nil' negative effects. That this is the opinion of APNIC (and it seems, of a significant portion of the community) is incredibly concerning, because it couldn't be further from the truth.
Many real businesses will be affected by this, with real people. And the flippancy with which many within APNIC are treating this proposal shows a concerning lack of empathy towards that - and a failure to grasp the nature of IPv4 addresses as a modern asset class.
Without the above questions answered, I don't see how this policy vote can go ahead - and I would implore everyone considering this policy to reject it outright. There may be issues with the current IPv4 paradigm but this is definitely not the solution.
Kind Regards
Matt Shearing Chief Executive Officer [https://www.oneqode.com/img/email-pin.png] Brisbane, Australia (AEST) • matt@oneqode.commailto:matt@oneqode.com • +61 406 778 038 [OneQode™]https://www.oneqode.com/
[Follow us on LinkedIn]https://www.linkedin.com/company/oneqode/
From: Mike Burns mike@iptrading.commailto:mike@iptrading.com Sent: Thursday, 8 September 2022 6:52 AM To: 'Fernando Frediani' fhfrediani@gmail.commailto:fhfrediani@gmail.com; sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Alas, Fernando, there is no alternative “drug” for people to live without IPv4. Banning leasing hurts the smallest and poorest of companies most.
And you cannot elucidate any “major damages” suffered where leasing has actually, in reality, occurred for many years at RIPE. Yet you use this evidence-free assertion as your major argument against leasing. That some kind of serious damage will occur to the RIR system.
As a broker who as to talk to actual, real companies in need, who can’t afford to pay upfront, can you tell me what I should say when they ask me why leasing is forbidden? If I say it’s to avoid “major damages” and they ask what they are, can you tell me?
What major damages?
Regards, Mike
From: Fernando Frediani <fhfrediani@gmail.commailto:fhfrediani@gmail.com> Sent: Wednesday, September 7, 2022 4:33 PM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Do you understand the argument that certain drugs can alleviate certain pains but they remain forbidden because they cause a major damage to society in long term and there are alternatives for people be able to still live without have to use those type of damageable mechanisms. Companies can also live without that and still have other legally allowed mechanisms.
This discussion is unnecessary for this policy discussion as what it proposes is to make something *already forbidden* clear in to the text, not to discuss if leasing should exist or not.
If anyone opposes it please take attention to provide arguments and suggestions on how to address the issues raised about what the proposal really proposes.
Regards Fernando On 07/09/2022 14:12, Mike Burns wrote: Hi Fernando,
Do you understand my argument that smaller business cannot afford the full upfront payment but can afford monthly lease payments?
Please address that simple argument by telling me how the small business benefits by not having the lease option, but only having the purchase option.
Regards, Mike
From: Fernando Frediani fhfrediani@gmail.commailto:fhfrediani@gmail.com Sent: Wednesday, September 7, 2022 1:01 PM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
IP Leasing is already banned in most RIRs and should stay as is.
But yes it does help as it doesn't push even further up IPv4 pricing and makes it easier for these small companies to get IPv4 via the proper and allowed way which are transfers. Other then diverting totally the propose o IPv4 Allocation, Leasing market contributes significantly to price increasing fueling the market with more demand for that type of very wrong thing.
RIPE is normally not a good example for certain policies which don't seem to have receptivity in discussions on all other RIRs.
There are still mechanisms that allow companies to get IP addressing either directly from the RIR, via Transfers which is a pretty common way or from the Upstream providers. People may not have got used yet to learn to live with less address and they may believe they need a bunch of address.
IP Leasing will never help small companies. The ones who really benefit from it are the IP broker companies who profit from them and also the resource holders which don't justify anymore to keep those addresses and are also profiting from something that should have been re-assigned directly to those who really need and justify for them in order to build Internet Infrastructure and Connectivity and instead are leasing a asset they don't own.
Fernando On 07/09/2022 12:39, Mike Burns wrote: Hi Fernando,
So your argument is that banning leasing actually helps smaller companies in their quest for IPv4?
Are you aware that RIPE has allowed leasing for many years but is still a functioning RIR whose IPv4 sale prices are not more expensive despite the history of leasing there?
Can you reconcile that with your argument that leasing will raise prices for both leasing and transfers?
Are you aware that it’s not always possible to get IPv4 blocks from the company that is providing you with connectivity?
Regards, Mike
From: Fernando Frediani fhfrediani@gmail.commailto:fhfrediani@gmail.com Sent: Wednesday, September 7, 2022 11:27 AM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
This is exactly the opposite.
Allowing IP leasing to happen more than just tottaly divert the propose of IP assignments by RIRs it make it bad specially for smaller companies as it increases the cost for both leasing and transfers in long term. The cost of leasing is based on the transfer and if leasing is allowed then transfer prices will always go up which makes it even harder for smaller companies to go into the market.
Any form of IP leasing without a direct connection relationship to provide a connectivity service makes it more expensive for smaller companies to get IP addresses to operate.
Fernando On 07/09/2022 11:15, Mike Burns wrote: Hi Jordi,
It’s plain you feel that we should do all possible to raise the price of IPv4 and make it unattainable for small business in the vain hope that this will drive IPv6 adoption.
I don’t think making IPv4 more difficult to acquire is the job of the RIR system.
You have not addressed the inability of smaller companies to acquire necessary IPv4 blocks if you ban leasing. Is that something you are comfortable with, in pursuit of the IPv6 grail? It’s okay with you that this policy prevents small companies from growing?
Regards, Mike
From: JORDI PALET MARTINEZ via sig-policy sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Sent: Wednesday, September 7, 2022 10:11 AM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Actually, I must disagree …
If organizations having unused resources, they need to transfer them or return them to the RIR. If prices keep going high, that could encourage faster IPv6 adoption, then transfer prices will go down, up to “no value”. It takes time, but it is just market.
Those that have more money, have more facilities to do a faster transition and not bother about IPv4.
Regards, Jordi @jordipalet
El 7/9/22, 16:05, "Mike Burns" <mike@iptrading.commailto:mike@iptrading.com> escribió:
Hello,
Per Gaurav’s statement that “only those with millions of dollars can think of getting ips”, this community should oppose this policy.
Because the only way small companies can afford to get ips today is by leasing them. The same way the small company can’t afford to purchase a big office building but instead rents an office. Leasing is the only way to finance IPv4 acquisitions today. No bank or other entity that I am aware of will do it. Purchasing addresses requires full upfront payment, but leasing allow for much smaller monthly payments.
If this community wants to ensure only the largest and richest companies can acquire new addresses, ban leasing.
But if the community tries to ban something with such a large business motivation behind it, it will find itself struggling against a powerful foe.
And for what purpose do we punish the small businesses? Leasing puts addresses in the hands of those who need them to build and operate networks. Isn’t that the primary goal of the RIR system?
Regards, Mike
El 2/9/22, 9:23, "Gaurav Kansal" <gaurav.kansal@nic.inmailto:gaurav.kansal@nic.in> escribió:
Hello everyone,
In my opinion, even Trading of IPs (leave apart the lease for making dollars) in the name of transfers must be stopped. If organisation doesn’t need IPs , then those must be returned back so that smaller organisations can get it from the RIR.
Currently, only the one which have millions of dollars can think of getting IPs. In today’s scenario, no one can start the Data Centre, ISP business without investing millions in IPs. Even education and research org doesn’t have an option to get IPs from RIR.
This is like horse trading and isn’t a good practice for the community as a whole.
Regards, Gaurav Kansal
On 02-Sep-2022, at 12:20, rajesh@smartlinkindia.commailto:rajesh@smartlinkindia.com wrote:
Dear Team,
As Mr. Satoru, mentioned there are changes, but if carefully implemented in phased manner, unauthorised leasing can be stopped.
For example in first phase, leasing among countries can be stopped, if the owner company doesn't provide any services beyond its home country. For example if a company in India doesn't have any operation in Singapore or Japan , can't lease resources to those companies in Singapore or Japan. This can be verified by taking business registration documents of both lease and lessor. Once this is done same may be granularized at RIR level, where in country like India, leasing can be restricted to the licensed service area for service provider within their designated service area. This may stop majority of issues, barring few exceptions. Some more brainstorming is required for better understanding and precise implementation.
Regards,
Rajesh Panwala For Smartlink Solutions Pvt Ltd +91-9227886001 +91-9426110781
On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru <stsuruma@bbix.netmailto:stsuruma@bbix.net> wrote: Dear Colleagues,
I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team..
I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals.
Many participants support the intent of the proposal but felt that implementation would be challenging.
(comment details) - It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses. - I think this proposal would be useful if the concept of leasing is accurately defined. - Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement.
Regards,
Satoru Tsurumaki / JPOPF Steering Team
2022年8月26日(金) 17:27 Shaila Sharmin <shaila.sharmin.ovi@gmail.commailto:shaila.sharmin.ovi@gmail.com>:
Dear SIG members,
A new version of the proposal "prop-148-v002: Clarification - Leasing of Resources is not Acceptable" has been sent to the Policy SIG for review.
Information about earlier versions is available from:
http://www.apnic.net/policy/proposals/prop-148
You are encouraged to express your views on the proposal:
- Do you support or oppose the proposal?
- Is there anything in the proposal that is not clear?
- What changes could be made to this proposal to make it more effective?
Please find the text of the proposal below.
Regards, Bertrand, Shaila, and Ching-Heng APNIC Policy SIG Chairs
prop-148-v002: Clarification - Leasing of Resources is not Acceptable
Proposer: Jordi Palet Martinez (jordi.palet@theipv6company.comAnupammailto:jordi.palet@theipv6company.comAnupam) Amrita Choudhury (amritachoudhury@ccaoi.inmailto:amritachoudhury@ccaoi.in) Fernando Frediani (fhfredani@gmail.commailto:fhfredani@gmail.com)
- Problem statement
RIRs have been conceived to manage, allocate and assign resources according to need, in such a 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 delegated by APNIC or an NIR, the justification of the need implies the need to use on their own infrastructure and/or network connectivity services provided directly to customers. As a result, any form of IP address leasing is unacceptable, 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.
APNIC may proactively investigate those cases and also initiate the investigation in case of reports by means of a form, email address or other means developed by APNIC.
If any form of leasing, regardless of when the delegation has been issued, is confirmed by an APNIC investigation, it will be considered a policy violation and revocation may apply against any account holders who are leasing or using them for any purposes not specified in the initial request.
- Advantages / Disadvantages
Advantages: Fulfilling the objective above indicated and making the policy clear.
Disadvantages: None.
- Impact on resource holders
None.
- 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 _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.netmailto:sig-policy-leave@lists.apnic.net
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Thanks Matt. Well put.
Andrew
Get Outlook for iOShttps://aka.ms/o0ukef ________________________________ From: Matthew Shearing matt@oneqode.com.au Sent: Thursday, September 8, 2022 12:39:37 PM To: Fernando Frediani fhfrediani@gmail.com; sig-policy@lists.apnic.net sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Fernando, very simply – if it was already against the rules, why this policy? There should be no need for clarification if this was already ‘illegal’ or ‘against the rules’ as you say. What is the point of this policy if it’s already clear?
Further, you keep talking about IPv4 exhaustion and that we need to ‘deal with it’. The fact there exists a leasing market in the first place means that there are plenty of unused IPv4 resources. Otherwise, there would be no IPv4 addresses to lease.
If APNIC wants to tackle ‘misuse’, that is also fine. However, why not start with those who have plenty of IP space? Why not build in guarantees that APNIC it revokes space from a large holder, any lessees currently using that space will get access to those IPv4 addresses, as they are the ones using them? Why is none of this even being discussed? It’s incredibly obvious this policy hurts mainly the smaller companies, by going after leases, not the big holdings themselves.
By saying ‘there are ways to get blocks’ also tells me very clearly that you’ve either not tried recently, or you’re just willfully ignorant. For many companies, leasing is the only feasible ways to get blocks because we are priced out.
Ideologically, we are all in agreement that an IPv6 world would be amazing. Unfortunately, those of us running businesses need to exist here in the real world, not in your imaginary world where we get everything we would like. If you want to help change that, we’ll all be here, cheering you on. Until then, businesses like ours don’t have the luxury of sitting around wishing – we’ve got customers we need to serve and employees we need to pay.
These ‘emotional’ arguments are common because they are real. They are for businesses that exist in the real world, in an IP environment that APNIC (and other registrars) created. APNIC allowed the leasing paradigm to occur and did nothing about it. This is not some new thing – it is a mature market that has existed for a long time.
It is incredibly irresponsible for APNIC to try and roll it back now, after many years of inaction, and disingenuous for people like you to somehow claim businesses that are just trying to do the best they can in the environment we currently have are somehow at fault. This problem can be laid squarely at the feet of APNIC – and for that reason, it can and will be held liable by those damaged if any changes are made now.
This policy is approaching everything from the wrong direction. Its implementation will punish the smallest businesses while doing nothing about the largest legacy holders. If APNIC is serious about the IPv4 allocation issue, it should start with the swathes of latent resources and move backwards. This should be tempered by protections and policies which ensure smaller businesses aren’t ruined in the process. Maybe once that is solved, in several years time, it will be time to revisit this topic. For now though, this is far too premature.
The reality is this – for many of us, leasing is right now the only viable option. Taking that away without proposing any kind of genuine alternatives (ie not the handwavium generalisations you’ve been engaging in) is reckless and will result in incredible damage to members who have simply been doing their best in an environment APNIC created in the first place.
Cheers,
Matt Shearing Chief Executive Officer
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Brisbane, Australia (AEST) • matt@oneqode.commailto:matt@oneqode.com • +61 406 778 038
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From: Fernando Frediani fhfrediani@gmail.com Sent: Thursday, 8 September 2022 12:15 PM To: sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Unfortunately this shows a tentative to discuss something with lack of enough important information about the topic and also there was not proper follow of most of this thread discussion.
First Internet Resources are not irrevocable assets that anyone who holds them can do whatever they like as if they own them. Unfortunately many people in this industry still don't know, but the fact that organizations hold a resource assigned to them does not mean they own it and therefore they must operate them under certain rules otherwise they risk to have them revoked, therefore they cannot be treated as an asset you purchased and may do whatever you like with it. If you purchase a server or a router it is yours and you sell or lease it for whatever amount you wish, but not with internet resources because you don't own them.
It is unimportant that anything APNIC may do against those who using IPv4 blocks illegally and may have them revoked because they should never have used in that way in first instance. A while back, when they became members they have signed a contract agreeing they would use the resources according to the rules. Therefore if someone decided to do out of what has been previously agreed they did it in their own risk and cannot allege they are "being affected".
Regardless how market evolves APNIC has full rights to revoke resources from members who are misusing resources not in accordance with the contracts they have signed and agreed. And by doing that APNIC is protecting community interests in detriment to individual and very specific interests that wants to use internet resources for proposes they were never conceived for.
Seems that people still didn't accept IPv4 exhaustion and keep hoping for something that will never come instead of learn once for all how to deal with it. There are ways to get blocks, for example via transfers and other specific methods, but the scenario many were used for decades doesn't exist anymore and still seems people keep trying to make up stuff to benefit their own specific interest in detriment of everybody else and of the fairness with everybody involved. If a company doesn't have enough money to afford a transfer I am sorry, but that is the new reality for a while. Learn how to deal with it and use other alternatives available like getting from upstreams - who provide connectivity - until there is budget to get address via a transfer for example. And not less important, stop hiding from IPv6 saying that will not revolve.
APNIC has all rights to fight in courts and is fully legally covered to enforce what members using internet resources signed and agreed for. Hardly judges will overwrite such agreement because they fell sorry that some people still didn't accept and learned to live with IPv4 exhaustion. No 'difficult' scenario gives the right to a member to void a contract they signed and agreed and win that in court.
These 'emotional arguments' of people and companies that will suffer if no leasing is allowed is a common argument from organizations who profit from IP leasing and don't build any internet connectivity and is already old one. If people keep insisting in doing things out of the rules sooner or later they will have to pay the price and they should know the risk before they even started.
IP addresses were not made to be rented from a resource holder who don't need them anymore to one that needs and could get them directly from the RIR. Regardless of the most noble reason, going against the rules doesn't make they valid.
Fernando
On 07/09/2022 22:49, Matthew Shearing wrote:
Just wanted to chime in here and follow up on Mike's point (and those of several others).
What APNIC has done by its previous conduct is create a scarce asset collected in the hands of a number of large providers, with increasingly less being issued to small providers. As with any scarce asset in human history, this necessarily creates all the prerequisites for a fee market.
Just like real estate, vehicles and other commodities, leasing is a natural evolution of scarcity in an asset class with direct utility. Right now, IPv4 blocks are like houses - some own them, but some don't have the capital resources to outright own the amount they need. Simply looking at the prices which IPv4 blocks are going for on the open market will make it clear that many smaller businesses are priced out.
Leasing represents a viable option for companies to access the blocks they need and pay manageable, monthly or yearly payments for the use of those blocks. Many businesses are reliant on these currently.
Saying that APNIC will outright ban leasing and that this will somehow benefit businesses is abjectly false. Not only will it disrupt many current business operations, but there is no guarantee that a market with more perverse incentives won't emerge afterwards.
In our view, APNIC has already demonstrated by its statements and conduct with this policy that they have little grasp on how (and why) asset markets evolve. They've also done nothing to dissuade us that the new 'status quo' after this policy change won't be worse than the current one - which operates relatively fine.
Practically, for APNIC to say there will be no meaningful damage to current users and businesses (who are APNIC members in their own right) it must answer the following questions:
1. What alternative does APNIC propose to the current IPv4 market and particularly, leasing options available to smaller companies and new entrants? 2. How will terminating leases currently on foot result in a better outcome for the businesses currently relying on them? 3. How will new IPv4 addresses be allocated, what timeframes and costs will be involved in this allocation? 4. Can APNIC give guarantees to current lessees who are reliant on IPv4 address leases that they can continue to access those addresses or will have replacements of similar value, at less cost, instantly after the change is made? 5. Is APNIC prepared to be held liable in lawsuits or a class action for the damages incurred by this policy change? Has it considered this risk and informed members accordingly?
It appears that those that will not be affected by this policy or those who already have large IPv4 blocks are some of the largest proponents of it - which makes sense. It is easy to vote for a change if it's only others that will be affected.
However, there are a large number of SME businesses out there who rely on these leases to run their operations. For them, this isn't just some merely intellectual exercise. Rather, it's a question of hundreds of thousands, or even millions, of dollars.
It's their ability to remain operational. It's their employees' livelihoods and those of their families. It's a core part of how they operate and for many, the foundation which they've built their business on.
This policy change seems to almost be a 'policy for policies sake'. It is clear that the repercussions of this were either not considered, or not even known, as the policy notes listed 'nil' negative effects. That this is the opinion of APNIC (and it seems, of a significant portion of the community) is incredibly concerning, because it couldn't be further from the truth.
Many real businesses will be affected by this, with real people. And the flippancy with which many within APNIC are treating this proposal shows a concerning lack of empathy towards that - and a failure to grasp the nature of IPv4 addresses as a modern asset class.
Without the above questions answered, I don't see how this policy vote can go ahead - and I would implore everyone considering this policy to reject it outright. There may be issues with the current IPv4 paradigm but this is definitely not the solution.
Kind Regards
Matt Shearing Chief Executive Officer
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From: Mike Burns mike@iptrading.commailto:mike@iptrading.com Sent: Thursday, 8 September 2022 6:52 AM To: 'Fernando Frediani' fhfrediani@gmail.commailto:fhfrediani@gmail.com; sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Alas, Fernando, there is no alternative “drug” for people to live without IPv4.
Banning leasing hurts the smallest and poorest of companies most.
And you cannot elucidate any “major damages” suffered where leasing has actually, in reality, occurred for many years at RIPE.
Yet you use this evidence-free assertion as your major argument against leasing.
That some kind of serious damage will occur to the RIR system.
As a broker who as to talk to actual, real companies in need, who can’t afford to pay upfront, can you tell me what I should say when they ask me why leasing is forbidden? If I say it’s to avoid “major damages” and they ask what they are, can you tell me?
What major damages?
Regards, Mike
From: Fernando Frediani <fhfrediani@gmail.commailto:fhfrediani@gmail.com> Sent: Wednesday, September 7, 2022 4:33 PM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Do you understand the argument that certain drugs can alleviate certain pains but they remain forbidden because they cause a major damage to society in long term and there are alternatives for people be able to still live without have to use those type of damageable mechanisms. Companies can also live without that and still have other legally allowed mechanisms.
This discussion is unnecessary for this policy discussion as what it proposes is to make something *already forbidden* clear in to the text, not to discuss if leasing should exist or not.
If anyone opposes it please take attention to provide arguments and suggestions on how to address the issues raised about what the proposal really proposes.
Regards Fernando
On 07/09/2022 14:12, Mike Burns wrote:
Hi Fernando,
Do you understand my argument that smaller business cannot afford the full upfront payment but can afford monthly lease payments?
Please address that simple argument by telling me how the small business benefits by not having the lease option, but only having the purchase option.
Regards, Mike
From: Fernando Frediani fhfrediani@gmail.commailto:fhfrediani@gmail.com Sent: Wednesday, September 7, 2022 1:01 PM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
IP Leasing is already banned in most RIRs and should stay as is.
But yes it does help as it doesn't push even further up IPv4 pricing and makes it easier for these small companies to get IPv4 via the proper and allowed way which are transfers. Other then diverting totally the propose o IPv4 Allocation, Leasing market contributes significantly to price increasing fueling the market with more demand for that type of very wrong thing.
RIPE is normally not a good example for certain policies which don't seem to have receptivity in discussions on all other RIRs.
There are still mechanisms that allow companies to get IP addressing either directly from the RIR, via Transfers which is a pretty common way or from the Upstream providers. People may not have got used yet to learn to live with less address and they may believe they need a bunch of address.
IP Leasing will never help small companies. The ones who really benefit from it are the IP broker companies who profit from them and also the resource holders which don't justify anymore to keep those addresses and are also profiting from something that should have been re-assigned directly to those who really need and justify for them in order to build Internet Infrastructure and Connectivity and instead are leasing a asset they don't own.
Fernando
On 07/09/2022 12:39, Mike Burns wrote:
Hi Fernando,
So your argument is that banning leasing actually helps smaller companies in their quest for IPv4?
Are you aware that RIPE has allowed leasing for many years but is still a functioning RIR whose IPv4 sale prices are not more expensive despite the history of leasing there?
Can you reconcile that with your argument that leasing will raise prices for both leasing and transfers?
Are you aware that it’s not always possible to get IPv4 blocks from the company that is providing you with connectivity?
Regards, Mike
From: Fernando Frediani fhfrediani@gmail.commailto:fhfrediani@gmail.com Sent: Wednesday, September 7, 2022 11:27 AM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
This is exactly the opposite.
Allowing IP leasing to happen more than just tottaly divert the propose of IP assignments by RIRs it make it bad specially for smaller companies as it increases the cost for both leasing and transfers in long term. The cost of leasing is based on the transfer and if leasing is allowed then transfer prices will always go up which makes it even harder for smaller companies to go into the market.
Any form of IP leasing without a direct connection relationship to provide a connectivity service makes it more expensive for smaller companies to get IP addresses to operate.
Fernando
On 07/09/2022 11:15, Mike Burns wrote:
Hi Jordi,
It’s plain you feel that we should do all possible to raise the price of IPv4 and make it unattainable for small business in the vain hope that this will drive IPv6 adoption.
I don’t think making IPv4 more difficult to acquire is the job of the RIR system.
You have not addressed the inability of smaller companies to acquire necessary IPv4 blocks if you ban leasing.
Is that something you are comfortable with, in pursuit of the IPv6 grail?
It’s okay with you that this policy prevents small companies from growing?
Regards, Mike
From: JORDI PALET MARTINEZ via sig-policy sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Sent: Wednesday, September 7, 2022 10:11 AM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Actually, I must disagree …
If organizations having unused resources, they need to transfer them or return them to the RIR. If prices keep going high, that could encourage faster IPv6 adoption, then transfer prices will go down, up to “no value”. It takes time, but it is just market.
Those that have more money, have more facilities to do a faster transition and not bother about IPv4.
Regards,
Jordi
@jordipalet
El 7/9/22, 16:05, "Mike Burns" <mike@iptrading.commailto:mike@iptrading.com> escribió:
Hello,
Per Gaurav’s statement that “only those with millions of dollars can think of getting ips”, this community should oppose this policy.
Because the only way small companies can afford to get ips today is by leasing them. The same way the small company can’t afford to purchase a big office building but instead rents an office. Leasing is the only way to finance IPv4 acquisitions today. No bank or other entity that I am aware of will do it. Purchasing addresses requires full upfront payment, but leasing allow for much smaller monthly payments.
If this community wants to ensure only the largest and richest companies can acquire new addresses, ban leasing.
But if the community tries to ban something with such a large business motivation behind it, it will find itself struggling against a powerful foe.
And for what purpose do we punish the small businesses? Leasing puts addresses in the hands of those who need them to build and operate networks. Isn’t that the primary goal of the RIR system?
Regards,
Mike
El 2/9/22, 9:23, "Gaurav Kansal" <gaurav.kansal@nic.inmailto:gaurav.kansal@nic.in> escribió:
Hello everyone,
In my opinion, even Trading of IPs (leave apart the lease for making dollars) in the name of transfers must be stopped.
If organisation doesn’t need IPs , then those must be returned back so that smaller organisations can get it from the RIR.
Currently, only the one which have millions of dollars can think of getting IPs. In today’s scenario, no one can start the Data Centre, ISP business without investing millions in IPs. Even education and research org doesn’t have an option to get IPs from RIR.
This is like horse trading and isn’t a good practice for the community as a whole.
Regards,
Gaurav Kansal
On 02-Sep-2022, at 12:20, rajesh@smartlinkindia.commailto:rajesh@smartlinkindia.com wrote:
Dear Team,
As Mr. Satoru, mentioned there are changes, but if carefully implemented in phased manner, unauthorised leasing can be stopped.
For example in first phase, leasing among countries can be stopped, if the owner company doesn't provide any services beyond its home country. For example if a company in India doesn't have any operation in Singapore or Japan , can't lease resources to those companies in Singapore or Japan. This can be verified by taking business registration documents of both lease and lessor.
Once this is done same may be granularized at RIR level, where in country like India, leasing can be restricted to the licensed service area for service provider within their designated service area.
This may stop majority of issues, barring few exceptions.
Some more brainstorming is required for better understanding and precise implementation.
Regards,
Rajesh Panwala
For Smartlink Solutions Pvt Ltd
+91-9227886001
+91-9426110781
On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru <stsuruma@bbix.netmailto:stsuruma@bbix.net> wrote:
Dear Colleagues,
I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team..
I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals.
Many participants support the intent of the proposal but felt that implementation would be challenging.
(comment details) - It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses. - I think this proposal would be useful if the concept of leasing is accurately defined. - Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement.
Regards,
Satoru Tsurumaki / JPOPF Steering Team
2022年8月26日(金) 17:27 Shaila Sharmin <shaila.sharmin.ovi@gmail.commailto:shaila.sharmin.ovi@gmail.com>:
Dear SIG members,
A new version of the proposal "prop-148-v002: Clarification - Leasing of Resources is not Acceptable" has been sent to the Policy SIG for review.
Information about earlier versions is available from:
http://www.apnic.net/policy/proposals/prop-148
You are encouraged to express your views on the proposal:
- Do you support or oppose the proposal?
- Is there anything in the proposal that is not clear?
- What changes could be made to this proposal to make it more effective?
Please find the text of the proposal below.
Regards, Bertrand, Shaila, and Ching-Heng APNIC Policy SIG Chairs
prop-148-v002: Clarification - Leasing of Resources is not Acceptable
Proposer: Jordi Palet Martinez (jordi.palet@theipv6company.comAnupammailto:jordi.palet@theipv6company.comAnupam) Amrita Choudhury (amritachoudhury@ccaoi.inmailto:amritachoudhury@ccaoi.in) Fernando Frediani (fhfredani@gmail.commailto:fhfredani@gmail.com)
- Problem statement
RIRs have been conceived to manage, allocate and assign resources according to need, in such a 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 delegated by APNIC or an NIR, the justification of the need implies the need to use on their own infrastructure and/or network connectivity services provided directly to customers. As a result, any form of IP address leasing is unacceptable, 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.
APNIC may proactively investigate those cases and also initiate the investigation in case of reports by means of a form, email address or other means developed by APNIC.
If any form of leasing, regardless of when the delegation has been issued, is confirmed by an APNIC investigation, it will be considered a policy violation and revocation may apply against any account holders who are leasing or using them for any purposes not specified in the initial request.
- Advantages / Disadvantages
Advantages: Fulfilling the objective above indicated and making the policy clear.
Disadvantages: None.
- Impact on resource holders
None.
- 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 _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.netmailto:sig-policy-leave@lists.apnic.net
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Hi Matt, I am sorry but I don't really take some of these emotional arguments because they are created mostly by the ones who are most taking advantage from it. There are ways in the *real* world but there are also adjustments that must be made and many still seem to not have realized after a while. One thing I find it wrong is to blame APNIC for it and suggesting they should not stop this, despite the illegality presented and therefore the unfairness with the whole of community impacted.
It seems interesting however your idea of some tentative to transfer resources definitely to smaller companies, but not only from the larger holders but from *any* holder who is leasing them. In order words an idea of a proposal could be to allow a company who leases from a resources holders to have those resources forcibly transferred definitely to them regardless the permission of the resources holder if a leasing it shown to be happening there.
Sorry to disagree, but appealing to leasing as the only option available at this stage is a easy path to make it worst a scenario that is only causing more and more unfairness to all. If it is wrong - and it is - it must be stopped *right now* and how to act about what exists should be carried on being discussed (in another thread) in order to help APNIC how to deal with cases properly and have all the support it may require.
Regards Fernando
On 07/09/2022 23:39, Matthew Shearing wrote:
Fernando, very simply – if it was already against the rules, why this policy? There should be no need for clarification if this was already ‘illegal’ or ‘against the rules’ as you say. What is the point of this policy if it’s already clear?
Further, you keep talking about IPv4 exhaustion and that we need to ‘deal with it’. The fact there exists a leasing market in the first place means that there are plenty of unused IPv4 resources. Otherwise, there would be no IPv4 addresses to lease.
If APNIC wants to tackle ‘misuse’, that is also fine. However, why not start with those who have plenty of IP space? Why not build in guarantees that APNIC it revokes space from a large holder, any lessees currently using that space will get access to those IPv4 addresses, as they are the ones using them? Why is none of this even being discussed? It’s incredibly obvious this policy hurts mainly the smaller companies, by going after /leases/, not the big holdings themselves.
By saying /‘there are ways to get blocks’/ also tells me very clearly that you’ve either not tried recently, or you’re just willfully ignorant. For many companies, leasing is the only feasible ways to get blocks because we are priced out.
Ideologically, we are all in agreement that an IPv6 world would be amazing. Unfortunately, those of us running businesses need to exist here in the real world, not in your imaginary world where we get everything we would like. If you want to help change that, we’ll all be here, cheering you on. Until then, businesses like ours don’t have the luxury of sitting around wishing – we’ve got customers we need to serve and employees we need to pay.
These ‘emotional’ arguments are common because they are */real/*. They are for businesses that exist in the real world, in an IP environment that APNIC (and other registrars) created. APNIC allowed the leasing paradigm to occur and did nothing about it. This is not some new thing – it is a mature market that has existed for a long time.
It is incredibly irresponsible for APNIC to try and roll it back now, after many years of inaction, and disingenuous for people like you to somehow claim businesses that are just trying to do the best they can in the environment we currently have are somehow at fault. This problem can be laid squarely at the feet of APNIC – and for that reason, it can and will be held liable by those damaged if any changes are made now.
This policy is approaching everything from the wrong direction. Its implementation will punish the smallest businesses while doing nothing about the largest legacy holders. If APNIC is serious about the IPv4 allocation issue, it should start with the swathes of latent resources and move backwards. This should be tempered by protections and policies which ensure smaller businesses aren’t ruined in the process. Maybe once that is solved, in several years time, it will be time to revisit this topic. For now though, this is far too premature.
The reality is this – for many of us, leasing is right now the only viable option. Taking that away without proposing any kind of genuine alternatives (ie not the handwavium generalisations you’ve been engaging in) is reckless and will result in incredible damage to members who have simply been doing their best in an environment APNIC created in the first place.
Cheers,
*Matt Shearing* *Chief Executive Officer*
Brisbane, Australia (AEST) • matt@oneqode.com mailto:matt@oneqode.com • +61 406 778 038
OneQode™ https://www.oneqode.com/
Follow us on LinkedIn https://www.linkedin.com/company/oneqode/
*From:* Fernando Frediani fhfrediani@gmail.com *Sent:* Thursday, 8 September 2022 12:15 PM *To:* sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Unfortunately this shows a tentative to discuss something with lack of enough important information about the topic and also there was not proper follow of most of this thread discussion.
First Internet Resources are not irrevocable assets that anyone who holds them can do whatever they like as if they own them. Unfortunately many people in this industry still don't know, but the fact that organizations hold a resource assigned to them does not mean they own it and therefore they must operate them under certain rules otherwise they risk to have them revoked, therefore they cannot be treated as an asset you purchased and may do whatever you like with it. If you purchase a server or a router it is yours and you sell or lease it for whatever amount you wish, but not with internet resources because you don't own them.
It is unimportant that anything APNIC may do against those who using IPv4 blocks illegally and may have them revoked because they should never have used in that way in first instance. A while back, when they became members they have signed a contract agreeing they would use the resources according to the rules. Therefore if someone decided to do out of what has been previously agreed they did it in their own risk and cannot allege they are "being affected".
Regardless how market evolves APNIC has full rights to revoke resources from members who are misusing resources not in accordance with the contracts they have signed and agreed. And by doing that APNIC is protecting community interests in detriment to individual and very specific interests that wants to use internet resources for proposes they were never conceived for.
Seems that people still didn't accept IPv4 exhaustion and keep hoping for something that will never come instead of learn once for all how to deal with it. There are ways to get blocks, for example via transfers and other specific methods, but the scenario many were used for decades doesn't exist anymore and still seems people keep trying to make up stuff to benefit their own specific interest in detriment of everybody else and of the fairness with everybody involved. If a company doesn't have enough money to afford a transfer I am sorry, but that is the new reality for a while. Learn how to deal with it and use other alternatives available like getting from upstreams - who provide connectivity - until there is budget to get address via a transfer for example. And not less important, stop hiding from IPv6 saying that will not revolve.
APNIC has all rights to fight in courts and is fully legally covered to enforce what members using internet resources signed and agreed for. Hardly judges will overwrite such agreement because they fell sorry that some people still didn't accept and learned to live with IPv4 exhaustion. No 'difficult' scenario gives the right to a member to void a contract they signed and agreed and win that in court.
These 'emotional arguments' of people and companies that will suffer if no leasing is allowed is a common argument from organizations who profit from IP leasing and don't build any internet connectivity and is already old one. If people keep insisting in doing things out of the rules sooner or later they will have to pay the price and they should know the risk before they even started.
IP addresses were not made to be rented from a resource holder who don't need them anymore to one that needs and could get them directly from the RIR. Regardless of the most noble reason, going against the rules doesn't make they valid.
Fernando
On 07/09/2022 22:49, Matthew Shearing wrote:
Just wanted to chime in here and follow up on Mike's point (and those of several others). What APNIC has done by its previous conduct is create a scarce asset collected in the hands of a number of large providers, with increasingly less being issued to small providers. As with any scarce asset in human history, this necessarily creates all the prerequisites for a fee market. Just like real estate, vehicles and other commodities, leasing is a natural evolution of scarcity in an asset class with direct utility. Right now, IPv4 blocks are like houses - some own them, but some don't have the capital resources to outright own the amount they need. Simply looking at the prices which IPv4 blocks are going for on the open market will make it clear that many smaller businesses are priced out. Leasing represents a viable option for companies to access the blocks they need and pay manageable, monthly or yearly payments for the use of those blocks. Many businesses are reliant on these currently. Saying that APNIC will outright ban leasing and that this will somehow benefit businesses is abjectly false. Not only will it disrupt many current business operations, but there is no guarantee that a market with more perverse incentives won't emerge afterwards. In our view, APNIC has already demonstrated by its statements and conduct with this policy that they have little grasp on how (and why) asset markets evolve. They've also done nothing to dissuade us that the new 'status quo' after this policy change won't be worse than the current one - which operates relatively fine. Practically, for APNIC to say there will be no meaningful damage to current users and businesses (who are APNIC members in their own right) it must answer the following questions: 1. What alternative does APNIC propose to the current IPv4 market and particularly, leasing options available to smaller companies and new entrants? 2. How will terminating leases currently on foot result in a better outcome for the businesses currently relying on them? 3. How will new IPv4 addresses be allocated, what timeframes and costs will be involved in this allocation? 4. Can APNIC give guarantees to current lessees who are reliant on IPv4 address leases that they can continue to access those addresses or will have replacements of similar value, at less cost, instantly after the change is made? 5. Is APNIC prepared to be held liable in lawsuits or a class action for the damages incurred by this policy change? Has it considered this risk and informed members accordingly? It appears that those that will not be affected by this policy or those who already have large IPv4 blocks are some of the largest proponents of it - which makes sense. It is easy to vote for a change if it's only others that will be affected. However, there are a large number of SME businesses out there who rely on these leases to run their operations. For them, this isn't just some merely intellectual exercise. Rather, it's a question of hundreds of thousands, or even millions, of dollars. It's their ability to remain operational. It's their employees' livelihoods and those of their families. It's a core part of how they operate and for many, the foundation which they've built their business on. This policy change seems to almost be a /'policy for policies sake'/. It is clear that the repercussions of this were either not considered, or not even known, as the policy notes listed 'nil' negative effects. That this is the opinion of APNIC (and it seems, of a significant portion of the community) is incredibly concerning, because it couldn't be further from the truth. Many real businesses will be affected by this, with real people. And the flippancy with which many within APNIC are treating this proposal shows a concerning lack of empathy towards that - and a failure to grasp the nature of IPv4 addresses as a modern asset class. Without the above questions answered, I don't see how this policy vote can go ahead - and I would implore everyone considering this policy to reject it outright. There may be issues with the current IPv4 paradigm but this is definitely not the solution. Kind Regards *Matt Shearing* *Chief Executive Officer* Brisbane, Australia (AEST) • matt@oneqode.com <mailto:matt@oneqode.com> • +61 406 778 038 OneQode™ <https://www.oneqode.com/> Follow us on LinkedIn <https://www.linkedin.com/company/oneqode/> *From:* Mike Burns <mike@iptrading.com> <mailto:mike@iptrading.com> *Sent:* Thursday, 8 September 2022 6:52 AM *To:* 'Fernando Frediani' <fhfrediani@gmail.com> <mailto:fhfrediani@gmail.com>; sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable Alas, Fernando, there is no alternative “drug” for people to live without IPv4. Banning leasing hurts the smallest and poorest of companies most. And you cannot elucidate any “major damages” suffered where leasing has actually, in reality, occurred for many years at RIPE. Yet you use this evidence-free assertion as your major argument against leasing. That some kind of serious damage will occur to the RIR system. As a broker who as to talk to actual, real companies in need, who can’t afford to pay upfront, can you tell me what I should say when they ask me why leasing is forbidden? If I say it’s to avoid “major damages” and they ask what they are, can you tell me? What major damages? Regards, Mike *From:* Fernando Frediani <fhfrediani@gmail.com> *Sent:* Wednesday, September 7, 2022 4:33 PM *To:* sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable Do you understand the argument that certain drugs can alleviate certain pains but they remain forbidden because they cause a major damage to society in long term and there are alternatives for people be able to still live without have to use those type of damageable mechanisms. Companies can also live without that and still have other legally allowed mechanisms. This discussion is unnecessary for this policy discussion as what it proposes is to make something *already forbidden* clear in to the text, not to discuss if leasing should exist or not. If anyone opposes it please take attention to provide arguments and suggestions on how to address the issues raised about what the proposal really proposes. Regards Fernando On 07/09/2022 14:12, Mike Burns wrote: Hi Fernando, Do you understand my argument that smaller business cannot afford the full upfront payment but can afford monthly lease payments? Please address that simple argument by telling me how the small business benefits by not having the lease option, but only having the purchase option. Regards, Mike *From:* Fernando Frediani <fhfrediani@gmail.com> <mailto:fhfrediani@gmail.com> *Sent:* Wednesday, September 7, 2022 1:01 PM *To:* sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable IP Leasing is already banned in most RIRs and should stay as is. But yes it does help as it doesn't push even further up IPv4 pricing and makes it easier for these small companies to get IPv4 via the proper and allowed way which are transfers. Other then diverting totally the propose o IPv4 Allocation, Leasing market contributes significantly to price increasing fueling the market with more demand for that type of very wrong thing. RIPE is normally not a good example for certain policies which don't seem to have receptivity in discussions on all other RIRs. There are still mechanisms that allow companies to get IP addressing either directly from the RIR, via Transfers which is a pretty common way or from the Upstream providers. People may not have got used yet to learn to live with less address and they may believe they need a bunch of address. IP Leasing will never help small companies. The ones who really benefit from it are the IP broker companies who profit from them and also the resource holders which don't justify anymore to keep those addresses and are also profiting from something that should have been re-assigned directly to those who really need and justify for them in order to build Internet Infrastructure and Connectivity and instead are leasing a asset they don't own. Fernando On 07/09/2022 12:39, Mike Burns wrote: Hi Fernando, So your argument is that banning leasing actually helps smaller companies in their quest for IPv4? Are you aware that RIPE has allowed leasing for many years but is still a functioning RIR whose IPv4 sale prices are not more expensive despite the history of leasing there? Can you reconcile that with your argument that leasing will raise prices for both leasing and transfers? Are you aware that it’s not always possible to get IPv4 blocks from the company that is providing you with connectivity? Regards, Mike *From:* Fernando Frediani <fhfrediani@gmail.com> <mailto:fhfrediani@gmail.com> *Sent:* Wednesday, September 7, 2022 11:27 AM *To:* sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable This is exactly the opposite. Allowing IP leasing to happen more than just tottaly divert the propose of IP assignments by RIRs it make it bad specially for smaller companies as it increases the cost for both leasing and transfers in long term. The cost of leasing is based on the transfer and if leasing is allowed then transfer prices will always go up which makes it even harder for smaller companies to go into the market. Any form of IP leasing without a direct connection relationship to provide a connectivity service makes it more expensive for smaller companies to get IP addresses to operate. Fernando On 07/09/2022 11:15, Mike Burns wrote: Hi Jordi, It’s plain you feel that we should do all possible to raise the price of IPv4 and make it unattainable for small business in the vain hope that this will drive IPv6 adoption. I don’t think making IPv4 more difficult to acquire is the job of the RIR system. You have not addressed the inability of smaller companies to acquire necessary IPv4 blocks if you ban leasing. Is that something you are comfortable with, in pursuit of the IPv6 grail? It’s okay with you that this policy prevents small companies from growing? Regards, Mike *From:* JORDI PALET MARTINEZ via sig-policy <sig-policy@lists.apnic.net> <mailto:sig-policy@lists.apnic.net> *Sent:* Wednesday, September 7, 2022 10:11 AM *To:* sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable Actually, I must disagree … If organizations having unused resources, they need to transfer them or return them to the RIR. If prices keep going high, that could encourage faster IPv6 adoption, then transfer prices will go down, up to “no value”. It takes time, but it is just market. Those that have more money, have more facilities to do a faster transition and not bother about IPv4. Regards, Jordi @jordipalet El 7/9/22, 16:05, "Mike Burns" <mike@iptrading.com> escribió: Hello, Per Gaurav’s statement that “only those with millions of dollars can think of getting ips”, this community should oppose this policy. Because the only way small companies can afford to get ips today is by leasing them. The same way the small company can’t afford to purchase a big office building but instead rents an office. Leasing is the only way to finance IPv4 acquisitions today. No bank or other entity that I am aware of will do it. Purchasing addresses requires full upfront payment, but leasing allow for much smaller monthly payments. If this community wants to ensure only the largest and richest companies can acquire new addresses, ban leasing. But if the community tries to ban something with such a large business motivation behind it, it will find itself struggling against a powerful foe. And for what purpose do we punish the small businesses? Leasing puts addresses in the hands of those who need them to build and operate networks. Isn’t that the primary goal of the RIR system? Regards, Mike El 2/9/22, 9:23, "Gaurav Kansal" <gaurav.kansal@nic.in> escribió: Hello everyone, In my opinion, even Trading of IPs (leave apart the lease for making dollars) in the name of transfers must be stopped. If organisation doesn’t need IPs , then those must be returned back so that smaller organisations can get it from the RIR. Currently, only the one which have millions of dollars can think of getting IPs. In today’s scenario, no one can start the Data Centre, ISP business without investing millions in IPs. Even education and research org doesn’t have an option to get IPs from RIR. This is like horse trading and isn’t a good practice for the community as a whole. Regards, Gaurav Kansal On 02-Sep-2022, at 12:20, rajesh@smartlinkindia.com wrote: Dear Team, As Mr. Satoru, mentioned there are changes, but if carefully implemented in phased manner, unauthorised leasing can be stopped. For example in first phase, leasing among countries can be stopped, if the owner company doesn't provide any services beyond its home country. For example if a company in India doesn't have any operation in Singapore or Japan , can't lease resources to those companies in Singapore or Japan. This can be verified by taking business registration documents of both lease and lessor. Once this is done same may be granularized at RIR level, where in country like India, leasing can be restricted to the licensed service area for service provider within their designated service area. This may stop majority of issues, barring few exceptions. Some more brainstorming is required for better understanding and precise implementation. Regards, Rajesh Panwala For Smartlink Solutions Pvt Ltd +91-9227886001 +91-9426110781 On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru <stsuruma@bbix.net> wrote: Dear Colleagues, I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team.. I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals. Many participants support the intent of the proposal but felt that implementation would be challenging. (comment details) - It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses. - I think this proposal would be useful if the concept of leasing is accurately defined. - Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement. Regards, Satoru Tsurumaki / JPOPF Steering Team 2022年8月26日(金) 17:27 Shaila Sharmin <shaila.sharmin.ovi@gmail.com>: > > Dear SIG members, > > A new version of the proposal "prop-148-v002: Clarification - Leasing of > Resources is not Acceptable" has been sent to the Policy SIG for review. > > Information about earlier versions is available from: > > http://www.apnic.net/policy/proposals/prop-148 > > You are encouraged to express your views on the proposal: > > - Do you support or oppose the proposal? > - Is there anything in the proposal that is not clear? > - What changes could be made to this proposal to make it more effective? > > Please find the text of the proposal below. > > Regards, > Bertrand, Shaila, and Ching-Heng > APNIC Policy SIG Chairs > > > ---------------------------------------------------------------------- > prop-148-v002: Clarification - 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 a 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 delegated by APNIC or an NIR, > the justification of the need implies the need to use on their own > infrastructure and/or network connectivity services provided directly to > customers. As a result, any form of IP address leasing is unacceptable, > 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. > > APNIC may proactively investigate those cases and also initiate the > investigation in case of reports by means of a form, email address or > other means developed by APNIC. > > If any form of leasing, regardless of when the delegation has been > issued, is confirmed by an APNIC investigation, it will be considered a > policy violation and revocation may apply against any account holders > who are leasing or using them for any purposes not specified in the > initial request. > > > 5. Advantages / Disadvantages > ----------------------------- > Advantages: > Fulfilling the objective above indicated and making the policy clear. > > Disadvantages: > None. > > > 6. Impact on resource holders > ----------------------------- > None. > > > 7. References > ------------- > https://www.arin.net/participate/policy/proposals/2022/ARIN_prop_308_v2/ > https://politicas.lacnic.net/politicas/detail/id/LAC-2022-2/language/en > _______________________________________________ > sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ > To unsubscribe send an email to sig-policy-leave@lists.apnic.net -- -- Satoru Tsurumaki BBIX, Inc _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.net _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.net <https://amritmahotsav.nic.in/> _______________________________________________ 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. 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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 tosig-policy-leave@lists.apnic.net
In response to your last paragaph
Can the secretariat confirm:
* they have an issue with enforcement now * They have an active need that they are unable to address under this framework * That the current membership agreement is inadequate to allow them to fulfil the tasks they have
Your statements infer that there is an issue, they can’t enforce behaviour and that the current policies are inadequate. I’m yet to see any evidence of this.
Andre
Get Outlook for iOShttps://aka.ms/o0ukef ________________________________ From: Fernando Frediani fhfrediani@gmail.com Sent: Thursday, September 8, 2022 1:01:40 PM To: sig-policy@lists.apnic.net sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Hi Matt, I am sorry but I don't really take some of these emotional arguments because they are created mostly by the ones who are most taking advantage from it. There are ways in the *real* world but there are also adjustments that must be made and many still seem to not have realized after a while. One thing I find it wrong is to blame APNIC for it and suggesting they should not stop this, despite the illegality presented and therefore the unfairness with the whole of community impacted.
It seems interesting however your idea of some tentative to transfer resources definitely to smaller companies, but not only from the larger holders but from *any* holder who is leasing them. In order words an idea of a proposal could be to allow a company who leases from a resources holders to have those resources forcibly transferred definitely to them regardless the permission of the resources holder if a leasing it shown to be happening there.
Sorry to disagree, but appealing to leasing as the only option available at this stage is a easy path to make it worst a scenario that is only causing more and more unfairness to all. If it is wrong - and it is - it must be stopped *right now* and how to act about what exists should be carried on being discussed (in another thread) in order to help APNIC how to deal with cases properly and have all the support it may require.
Regards Fernando
On 07/09/2022 23:39, Matthew Shearing wrote:
Fernando, very simply – if it was already against the rules, why this policy? There should be no need for clarification if this was already ‘illegal’ or ‘against the rules’ as you say. What is the point of this policy if it’s already clear?
Further, you keep talking about IPv4 exhaustion and that we need to ‘deal with it’. The fact there exists a leasing market in the first place means that there are plenty of unused IPv4 resources. Otherwise, there would be no IPv4 addresses to lease.
If APNIC wants to tackle ‘misuse’, that is also fine. However, why not start with those who have plenty of IP space? Why not build in guarantees that APNIC it revokes space from a large holder, any lessees currently using that space will get access to those IPv4 addresses, as they are the ones using them? Why is none of this even being discussed? It’s incredibly obvious this policy hurts mainly the smaller companies, by going after leases, not the big holdings themselves.
By saying ‘there are ways to get blocks’ also tells me very clearly that you’ve either not tried recently, or you’re just willfully ignorant. For many companies, leasing is the only feasible ways to get blocks because we are priced out.
Ideologically, we are all in agreement that an IPv6 world would be amazing. Unfortunately, those of us running businesses need to exist here in the real world, not in your imaginary world where we get everything we would like. If you want to help change that, we’ll all be here, cheering you on. Until then, businesses like ours don’t have the luxury of sitting around wishing – we’ve got customers we need to serve and employees we need to pay.
These ‘emotional’ arguments are common because they are real. They are for businesses that exist in the real world, in an IP environment that APNIC (and other registrars) created. APNIC allowed the leasing paradigm to occur and did nothing about it. This is not some new thing – it is a mature market that has existed for a long time.
It is incredibly irresponsible for APNIC to try and roll it back now, after many years of inaction, and disingenuous for people like you to somehow claim businesses that are just trying to do the best they can in the environment we currently have are somehow at fault. This problem can be laid squarely at the feet of APNIC – and for that reason, it can and will be held liable by those damaged if any changes are made now.
This policy is approaching everything from the wrong direction. Its implementation will punish the smallest businesses while doing nothing about the largest legacy holders. If APNIC is serious about the IPv4 allocation issue, it should start with the swathes of latent resources and move backwards. This should be tempered by protections and policies which ensure smaller businesses aren’t ruined in the process. Maybe once that is solved, in several years time, it will be time to revisit this topic. For now though, this is far too premature.
The reality is this – for many of us, leasing is right now the only viable option. Taking that away without proposing any kind of genuine alternatives (ie not the handwavium generalisations you’ve been engaging in) is reckless and will result in incredible damage to members who have simply been doing their best in an environment APNIC created in the first place.
Cheers,
Matt Shearing Chief Executive Officer
[https://www.oneqode.com/img/email-pin.png]
Brisbane, Australia (AEST) • matt@oneqode.commailto:matt@oneqode.com • +61 406 778 038
[OneQode™]https://www.oneqode.com/
[Follow us on LinkedIn]https://www.linkedin.com/company/oneqode/
From: Fernando Frediani fhfrediani@gmail.commailto:fhfrediani@gmail.com Sent: Thursday, 8 September 2022 12:15 PM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Unfortunately this shows a tentative to discuss something with lack of enough important information about the topic and also there was not proper follow of most of this thread discussion.
First Internet Resources are not irrevocable assets that anyone who holds them can do whatever they like as if they own them. Unfortunately many people in this industry still don't know, but the fact that organizations hold a resource assigned to them does not mean they own it and therefore they must operate them under certain rules otherwise they risk to have them revoked, therefore they cannot be treated as an asset you purchased and may do whatever you like with it. If you purchase a server or a router it is yours and you sell or lease it for whatever amount you wish, but not with internet resources because you don't own them.
It is unimportant that anything APNIC may do against those who using IPv4 blocks illegally and may have them revoked because they should never have used in that way in first instance. A while back, when they became members they have signed a contract agreeing they would use the resources according to the rules. Therefore if someone decided to do out of what has been previously agreed they did it in their own risk and cannot allege they are "being affected".
Regardless how market evolves APNIC has full rights to revoke resources from members who are misusing resources not in accordance with the contracts they have signed and agreed. And by doing that APNIC is protecting community interests in detriment to individual and very specific interests that wants to use internet resources for proposes they were never conceived for.
Seems that people still didn't accept IPv4 exhaustion and keep hoping for something that will never come instead of learn once for all how to deal with it. There are ways to get blocks, for example via transfers and other specific methods, but the scenario many were used for decades doesn't exist anymore and still seems people keep trying to make up stuff to benefit their own specific interest in detriment of everybody else and of the fairness with everybody involved. If a company doesn't have enough money to afford a transfer I am sorry, but that is the new reality for a while. Learn how to deal with it and use other alternatives available like getting from upstreams - who provide connectivity - until there is budget to get address via a transfer for example. And not less important, stop hiding from IPv6 saying that will not revolve.
APNIC has all rights to fight in courts and is fully legally covered to enforce what members using internet resources signed and agreed for. Hardly judges will overwrite such agreement because they fell sorry that some people still didn't accept and learned to live with IPv4 exhaustion. No 'difficult' scenario gives the right to a member to void a contract they signed and agreed and win that in court.
These 'emotional arguments' of people and companies that will suffer if no leasing is allowed is a common argument from organizations who profit from IP leasing and don't build any internet connectivity and is already old one. If people keep insisting in doing things out of the rules sooner or later they will have to pay the price and they should know the risk before they even started.
IP addresses were not made to be rented from a resource holder who don't need them anymore to one that needs and could get them directly from the RIR. Regardless of the most noble reason, going against the rules doesn't make they valid.
Fernando
On 07/09/2022 22:49, Matthew Shearing wrote:
Just wanted to chime in here and follow up on Mike's point (and those of several others).
What APNIC has done by its previous conduct is create a scarce asset collected in the hands of a number of large providers, with increasingly less being issued to small providers. As with any scarce asset in human history, this necessarily creates all the prerequisites for a fee market.
Just like real estate, vehicles and other commodities, leasing is a natural evolution of scarcity in an asset class with direct utility. Right now, IPv4 blocks are like houses - some own them, but some don't have the capital resources to outright own the amount they need. Simply looking at the prices which IPv4 blocks are going for on the open market will make it clear that many smaller businesses are priced out.
Leasing represents a viable option for companies to access the blocks they need and pay manageable, monthly or yearly payments for the use of those blocks. Many businesses are reliant on these currently.
Saying that APNIC will outright ban leasing and that this will somehow benefit businesses is abjectly false. Not only will it disrupt many current business operations, but there is no guarantee that a market with more perverse incentives won't emerge afterwards.
In our view, APNIC has already demonstrated by its statements and conduct with this policy that they have little grasp on how (and why) asset markets evolve. They've also done nothing to dissuade us that the new 'status quo' after this policy change won't be worse than the current one - which operates relatively fine.
Practically, for APNIC to say there will be no meaningful damage to current users and businesses (who are APNIC members in their own right) it must answer the following questions:
1. What alternative does APNIC propose to the current IPv4 market and particularly, leasing options available to smaller companies and new entrants? 2. How will terminating leases currently on foot result in a better outcome for the businesses currently relying on them? 3. How will new IPv4 addresses be allocated, what timeframes and costs will be involved in this allocation? 4. Can APNIC give guarantees to current lessees who are reliant on IPv4 address leases that they can continue to access those addresses or will have replacements of similar value, at less cost, instantly after the change is made? 5. Is APNIC prepared to be held liable in lawsuits or a class action for the damages incurred by this policy change? Has it considered this risk and informed members accordingly?
It appears that those that will not be affected by this policy or those who already have large IPv4 blocks are some of the largest proponents of it - which makes sense. It is easy to vote for a change if it's only others that will be affected.
However, there are a large number of SME businesses out there who rely on these leases to run their operations. For them, this isn't just some merely intellectual exercise. Rather, it's a question of hundreds of thousands, or even millions, of dollars.
It's their ability to remain operational. It's their employees' livelihoods and those of their families. It's a core part of how they operate and for many, the foundation which they've built their business on.
This policy change seems to almost be a 'policy for policies sake'. It is clear that the repercussions of this were either not considered, or not even known, as the policy notes listed 'nil' negative effects. That this is the opinion of APNIC (and it seems, of a significant portion of the community) is incredibly concerning, because it couldn't be further from the truth.
Many real businesses will be affected by this, with real people. And the flippancy with which many within APNIC are treating this proposal shows a concerning lack of empathy towards that - and a failure to grasp the nature of IPv4 addresses as a modern asset class.
Without the above questions answered, I don't see how this policy vote can go ahead - and I would implore everyone considering this policy to reject it outright. There may be issues with the current IPv4 paradigm but this is definitely not the solution.
Kind Regards
Matt Shearing Chief Executive Officer
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Brisbane, Australia (AEST) • matt@oneqode.commailto:matt@oneqode.com • +61 406 778 038
[OneQode™]https://www.oneqode.com/
[Follow us on LinkedIn]https://www.linkedin.com/company/oneqode/
From: Mike Burns mike@iptrading.commailto:mike@iptrading.com Sent: Thursday, 8 September 2022 6:52 AM To: 'Fernando Frediani' fhfrediani@gmail.commailto:fhfrediani@gmail.com; sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Alas, Fernando, there is no alternative “drug” for people to live without IPv4.
Banning leasing hurts the smallest and poorest of companies most.
And you cannot elucidate any “major damages” suffered where leasing has actually, in reality, occurred for many years at RIPE.
Yet you use this evidence-free assertion as your major argument against leasing.
That some kind of serious damage will occur to the RIR system.
As a broker who as to talk to actual, real companies in need, who can’t afford to pay upfront, can you tell me what I should say when they ask me why leasing is forbidden? If I say it’s to avoid “major damages” and they ask what they are, can you tell me?
What major damages?
Regards, Mike
From: Fernando Frediani <fhfrediani@gmail.commailto:fhfrediani@gmail.com> Sent: Wednesday, September 7, 2022 4:33 PM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Do you understand the argument that certain drugs can alleviate certain pains but they remain forbidden because they cause a major damage to society in long term and there are alternatives for people be able to still live without have to use those type of damageable mechanisms. Companies can also live without that and still have other legally allowed mechanisms.
This discussion is unnecessary for this policy discussion as what it proposes is to make something *already forbidden* clear in to the text, not to discuss if leasing should exist or not.
If anyone opposes it please take attention to provide arguments and suggestions on how to address the issues raised about what the proposal really proposes.
Regards Fernando
On 07/09/2022 14:12, Mike Burns wrote:
Hi Fernando,
Do you understand my argument that smaller business cannot afford the full upfront payment but can afford monthly lease payments?
Please address that simple argument by telling me how the small business benefits by not having the lease option, but only having the purchase option.
Regards, Mike
From: Fernando Frediani fhfrediani@gmail.commailto:fhfrediani@gmail.com Sent: Wednesday, September 7, 2022 1:01 PM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
IP Leasing is already banned in most RIRs and should stay as is.
But yes it does help as it doesn't push even further up IPv4 pricing and makes it easier for these small companies to get IPv4 via the proper and allowed way which are transfers. Other then diverting totally the propose o IPv4 Allocation, Leasing market contributes significantly to price increasing fueling the market with more demand for that type of very wrong thing.
RIPE is normally not a good example for certain policies which don't seem to have receptivity in discussions on all other RIRs.
There are still mechanisms that allow companies to get IP addressing either directly from the RIR, via Transfers which is a pretty common way or from the Upstream providers. People may not have got used yet to learn to live with less address and they may believe they need a bunch of address.
IP Leasing will never help small companies. The ones who really benefit from it are the IP broker companies who profit from them and also the resource holders which don't justify anymore to keep those addresses and are also profiting from something that should have been re-assigned directly to those who really need and justify for them in order to build Internet Infrastructure and Connectivity and instead are leasing a asset they don't own.
Fernando
On 07/09/2022 12:39, Mike Burns wrote:
Hi Fernando,
So your argument is that banning leasing actually helps smaller companies in their quest for IPv4?
Are you aware that RIPE has allowed leasing for many years but is still a functioning RIR whose IPv4 sale prices are not more expensive despite the history of leasing there?
Can you reconcile that with your argument that leasing will raise prices for both leasing and transfers?
Are you aware that it’s not always possible to get IPv4 blocks from the company that is providing you with connectivity?
Regards, Mike
From: Fernando Frediani fhfrediani@gmail.commailto:fhfrediani@gmail.com Sent: Wednesday, September 7, 2022 11:27 AM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
This is exactly the opposite.
Allowing IP leasing to happen more than just tottaly divert the propose of IP assignments by RIRs it make it bad specially for smaller companies as it increases the cost for both leasing and transfers in long term. The cost of leasing is based on the transfer and if leasing is allowed then transfer prices will always go up which makes it even harder for smaller companies to go into the market.
Any form of IP leasing without a direct connection relationship to provide a connectivity service makes it more expensive for smaller companies to get IP addresses to operate.
Fernando
On 07/09/2022 11:15, Mike Burns wrote:
Hi Jordi,
It’s plain you feel that we should do all possible to raise the price of IPv4 and make it unattainable for small business in the vain hope that this will drive IPv6 adoption.
I don’t think making IPv4 more difficult to acquire is the job of the RIR system.
You have not addressed the inability of smaller companies to acquire necessary IPv4 blocks if you ban leasing.
Is that something you are comfortable with, in pursuit of the IPv6 grail?
It’s okay with you that this policy prevents small companies from growing?
Regards, Mike
From: JORDI PALET MARTINEZ via sig-policy sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Sent: Wednesday, September 7, 2022 10:11 AM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Actually, I must disagree …
If organizations having unused resources, they need to transfer them or return them to the RIR. If prices keep going high, that could encourage faster IPv6 adoption, then transfer prices will go down, up to “no value”. It takes time, but it is just market.
Those that have more money, have more facilities to do a faster transition and not bother about IPv4.
Regards,
Jordi
@jordipalet
El 7/9/22, 16:05, "Mike Burns" <mike@iptrading.commailto:mike@iptrading.com> escribió:
Hello,
Per Gaurav’s statement that “only those with millions of dollars can think of getting ips”, this community should oppose this policy.
Because the only way small companies can afford to get ips today is by leasing them. The same way the small company can’t afford to purchase a big office building but instead rents an office. Leasing is the only way to finance IPv4 acquisitions today. No bank or other entity that I am aware of will do it. Purchasing addresses requires full upfront payment, but leasing allow for much smaller monthly payments.
If this community wants to ensure only the largest and richest companies can acquire new addresses, ban leasing.
But if the community tries to ban something with such a large business motivation behind it, it will find itself struggling against a powerful foe.
And for what purpose do we punish the small businesses? Leasing puts addresses in the hands of those who need them to build and operate networks. Isn’t that the primary goal of the RIR system?
Regards,
Mike
El 2/9/22, 9:23, "Gaurav Kansal" <gaurav.kansal@nic.inmailto:gaurav.kansal@nic.in> escribió:
Hello everyone,
In my opinion, even Trading of IPs (leave apart the lease for making dollars) in the name of transfers must be stopped.
If organisation doesn’t need IPs , then those must be returned back so that smaller organisations can get it from the RIR.
Currently, only the one which have millions of dollars can think of getting IPs. In today’s scenario, no one can start the Data Centre, ISP business without investing millions in IPs. Even education and research org doesn’t have an option to get IPs from RIR.
This is like horse trading and isn’t a good practice for the community as a whole.
Regards,
Gaurav Kansal
On 02-Sep-2022, at 12:20, rajesh@smartlinkindia.commailto:rajesh@smartlinkindia.com wrote:
Dear Team,
As Mr. Satoru, mentioned there are changes, but if carefully implemented in phased manner, unauthorised leasing can be stopped.
For example in first phase, leasing among countries can be stopped, if the owner company doesn't provide any services beyond its home country. For example if a company in India doesn't have any operation in Singapore or Japan , can't lease resources to those companies in Singapore or Japan. This can be verified by taking business registration documents of both lease and lessor.
Once this is done same may be granularized at RIR level, where in country like India, leasing can be restricted to the licensed service area for service provider within their designated service area.
This may stop majority of issues, barring few exceptions.
Some more brainstorming is required for better understanding and precise implementation.
Regards,
Rajesh Panwala
For Smartlink Solutions Pvt Ltd
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On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru <stsuruma@bbix.netmailto:stsuruma@bbix.net> wrote:
Dear Colleagues,
I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team..
I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals.
Many participants support the intent of the proposal but felt that implementation would be challenging.
(comment details) - It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses. - I think this proposal would be useful if the concept of leasing is accurately defined. - Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement.
Regards,
Satoru Tsurumaki / JPOPF Steering Team
2022年8月26日(金) 17:27 Shaila Sharmin <shaila.sharmin.ovi@gmail.commailto:shaila.sharmin.ovi@gmail.com>:
Dear SIG members,
A new version of the proposal "prop-148-v002: Clarification - Leasing of Resources is not Acceptable" has been sent to the Policy SIG for review.
Information about earlier versions is available from:
http://www.apnic.net/policy/proposals/prop-148
You are encouraged to express your views on the proposal:
- Do you support or oppose the proposal?
- Is there anything in the proposal that is not clear?
- What changes could be made to this proposal to make it more effective?
Please find the text of the proposal below.
Regards, Bertrand, Shaila, and Ching-Heng APNIC Policy SIG Chairs
prop-148-v002: Clarification - Leasing of Resources is not Acceptable
Proposer: Jordi Palet Martinez (jordi.palet@theipv6company.comAnupammailto:jordi.palet@theipv6company.comAnupam) Amrita Choudhury (amritachoudhury@ccaoi.inmailto:amritachoudhury@ccaoi.in) Fernando Frediani (fhfredani@gmail.commailto:fhfredani@gmail.com)
- Problem statement
RIRs have been conceived to manage, allocate and assign resources according to need, in such a 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 delegated by APNIC or an NIR, the justification of the need implies the need to use on their own infrastructure and/or network connectivity services provided directly to customers. As a result, any form of IP address leasing is unacceptable, 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.
APNIC may proactively investigate those cases and also initiate the investigation in case of reports by means of a form, email address or other means developed by APNIC.
If any form of leasing, regardless of when the delegation has been issued, is confirmed by an APNIC investigation, it will be considered a policy violation and revocation may apply against any account holders who are leasing or using them for any purposes not specified in the initial request.
- Advantages / Disadvantages
Advantages: Fulfilling the objective above indicated and making the policy clear.
Disadvantages: None.
- Impact on resource holders
None.
- 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 _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.netmailto:sig-policy-leave@lists.apnic.net
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Andrew your understanding about my statements is wrong. it is unnecessary the secretariat to confirm such points, unless you have a concern about them.
There is an issue with leasing existing despite the current rules don't allow them. And all I said they should always be able to enforce regardless the scenario and have all legal cover and support to do this in courts if necessary. This proposal helps text helps them further to make it even clear to a court what can and cannot be done with Internet Resources.
Fernando
On 08/09/2022 00:08, Andrew Yager wrote:
In response to your last paragaph
Can the secretariat confirm:
- they have an issue with enforcement now
- They have an active need that they are unable to address under this framework
- That the current membership agreement is inadequate to allow them to fulfil the tasks they have
Your statements infer that there is an issue, they can’t enforce behaviour and that the current policies are inadequate. I’m yet to see any evidence of this.
Andre
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*From:* Fernando Frediani fhfrediani@gmail.com *Sent:* Thursday, September 8, 2022 1:01:40 PM *To:* sig-policy@lists.apnic.net sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Hi Matt, I am sorry but I don't really take some of these emotional arguments because they are created mostly by the ones who are most taking advantage from it. There are ways in the *real* world but there are also adjustments that must be made and many still seem to not have realized after a while. One thing I find it wrong is to blame APNIC for it and suggesting they should not stop this, despite the illegality presented and therefore the unfairness with the whole of community impacted.
It seems interesting however your idea of some tentative to transfer resources definitely to smaller companies, but not only from the larger holders but from *any* holder who is leasing them. In order words an idea of a proposal could be to allow a company who leases from a resources holders to have those resources forcibly transferred definitely to them regardless the permission of the resources holder if a leasing it shown to be happening there.
Sorry to disagree, but appealing to leasing as the only option available at this stage is a easy path to make it worst a scenario that is only causing more and more unfairness to all. If it is wrong - and it is - it must be stopped *right now* and how to act about what exists should be carried on being discussed (in another thread) in order to help APNIC how to deal with cases properly and have all the support it may require.
Regards Fernando
On 07/09/2022 23:39, Matthew Shearing wrote:
Fernando, very simply – if it was already against the rules, why this policy? There should be no need for clarification if this was already ‘illegal’ or ‘against the rules’ as you say. What is the point of this policy if it’s already clear?
Further, you keep talking about IPv4 exhaustion and that we need to ‘deal with it’. The fact there exists a leasing market in the first place means that there are plenty of unused IPv4 resources. Otherwise, there would be no IPv4 addresses to lease.
If APNIC wants to tackle ‘misuse’, that is also fine. However, why not start with those who have plenty of IP space? Why not build in guarantees that APNIC it revokes space from a large holder, any lessees currently using that space will get access to those IPv4 addresses, as they are the ones using them? Why is none of this even being discussed? It’s incredibly obvious this policy hurts mainly the smaller companies, by going after /leases/, not the big holdings themselves.
By saying /‘there are ways to get blocks’/ also tells me very clearly that you’ve either not tried recently, or you’re just willfully ignorant. For many companies, leasing is the only feasible ways to get blocks because we are priced out.
Ideologically, we are all in agreement that an IPv6 world would be amazing. Unfortunately, those of us running businesses need to exist here in the real world, not in your imaginary world where we get everything we would like. If you want to help change that, we’ll all be here, cheering you on. Until then, businesses like ours don’t have the luxury of sitting around wishing – we’ve got customers we need to serve and employees we need to pay.
These ‘emotional’ arguments are common because they are */real/*. They are for businesses that exist in the real world, in an IP environment that APNIC (and other registrars) created. APNIC allowed the leasing paradigm to occur and did nothing about it. This is not some new thing – it is a mature market that has existed for a long time.
It is incredibly irresponsible for APNIC to try and roll it back now, after many years of inaction, and disingenuous for people like you to somehow claim businesses that are just trying to do the best they can in the environment we currently have are somehow at fault. This problem can be laid squarely at the feet of APNIC – and for that reason, it can and will be held liable by those damaged if any changes are made now.
This policy is approaching everything from the wrong direction. Its implementation will punish the smallest businesses while doing nothing about the largest legacy holders. If APNIC is serious about the IPv4 allocation issue, it should start with the swathes of latent resources and move backwards. This should be tempered by protections and policies which ensure smaller businesses aren’t ruined in the process. Maybe once that is solved, in several years time, it will be time to revisit this topic. For now though, this is far too premature.
The reality is this – for many of us, leasing is right now the only viable option. Taking that away without proposing any kind of genuine alternatives (ie not the handwavium generalisations you’ve been engaging in) is reckless and will result in incredible damage to members who have simply been doing their best in an environment APNIC created in the first place.
Cheers,
*Matt Shearing* *Chief Executive Officer*
Brisbane, Australia (AEST) • matt@oneqode.com mailto:matt@oneqode.com • +61 406 778 038
OneQode™ https://www.oneqode.com/
Follow us on LinkedIn https://www.linkedin.com/company/oneqode/
*From:* Fernando Frediani fhfrediani@gmail.com mailto:fhfrediani@gmail.com *Sent:* Thursday, 8 September 2022 12:15 PM *To:* sig-policy@lists.apnic.net mailto:sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Unfortunately this shows a tentative to discuss something with lack of enough important information about the topic and also there was not proper follow of most of this thread discussion.
First Internet Resources are not irrevocable assets that anyone who holds them can do whatever they like as if they own them. Unfortunately many people in this industry still don't know, but the fact that organizations hold a resource assigned to them does not mean they own it and therefore they must operate them under certain rules otherwise they risk to have them revoked, therefore they cannot be treated as an asset you purchased and may do whatever you like with it. If you purchase a server or a router it is yours and you sell or lease it for whatever amount you wish, but not with internet resources because you don't own them.
It is unimportant that anything APNIC may do against those who using IPv4 blocks illegally and may have them revoked because they should never have used in that way in first instance. A while back, when they became members they have signed a contract agreeing they would use the resources according to the rules. Therefore if someone decided to do out of what has been previously agreed they did it in their own risk and cannot allege they are "being affected".
Regardless how market evolves APNIC has full rights to revoke resources from members who are misusing resources not in accordance with the contracts they have signed and agreed. And by doing that APNIC is protecting community interests in detriment to individual and very specific interests that wants to use internet resources for proposes they were never conceived for.
Seems that people still didn't accept IPv4 exhaustion and keep hoping for something that will never come instead of learn once for all how to deal with it. There are ways to get blocks, for example via transfers and other specific methods, but the scenario many were used for decades doesn't exist anymore and still seems people keep trying to make up stuff to benefit their own specific interest in detriment of everybody else and of the fairness with everybody involved. If a company doesn't have enough money to afford a transfer I am sorry, but that is the new reality for a while. Learn how to deal with it and use other alternatives available like getting from upstreams - who provide connectivity - until there is budget to get address via a transfer for example. And not less important, stop hiding from IPv6 saying that will not revolve.
APNIC has all rights to fight in courts and is fully legally covered to enforce what members using internet resources signed and agreed for. Hardly judges will overwrite such agreement because they fell sorry that some people still didn't accept and learned to live with IPv4 exhaustion. No 'difficult' scenario gives the right to a member to void a contract they signed and agreed and win that in court.
These 'emotional arguments' of people and companies that will suffer if no leasing is allowed is a common argument from organizations who profit from IP leasing and don't build any internet connectivity and is already old one. If people keep insisting in doing things out of the rules sooner or later they will have to pay the price and they should know the risk before they even started.
IP addresses were not made to be rented from a resource holder who don't need them anymore to one that needs and could get them directly from the RIR. Regardless of the most noble reason, going against the rules doesn't make they valid.
Fernando
On 07/09/2022 22:49, Matthew Shearing wrote:
Just wanted to chime in here and follow up on Mike's point (and those of several others). What APNIC has done by its previous conduct is create a scarce asset collected in the hands of a number of large providers, with increasingly less being issued to small providers. As with any scarce asset in human history, this necessarily creates all the prerequisites for a fee market. Just like real estate, vehicles and other commodities, leasing is a natural evolution of scarcity in an asset class with direct utility. Right now, IPv4 blocks are like houses - some own them, but some don't have the capital resources to outright own the amount they need. Simply looking at the prices which IPv4 blocks are going for on the open market will make it clear that many smaller businesses are priced out. Leasing represents a viable option for companies to access the blocks they need and pay manageable, monthly or yearly payments for the use of those blocks. Many businesses are reliant on these currently. Saying that APNIC will outright ban leasing and that this will somehow benefit businesses is abjectly false. Not only will it disrupt many current business operations, but there is no guarantee that a market with more perverse incentives won't emerge afterwards. In our view, APNIC has already demonstrated by its statements and conduct with this policy that they have little grasp on how (and why) asset markets evolve. They've also done nothing to dissuade us that the new 'status quo' after this policy change won't be worse than the current one - which operates relatively fine. Practically, for APNIC to say there will be no meaningful damage to current users and businesses (who are APNIC members in their own right) it must answer the following questions: 1. What alternative does APNIC propose to the current IPv4 market and particularly, leasing options available to smaller companies and new entrants? 2. How will terminating leases currently on foot result in a better outcome for the businesses currently relying on them? 3. How will new IPv4 addresses be allocated, what timeframes and costs will be involved in this allocation? 4. Can APNIC give guarantees to current lessees who are reliant on IPv4 address leases that they can continue to access those addresses or will have replacements of similar value, at less cost, instantly after the change is made? 5. Is APNIC prepared to be held liable in lawsuits or a class action for the damages incurred by this policy change? Has it considered this risk and informed members accordingly? It appears that those that will not be affected by this policy or those who already have large IPv4 blocks are some of the largest proponents of it - which makes sense. It is easy to vote for a change if it's only others that will be affected. However, there are a large number of SME businesses out there who rely on these leases to run their operations. For them, this isn't just some merely intellectual exercise. Rather, it's a question of hundreds of thousands, or even millions, of dollars. It's their ability to remain operational. It's their employees' livelihoods and those of their families. It's a core part of how they operate and for many, the foundation which they've built their business on. This policy change seems to almost be a /'policy for policies sake'/. It is clear that the repercussions of this were either not considered, or not even known, as the policy notes listed 'nil' negative effects. That this is the opinion of APNIC (and it seems, of a significant portion of the community) is incredibly concerning, because it couldn't be further from the truth. Many real businesses will be affected by this, with real people. And the flippancy with which many within APNIC are treating this proposal shows a concerning lack of empathy towards that - and a failure to grasp the nature of IPv4 addresses as a modern asset class. Without the above questions answered, I don't see how this policy vote can go ahead - and I would implore everyone considering this policy to reject it outright. There may be issues with the current IPv4 paradigm but this is definitely not the solution. Kind Regards *Matt Shearing* *Chief Executive Officer* Brisbane, Australia (AEST) • matt@oneqode.com <mailto:matt@oneqode.com> • +61 406 778 038 OneQode™ <https://www.oneqode.com/> Follow us on LinkedIn <https://www.linkedin.com/company/oneqode/> *From:* Mike Burns <mike@iptrading.com> <mailto:mike@iptrading.com> *Sent:* Thursday, 8 September 2022 6:52 AM *To:* 'Fernando Frediani' <fhfrediani@gmail.com> <mailto:fhfrediani@gmail.com>; sig-policy@lists.apnic.net <mailto:sig-policy@lists.apnic.net> *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable Alas, Fernando, there is no alternative “drug” for people to live without IPv4. Banning leasing hurts the smallest and poorest of companies most. And you cannot elucidate any “major damages” suffered where leasing has actually, in reality, occurred for many years at RIPE. Yet you use this evidence-free assertion as your major argument against leasing. That some kind of serious damage will occur to the RIR system. As a broker who as to talk to actual, real companies in need, who can’t afford to pay upfront, can you tell me what I should say when they ask me why leasing is forbidden? If I say it’s to avoid “major damages” and they ask what they are, can you tell me? What major damages? Regards, Mike *From:* Fernando Frediani <fhfrediani@gmail.com <mailto:fhfrediani@gmail.com>> *Sent:* Wednesday, September 7, 2022 4:33 PM *To:* sig-policy@lists.apnic.net <mailto:sig-policy@lists.apnic.net> *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable Do you understand the argument that certain drugs can alleviate certain pains but they remain forbidden because they cause a major damage to society in long term and there are alternatives for people be able to still live without have to use those type of damageable mechanisms. Companies can also live without that and still have other legally allowed mechanisms. This discussion is unnecessary for this policy discussion as what it proposes is to make something *already forbidden* clear in to the text, not to discuss if leasing should exist or not. If anyone opposes it please take attention to provide arguments and suggestions on how to address the issues raised about what the proposal really proposes. Regards Fernando On 07/09/2022 14:12, Mike Burns wrote: Hi Fernando, Do you understand my argument that smaller business cannot afford the full upfront payment but can afford monthly lease payments? Please address that simple argument by telling me how the small business benefits by not having the lease option, but only having the purchase option. Regards, Mike *From:* Fernando Frediani <fhfrediani@gmail.com> <mailto:fhfrediani@gmail.com> *Sent:* Wednesday, September 7, 2022 1:01 PM *To:* sig-policy@lists.apnic.net <mailto:sig-policy@lists.apnic.net> *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable IP Leasing is already banned in most RIRs and should stay as is. But yes it does help as it doesn't push even further up IPv4 pricing and makes it easier for these small companies to get IPv4 via the proper and allowed way which are transfers. Other then diverting totally the propose o IPv4 Allocation, Leasing market contributes significantly to price increasing fueling the market with more demand for that type of very wrong thing. RIPE is normally not a good example for certain policies which don't seem to have receptivity in discussions on all other RIRs. There are still mechanisms that allow companies to get IP addressing either directly from the RIR, via Transfers which is a pretty common way or from the Upstream providers. People may not have got used yet to learn to live with less address and they may believe they need a bunch of address. IP Leasing will never help small companies. The ones who really benefit from it are the IP broker companies who profit from them and also the resource holders which don't justify anymore to keep those addresses and are also profiting from something that should have been re-assigned directly to those who really need and justify for them in order to build Internet Infrastructure and Connectivity and instead are leasing a asset they don't own. Fernando On 07/09/2022 12:39, Mike Burns wrote: Hi Fernando, So your argument is that banning leasing actually helps smaller companies in their quest for IPv4? Are you aware that RIPE has allowed leasing for many years but is still a functioning RIR whose IPv4 sale prices are not more expensive despite the history of leasing there? Can you reconcile that with your argument that leasing will raise prices for both leasing and transfers? Are you aware that it’s not always possible to get IPv4 blocks from the company that is providing you with connectivity? Regards, Mike *From:* Fernando Frediani <fhfrediani@gmail.com> <mailto:fhfrediani@gmail.com> *Sent:* Wednesday, September 7, 2022 11:27 AM *To:* sig-policy@lists.apnic.net <mailto:sig-policy@lists.apnic.net> *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable This is exactly the opposite. Allowing IP leasing to happen more than just tottaly divert the propose of IP assignments by RIRs it make it bad specially for smaller companies as it increases the cost for both leasing and transfers in long term. The cost of leasing is based on the transfer and if leasing is allowed then transfer prices will always go up which makes it even harder for smaller companies to go into the market. Any form of IP leasing without a direct connection relationship to provide a connectivity service makes it more expensive for smaller companies to get IP addresses to operate. Fernando On 07/09/2022 11:15, Mike Burns wrote: Hi Jordi, It’s plain you feel that we should do all possible to raise the price of IPv4 and make it unattainable for small business in the vain hope that this will drive IPv6 adoption. I don’t think making IPv4 more difficult to acquire is the job of the RIR system. You have not addressed the inability of smaller companies to acquire necessary IPv4 blocks if you ban leasing. Is that something you are comfortable with, in pursuit of the IPv6 grail? It’s okay with you that this policy prevents small companies from growing? Regards, Mike *From:* JORDI PALET MARTINEZ via sig-policy <sig-policy@lists.apnic.net> <mailto:sig-policy@lists.apnic.net> *Sent:* Wednesday, September 7, 2022 10:11 AM *To:* sig-policy@lists.apnic.net <mailto:sig-policy@lists.apnic.net> *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable Actually, I must disagree … If organizations having unused resources, they need to transfer them or return them to the RIR. If prices keep going high, that could encourage faster IPv6 adoption, then transfer prices will go down, up to “no value”. It takes time, but it is just market. Those that have more money, have more facilities to do a faster transition and not bother about IPv4. Regards, Jordi @jordipalet El 7/9/22, 16:05, "Mike Burns" <mike@iptrading.com <mailto:mike@iptrading.com>> escribió: Hello, Per Gaurav’s statement that “only those with millions of dollars can think of getting ips”, this community should oppose this policy. Because the only way small companies can afford to get ips today is by leasing them. The same way the small company can’t afford to purchase a big office building but instead rents an office. Leasing is the only way to finance IPv4 acquisitions today. No bank or other entity that I am aware of will do it. Purchasing addresses requires full upfront payment, but leasing allow for much smaller monthly payments. If this community wants to ensure only the largest and richest companies can acquire new addresses, ban leasing. But if the community tries to ban something with such a large business motivation behind it, it will find itself struggling against a powerful foe. And for what purpose do we punish the small businesses? Leasing puts addresses in the hands of those who need them to build and operate networks. Isn’t that the primary goal of the RIR system? Regards, Mike El 2/9/22, 9:23, "Gaurav Kansal" <gaurav.kansal@nic.in <mailto:gaurav.kansal@nic.in>> escribió: Hello everyone, In my opinion, even Trading of IPs (leave apart the lease for making dollars) in the name of transfers must be stopped. If organisation doesn’t need IPs , then those must be returned back so that smaller organisations can get it from the RIR. Currently, only the one which have millions of dollars can think of getting IPs. In today’s scenario, no one can start the Data Centre, ISP business without investing millions in IPs. Even education and research org doesn’t have an option to get IPs from RIR. This is like horse trading and isn’t a good practice for the community as a whole. Regards, Gaurav Kansal On 02-Sep-2022, at 12:20, rajesh@smartlinkindia.com <mailto:rajesh@smartlinkindia.com> wrote: Dear Team, As Mr. Satoru, mentioned there are changes, but if carefully implemented in phased manner, unauthorised leasing can be stopped. For example in first phase, leasing among countries can be stopped, if the owner company doesn't provide any services beyond its home country. For example if a company in India doesn't have any operation in Singapore or Japan , can't lease resources to those companies in Singapore or Japan. This can be verified by taking business registration documents of both lease and lessor. Once this is done same may be granularized at RIR level, where in country like India, leasing can be restricted to the licensed service area for service provider within their designated service area. This may stop majority of issues, barring few exceptions. Some more brainstorming is required for better understanding and precise implementation. Regards, Rajesh Panwala For Smartlink Solutions Pvt Ltd +91-9227886001 +91-9426110781 On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru <stsuruma@bbix.net <mailto:stsuruma@bbix.net>> wrote: Dear Colleagues, I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team.. I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals. Many participants support the intent of the proposal but felt that implementation would be challenging. (comment details) - It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses. - I think this proposal would be useful if the concept of leasing is accurately defined. - Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement. Regards, Satoru Tsurumaki / JPOPF Steering Team 2022年8月26日(金) 17:27 Shaila Sharmin <shaila.sharmin.ovi@gmail.com <mailto:shaila.sharmin.ovi@gmail.com>>: > > Dear SIG members, > > A new version of the proposal "prop-148-v002: Clarification - Leasing of > Resources is not Acceptable" has been sent to the Policy SIG for review. > > Information about earlier versions is available from: > > http://www.apnic.net/policy/proposals/prop-148 <http://www.apnic.net/policy/proposals/prop-148> > > You are encouraged to express your views on the proposal: > > - Do you support or oppose the proposal? > - Is there anything in the proposal that is not clear? > - What changes could be made to this proposal to make it more effective? > > Please find the text of the proposal below. > > Regards, > Bertrand, Shaila, and Ching-Heng > APNIC Policy SIG Chairs > > > ---------------------------------------------------------------------- > prop-148-v002: Clarification - 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 a 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 delegated by APNIC or an NIR, > the justification of the need implies the need to use on their own > infrastructure and/or network connectivity services provided directly to > customers. As a result, any form of IP address leasing is unacceptable, > 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. > > APNIC may proactively investigate those cases and also initiate the > investigation in case of reports by means of a form, email address or > other means developed by APNIC. > > If any form of leasing, regardless of when the delegation has been > issued, is confirmed by an APNIC investigation, it will be considered a > policy violation and revocation may apply against any account holders > who are leasing or using them for any purposes not specified in the > initial request. > > > 5. Advantages / Disadvantages > ----------------------------- > Advantages: > Fulfilling the objective above indicated and making the policy clear. > > Disadvantages: > None. > > > 6. Impact on resource holders > ----------------------------- > None. > > > 7. References > ------------- > https://www.arin.net/participate/policy/proposals/2022/ARIN_prop_308_v2/ <https://www.arin.net/participate/policy/proposals/2022/ARIN_prop_308_v2/> > https://politicas.lacnic.net/politicas/detail/id/LAC-2022-2/language/en <https://politicas.lacnic.net/politicas/detail/id/LAC-2022-2/language/en> > _______________________________________________ > sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ <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> -- -- Satoru Tsurumaki BBIX, Inc _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ <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> _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ <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> <https://amritmahotsav.nic.in/> _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ <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> ********************************************** IPv4 is over Are you ready for the new Internet ? http://www.theipv6company.com <http://www.theipv6company.com> The IPv6 Company This electronic message contains information which may be privileged or confidential. 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Fernando - you repeatedly state that there is an issue this policy is addressing. This is your base assumption.
I reiterate that to date the existing mechanisms are sufficient.
Feel free to demonstrate that they are not with evidence.
Andrew
Get Outlook for iOShttps://aka.ms/o0ukef ________________________________ From: Fernando Frediani fhfrediani@gmail.com Sent: Thursday, September 8, 2022 1:11:49 PM To: sig-policy@lists.apnic.net sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Andrew your understanding about my statements is wrong. it is unnecessary the secretariat to confirm such points, unless you have a concern about them.
There is an issue with leasing existing despite the current rules don't allow them. And all I said they should always be able to enforce regardless the scenario and have all legal cover and support to do this in courts if necessary. This proposal helps text helps them further to make it even clear to a court what can and cannot be done with Internet Resources.
Fernando
On 08/09/2022 00:08, Andrew Yager wrote: In response to your last paragaph
Can the secretariat confirm:
* they have an issue with enforcement now * They have an active need that they are unable to address under this framework * That the current membership agreement is inadequate to allow them to fulfil the tasks they have
Your statements infer that there is an issue, they can’t enforce behaviour and that the current policies are inadequate. I’m yet to see any evidence of this.
Andre
Get Outlook for iOShttps://aka.ms/o0ukef ________________________________ From: Fernando Frediani fhfrediani@gmail.commailto:fhfrediani@gmail.com Sent: Thursday, September 8, 2022 1:01:40 PM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Hi Matt, I am sorry but I don't really take some of these emotional arguments because they are created mostly by the ones who are most taking advantage from it. There are ways in the *real* world but there are also adjustments that must be made and many still seem to not have realized after a while. One thing I find it wrong is to blame APNIC for it and suggesting they should not stop this, despite the illegality presented and therefore the unfairness with the whole of community impacted.
It seems interesting however your idea of some tentative to transfer resources definitely to smaller companies, but not only from the larger holders but from *any* holder who is leasing them. In order words an idea of a proposal could be to allow a company who leases from a resources holders to have those resources forcibly transferred definitely to them regardless the permission of the resources holder if a leasing it shown to be happening there.
Sorry to disagree, but appealing to leasing as the only option available at this stage is a easy path to make it worst a scenario that is only causing more and more unfairness to all. If it is wrong - and it is - it must be stopped *right now* and how to act about what exists should be carried on being discussed (in another thread) in order to help APNIC how to deal with cases properly and have all the support it may require.
Regards Fernando
On 07/09/2022 23:39, Matthew Shearing wrote:
Fernando, very simply – if it was already against the rules, why this policy? There should be no need for clarification if this was already ‘illegal’ or ‘against the rules’ as you say. What is the point of this policy if it’s already clear?
Further, you keep talking about IPv4 exhaustion and that we need to ‘deal with it’. The fact there exists a leasing market in the first place means that there are plenty of unused IPv4 resources. Otherwise, there would be no IPv4 addresses to lease.
If APNIC wants to tackle ‘misuse’, that is also fine. However, why not start with those who have plenty of IP space? Why not build in guarantees that APNIC it revokes space from a large holder, any lessees currently using that space will get access to those IPv4 addresses, as they are the ones using them? Why is none of this even being discussed? It’s incredibly obvious this policy hurts mainly the smaller companies, by going after leases, not the big holdings themselves.
By saying ‘there are ways to get blocks’ also tells me very clearly that you’ve either not tried recently, or you’re just willfully ignorant. For many companies, leasing is the only feasible ways to get blocks because we are priced out.
Ideologically, we are all in agreement that an IPv6 world would be amazing. Unfortunately, those of us running businesses need to exist here in the real world, not in your imaginary world where we get everything we would like. If you want to help change that, we’ll all be here, cheering you on. Until then, businesses like ours don’t have the luxury of sitting around wishing – we’ve got customers we need to serve and employees we need to pay.
These ‘emotional’ arguments are common because they are real. They are for businesses that exist in the real world, in an IP environment that APNIC (and other registrars) created. APNIC allowed the leasing paradigm to occur and did nothing about it. This is not some new thing – it is a mature market that has existed for a long time.
It is incredibly irresponsible for APNIC to try and roll it back now, after many years of inaction, and disingenuous for people like you to somehow claim businesses that are just trying to do the best they can in the environment we currently have are somehow at fault. This problem can be laid squarely at the feet of APNIC – and for that reason, it can and will be held liable by those damaged if any changes are made now.
This policy is approaching everything from the wrong direction. Its implementation will punish the smallest businesses while doing nothing about the largest legacy holders. If APNIC is serious about the IPv4 allocation issue, it should start with the swathes of latent resources and move backwards. This should be tempered by protections and policies which ensure smaller businesses aren’t ruined in the process. Maybe once that is solved, in several years time, it will be time to revisit this topic. For now though, this is far too premature.
The reality is this – for many of us, leasing is right now the only viable option. Taking that away without proposing any kind of genuine alternatives (ie not the handwavium generalisations you’ve been engaging in) is reckless and will result in incredible damage to members who have simply been doing their best in an environment APNIC created in the first place.
Cheers,
Matt Shearing Chief Executive Officer
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From: Fernando Frediani fhfrediani@gmail.commailto:fhfrediani@gmail.com Sent: Thursday, 8 September 2022 12:15 PM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Unfortunately this shows a tentative to discuss something with lack of enough important information about the topic and also there was not proper follow of most of this thread discussion.
First Internet Resources are not irrevocable assets that anyone who holds them can do whatever they like as if they own them. Unfortunately many people in this industry still don't know, but the fact that organizations hold a resource assigned to them does not mean they own it and therefore they must operate them under certain rules otherwise they risk to have them revoked, therefore they cannot be treated as an asset you purchased and may do whatever you like with it. If you purchase a server or a router it is yours and you sell or lease it for whatever amount you wish, but not with internet resources because you don't own them.
It is unimportant that anything APNIC may do against those who using IPv4 blocks illegally and may have them revoked because they should never have used in that way in first instance. A while back, when they became members they have signed a contract agreeing they would use the resources according to the rules. Therefore if someone decided to do out of what has been previously agreed they did it in their own risk and cannot allege they are "being affected".
Regardless how market evolves APNIC has full rights to revoke resources from members who are misusing resources not in accordance with the contracts they have signed and agreed. And by doing that APNIC is protecting community interests in detriment to individual and very specific interests that wants to use internet resources for proposes they were never conceived for.
Seems that people still didn't accept IPv4 exhaustion and keep hoping for something that will never come instead of learn once for all how to deal with it. There are ways to get blocks, for example via transfers and other specific methods, but the scenario many were used for decades doesn't exist anymore and still seems people keep trying to make up stuff to benefit their own specific interest in detriment of everybody else and of the fairness with everybody involved. If a company doesn't have enough money to afford a transfer I am sorry, but that is the new reality for a while. Learn how to deal with it and use other alternatives available like getting from upstreams - who provide connectivity - until there is budget to get address via a transfer for example. And not less important, stop hiding from IPv6 saying that will not revolve.
APNIC has all rights to fight in courts and is fully legally covered to enforce what members using internet resources signed and agreed for. Hardly judges will overwrite such agreement because they fell sorry that some people still didn't accept and learned to live with IPv4 exhaustion. No 'difficult' scenario gives the right to a member to void a contract they signed and agreed and win that in court.
These 'emotional arguments' of people and companies that will suffer if no leasing is allowed is a common argument from organizations who profit from IP leasing and don't build any internet connectivity and is already old one. If people keep insisting in doing things out of the rules sooner or later they will have to pay the price and they should know the risk before they even started.
IP addresses were not made to be rented from a resource holder who don't need them anymore to one that needs and could get them directly from the RIR. Regardless of the most noble reason, going against the rules doesn't make they valid.
Fernando
On 07/09/2022 22:49, Matthew Shearing wrote:
Just wanted to chime in here and follow up on Mike's point (and those of several others).
What APNIC has done by its previous conduct is create a scarce asset collected in the hands of a number of large providers, with increasingly less being issued to small providers. As with any scarce asset in human history, this necessarily creates all the prerequisites for a fee market.
Just like real estate, vehicles and other commodities, leasing is a natural evolution of scarcity in an asset class with direct utility. Right now, IPv4 blocks are like houses - some own them, but some don't have the capital resources to outright own the amount they need. Simply looking at the prices which IPv4 blocks are going for on the open market will make it clear that many smaller businesses are priced out.
Leasing represents a viable option for companies to access the blocks they need and pay manageable, monthly or yearly payments for the use of those blocks. Many businesses are reliant on these currently.
Saying that APNIC will outright ban leasing and that this will somehow benefit businesses is abjectly false. Not only will it disrupt many current business operations, but there is no guarantee that a market with more perverse incentives won't emerge afterwards.
In our view, APNIC has already demonstrated by its statements and conduct with this policy that they have little grasp on how (and why) asset markets evolve. They've also done nothing to dissuade us that the new 'status quo' after this policy change won't be worse than the current one - which operates relatively fine.
Practically, for APNIC to say there will be no meaningful damage to current users and businesses (who are APNIC members in their own right) it must answer the following questions:
1. What alternative does APNIC propose to the current IPv4 market and particularly, leasing options available to smaller companies and new entrants? 2. How will terminating leases currently on foot result in a better outcome for the businesses currently relying on them? 3. How will new IPv4 addresses be allocated, what timeframes and costs will be involved in this allocation? 4. Can APNIC give guarantees to current lessees who are reliant on IPv4 address leases that they can continue to access those addresses or will have replacements of similar value, at less cost, instantly after the change is made? 5. Is APNIC prepared to be held liable in lawsuits or a class action for the damages incurred by this policy change? Has it considered this risk and informed members accordingly?
It appears that those that will not be affected by this policy or those who already have large IPv4 blocks are some of the largest proponents of it - which makes sense. It is easy to vote for a change if it's only others that will be affected.
However, there are a large number of SME businesses out there who rely on these leases to run their operations. For them, this isn't just some merely intellectual exercise. Rather, it's a question of hundreds of thousands, or even millions, of dollars.
It's their ability to remain operational. It's their employees' livelihoods and those of their families. It's a core part of how they operate and for many, the foundation which they've built their business on.
This policy change seems to almost be a 'policy for policies sake'. It is clear that the repercussions of this were either not considered, or not even known, as the policy notes listed 'nil' negative effects. That this is the opinion of APNIC (and it seems, of a significant portion of the community) is incredibly concerning, because it couldn't be further from the truth.
Many real businesses will be affected by this, with real people. And the flippancy with which many within APNIC are treating this proposal shows a concerning lack of empathy towards that - and a failure to grasp the nature of IPv4 addresses as a modern asset class.
Without the above questions answered, I don't see how this policy vote can go ahead - and I would implore everyone considering this policy to reject it outright. There may be issues with the current IPv4 paradigm but this is definitely not the solution.
Kind Regards
Matt Shearing Chief Executive Officer
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Brisbane, Australia (AEST) • matt@oneqode.commailto:matt@oneqode.com • +61 406 778 038
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[Follow us on LinkedIn]https://www.linkedin.com/company/oneqode/
From: Mike Burns mike@iptrading.commailto:mike@iptrading.com Sent: Thursday, 8 September 2022 6:52 AM To: 'Fernando Frediani' fhfrediani@gmail.commailto:fhfrediani@gmail.com; sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Alas, Fernando, there is no alternative “drug” for people to live without IPv4.
Banning leasing hurts the smallest and poorest of companies most.
And you cannot elucidate any “major damages” suffered where leasing has actually, in reality, occurred for many years at RIPE.
Yet you use this evidence-free assertion as your major argument against leasing.
That some kind of serious damage will occur to the RIR system.
As a broker who as to talk to actual, real companies in need, who can’t afford to pay upfront, can you tell me what I should say when they ask me why leasing is forbidden? If I say it’s to avoid “major damages” and they ask what they are, can you tell me?
What major damages?
Regards, Mike
From: Fernando Frediani <fhfrediani@gmail.commailto:fhfrediani@gmail.com> Sent: Wednesday, September 7, 2022 4:33 PM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Do you understand the argument that certain drugs can alleviate certain pains but they remain forbidden because they cause a major damage to society in long term and there are alternatives for people be able to still live without have to use those type of damageable mechanisms. Companies can also live without that and still have other legally allowed mechanisms.
This discussion is unnecessary for this policy discussion as what it proposes is to make something *already forbidden* clear in to the text, not to discuss if leasing should exist or not.
If anyone opposes it please take attention to provide arguments and suggestions on how to address the issues raised about what the proposal really proposes.
Regards Fernando
On 07/09/2022 14:12, Mike Burns wrote:
Hi Fernando,
Do you understand my argument that smaller business cannot afford the full upfront payment but can afford monthly lease payments?
Please address that simple argument by telling me how the small business benefits by not having the lease option, but only having the purchase option.
Regards, Mike
From: Fernando Frediani fhfrediani@gmail.commailto:fhfrediani@gmail.com Sent: Wednesday, September 7, 2022 1:01 PM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
IP Leasing is already banned in most RIRs and should stay as is.
But yes it does help as it doesn't push even further up IPv4 pricing and makes it easier for these small companies to get IPv4 via the proper and allowed way which are transfers. Other then diverting totally the propose o IPv4 Allocation, Leasing market contributes significantly to price increasing fueling the market with more demand for that type of very wrong thing.
RIPE is normally not a good example for certain policies which don't seem to have receptivity in discussions on all other RIRs.
There are still mechanisms that allow companies to get IP addressing either directly from the RIR, via Transfers which is a pretty common way or from the Upstream providers. People may not have got used yet to learn to live with less address and they may believe they need a bunch of address.
IP Leasing will never help small companies. The ones who really benefit from it are the IP broker companies who profit from them and also the resource holders which don't justify anymore to keep those addresses and are also profiting from something that should have been re-assigned directly to those who really need and justify for them in order to build Internet Infrastructure and Connectivity and instead are leasing a asset they don't own.
Fernando
On 07/09/2022 12:39, Mike Burns wrote:
Hi Fernando,
So your argument is that banning leasing actually helps smaller companies in their quest for IPv4?
Are you aware that RIPE has allowed leasing for many years but is still a functioning RIR whose IPv4 sale prices are not more expensive despite the history of leasing there?
Can you reconcile that with your argument that leasing will raise prices for both leasing and transfers?
Are you aware that it’s not always possible to get IPv4 blocks from the company that is providing you with connectivity?
Regards, Mike
From: Fernando Frediani fhfrediani@gmail.commailto:fhfrediani@gmail.com Sent: Wednesday, September 7, 2022 11:27 AM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
This is exactly the opposite.
Allowing IP leasing to happen more than just tottaly divert the propose of IP assignments by RIRs it make it bad specially for smaller companies as it increases the cost for both leasing and transfers in long term. The cost of leasing is based on the transfer and if leasing is allowed then transfer prices will always go up which makes it even harder for smaller companies to go into the market.
Any form of IP leasing without a direct connection relationship to provide a connectivity service makes it more expensive for smaller companies to get IP addresses to operate.
Fernando
On 07/09/2022 11:15, Mike Burns wrote:
Hi Jordi,
It’s plain you feel that we should do all possible to raise the price of IPv4 and make it unattainable for small business in the vain hope that this will drive IPv6 adoption.
I don’t think making IPv4 more difficult to acquire is the job of the RIR system.
You have not addressed the inability of smaller companies to acquire necessary IPv4 blocks if you ban leasing.
Is that something you are comfortable with, in pursuit of the IPv6 grail?
It’s okay with you that this policy prevents small companies from growing?
Regards, Mike
From: JORDI PALET MARTINEZ via sig-policy sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Sent: Wednesday, September 7, 2022 10:11 AM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Actually, I must disagree …
If organizations having unused resources, they need to transfer them or return them to the RIR. If prices keep going high, that could encourage faster IPv6 adoption, then transfer prices will go down, up to “no value”. It takes time, but it is just market.
Those that have more money, have more facilities to do a faster transition and not bother about IPv4.
Regards,
Jordi
@jordipalet
El 7/9/22, 16:05, "Mike Burns" <mike@iptrading.commailto:mike@iptrading.com> escribió:
Hello,
Per Gaurav’s statement that “only those with millions of dollars can think of getting ips”, this community should oppose this policy.
Because the only way small companies can afford to get ips today is by leasing them. The same way the small company can’t afford to purchase a big office building but instead rents an office. Leasing is the only way to finance IPv4 acquisitions today. No bank or other entity that I am aware of will do it. Purchasing addresses requires full upfront payment, but leasing allow for much smaller monthly payments.
If this community wants to ensure only the largest and richest companies can acquire new addresses, ban leasing.
But if the community tries to ban something with such a large business motivation behind it, it will find itself struggling against a powerful foe.
And for what purpose do we punish the small businesses? Leasing puts addresses in the hands of those who need them to build and operate networks. Isn’t that the primary goal of the RIR system?
Regards,
Mike
El 2/9/22, 9:23, "Gaurav Kansal" <gaurav.kansal@nic.inmailto:gaurav.kansal@nic.in> escribió:
Hello everyone,
In my opinion, even Trading of IPs (leave apart the lease for making dollars) in the name of transfers must be stopped.
If organisation doesn’t need IPs , then those must be returned back so that smaller organisations can get it from the RIR.
Currently, only the one which have millions of dollars can think of getting IPs. In today’s scenario, no one can start the Data Centre, ISP business without investing millions in IPs. Even education and research org doesn’t have an option to get IPs from RIR.
This is like horse trading and isn’t a good practice for the community as a whole.
Regards,
Gaurav Kansal
On 02-Sep-2022, at 12:20, rajesh@smartlinkindia.commailto:rajesh@smartlinkindia.com wrote:
Dear Team,
As Mr. Satoru, mentioned there are changes, but if carefully implemented in phased manner, unauthorised leasing can be stopped.
For example in first phase, leasing among countries can be stopped, if the owner company doesn't provide any services beyond its home country. For example if a company in India doesn't have any operation in Singapore or Japan , can't lease resources to those companies in Singapore or Japan. This can be verified by taking business registration documents of both lease and lessor.
Once this is done same may be granularized at RIR level, where in country like India, leasing can be restricted to the licensed service area for service provider within their designated service area.
This may stop majority of issues, barring few exceptions.
Some more brainstorming is required for better understanding and precise implementation.
Regards,
Rajesh Panwala
For Smartlink Solutions Pvt Ltd
+91-9227886001
+91-9426110781
On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru <stsuruma@bbix.netmailto:stsuruma@bbix.net> wrote:
Dear Colleagues,
I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team..
I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals.
Many participants support the intent of the proposal but felt that implementation would be challenging.
(comment details) - It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses. - I think this proposal would be useful if the concept of leasing is accurately defined. - Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement.
Regards,
Satoru Tsurumaki / JPOPF Steering Team
2022年8月26日(金) 17:27 Shaila Sharmin <shaila.sharmin.ovi@gmail.commailto:shaila.sharmin.ovi@gmail.com>:
Dear SIG members,
A new version of the proposal "prop-148-v002: Clarification - Leasing of Resources is not Acceptable" has been sent to the Policy SIG for review.
Information about earlier versions is available from:
http://www.apnic.net/policy/proposals/prop-148
You are encouraged to express your views on the proposal:
- Do you support or oppose the proposal?
- Is there anything in the proposal that is not clear?
- What changes could be made to this proposal to make it more effective?
Please find the text of the proposal below.
Regards, Bertrand, Shaila, and Ching-Heng APNIC Policy SIG Chairs
prop-148-v002: Clarification - Leasing of Resources is not Acceptable
Proposer: Jordi Palet Martinez (jordi.palet@theipv6company.comAnupammailto:jordi.palet@theipv6company.comAnupam) Amrita Choudhury (amritachoudhury@ccaoi.inmailto:amritachoudhury@ccaoi.in) Fernando Frediani (fhfredani@gmail.commailto:fhfredani@gmail.com)
- Problem statement
RIRs have been conceived to manage, allocate and assign resources according to need, in such a 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 delegated by APNIC or an NIR, the justification of the need implies the need to use on their own infrastructure and/or network connectivity services provided directly to customers. As a result, any form of IP address leasing is unacceptable, 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.
APNIC may proactively investigate those cases and also initiate the investigation in case of reports by means of a form, email address or other means developed by APNIC.
If any form of leasing, regardless of when the delegation has been issued, is confirmed by an APNIC investigation, it will be considered a policy violation and revocation may apply against any account holders who are leasing or using them for any purposes not specified in the initial request.
- Advantages / Disadvantages
Advantages: Fulfilling the objective above indicated and making the policy clear.
Disadvantages: None.
- Impact on resource holders
None.
- 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 _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.netmailto:sig-policy-leave@lists.apnic.net
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Hi
Let me ask Secretariat a simple question:
There is currently one of largest APNIC members who are leasing IP addresses to millions of end users(I won't name who that is but people in business should know), if this policy is adopted, how will the secretariat plan to enforce it without being sued out of existence?
The problem of this policy development process is, the real community is not involved. The real community is the near 10000 members and billions of end users those members represent.
Yes, it could be argued it is their fault not to join this policy process, but in reality, most don't care.
So this small room of people, who have never actually had any real memberbase support, believe they can make policy and use APNIC's monopoly position to do things, is simply disconnecting itself from reality.
Before Jordi and Fernado claim "community wants people to return space", how about getting 50% members' signatures to prove that point?
And the transfer data simply proves no one wants to return the space, and the real community wants a market.
I believe in order for RIR to survive, the small room of policy specialists that claim to represent the entire earth's interest(especially Jordi who makes policy proposals everywhere but failed to even have 10% of members supporting him), has to stop.
Policy needs to be made by the real members of APNIC, and real end users who are using the internet and someone can get a large percentage of the population to agree to them.
Otherwise, let APNIC stick to the bookkeeper, that is what is all created for.
On Thu, 8 Sept 2022 at 11:14, Andrew Yager andrew@rwts.com.au wrote:
Fernando - you repeatedly state that there is an issue this policy is addressing. This is your base assumption.
I reiterate that to date the existing mechanisms are sufficient.
Feel free to demonstrate that they are not with evidence.
Andrew
Get Outlook for iOS https://aka.ms/o0ukef
*From:* Fernando Frediani fhfrediani@gmail.com *Sent:* Thursday, September 8, 2022 1:11:49 PM *To:* sig-policy@lists.apnic.net sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Andrew your understanding about my statements is wrong. it is unnecessary the secretariat to confirm such points, unless you have a concern about them.
There is an issue with leasing existing despite the current rules don't allow them. And all I said they should always be able to enforce regardless the scenario and have all legal cover and support to do this in courts if necessary. This proposal helps text helps them further to make it even clear to a court what can and cannot be done with Internet Resources.
Fernando On 08/09/2022 00:08, Andrew Yager wrote:
In response to your last paragaph
Can the secretariat confirm:
- they have an issue with enforcement now
- They have an active need that they are unable to address under this
framework
- That the current membership agreement is inadequate to allow them to
fulfil the tasks they have
Your statements infer that there is an issue, they can’t enforce behaviour and that the current policies are inadequate. I’m yet to see any evidence of this.
Andre
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*From:* Fernando Frediani fhfrediani@gmail.com fhfrediani@gmail.com *Sent:* Thursday, September 8, 2022 1:01:40 PM *To:* sig-policy@lists.apnic.net sig-policy@lists.apnic.net sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Hi Matt, I am sorry but I don't really take some of these emotional arguments because they are created mostly by the ones who are most taking advantage from it. There are ways in the *real* world but there are also adjustments that must be made and many still seem to not have realized after a while. One thing I find it wrong is to blame APNIC for it and suggesting they should not stop this, despite the illegality presented and therefore the unfairness with the whole of community impacted.
It seems interesting however your idea of some tentative to transfer resources definitely to smaller companies, but not only from the larger holders but from *any* holder who is leasing them. In order words an idea of a proposal could be to allow a company who leases from a resources holders to have those resources forcibly transferred definitely to them regardless the permission of the resources holder if a leasing it shown to be happening there.
Sorry to disagree, but appealing to leasing as the only option available at this stage is a easy path to make it worst a scenario that is only causing more and more unfairness to all. If it is wrong - and it is - it must be stopped *right now* and how to act about what exists should be carried on being discussed (in another thread) in order to help APNIC how to deal with cases properly and have all the support it may require.
Regards Fernando On 07/09/2022 23:39, Matthew Shearing wrote:
Fernando, very simply – if it was already against the rules, why this policy? There should be no need for clarification if this was already ‘illegal’ or ‘against the rules’ as you say. What is the point of this policy if it’s already clear?
Further, you keep talking about IPv4 exhaustion and that we need to ‘deal with it’. The fact there exists a leasing market in the first place means that there are plenty of unused IPv4 resources. Otherwise, there would be no IPv4 addresses to lease.
If APNIC wants to tackle ‘misuse’, that is also fine. However, why not start with those who have plenty of IP space? Why not build in guarantees that APNIC it revokes space from a large holder, any lessees currently using that space will get access to those IPv4 addresses, as they are the ones using them? Why is none of this even being discussed? It’s incredibly obvious this policy hurts mainly the smaller companies, by going after *leases*, not the big holdings themselves.
By saying *‘there are ways to get blocks’* also tells me very clearly that you’ve either not tried recently, or you’re just willfully ignorant. For many companies, leasing is the only feasible ways to get blocks because we are priced out.
Ideologically, we are all in agreement that an IPv6 world would be amazing. Unfortunately, those of us running businesses need to exist here in the real world, not in your imaginary world where we get everything we would like. If you want to help change that, we’ll all be here, cheering you on. Until then, businesses like ours don’t have the luxury of sitting around wishing – we’ve got customers we need to serve and employees we need to pay.
These ‘emotional’ arguments are common because they are *real*. They are for businesses that exist in the real world, in an IP environment that APNIC (and other registrars) created. APNIC allowed the leasing paradigm to occur and did nothing about it. This is not some new thing – it is a mature market that has existed for a long time.
It is incredibly irresponsible for APNIC to try and roll it back now, after many years of inaction, and disingenuous for people like you to somehow claim businesses that are just trying to do the best they can in the environment we currently have are somehow at fault. This problem can be laid squarely at the feet of APNIC – and for that reason, it can and will be held liable by those damaged if any changes are made now.
This policy is approaching everything from the wrong direction. Its implementation will punish the smallest businesses while doing nothing about the largest legacy holders. If APNIC is serious about the IPv4 allocation issue, it should start with the swathes of latent resources and move backwards. This should be tempered by protections and policies which ensure smaller businesses aren’t ruined in the process. Maybe once that is solved, in several years time, it will be time to revisit this topic. For now though, this is far too premature.
The reality is this – for many of us, leasing is right now the only viable option. Taking that away without proposing any kind of genuine alternatives (ie not the handwavium generalisations you’ve been engaging in) is reckless and will result in incredible damage to members who have simply been doing their best in an environment APNIC created in the first place.
Cheers,
*Matt Shearing* *Chief Executive Officer*
Brisbane, Australia (AEST) • matt@oneqode.com • +61 406 778 038
[image: OneQode™] https://www.oneqode.com/
[image: Follow us on LinkedIn] https://www.linkedin.com/company/oneqode/
*From:* Fernando Frediani fhfrediani@gmail.com fhfrediani@gmail.com *Sent:* Thursday, 8 September 2022 12:15 PM *To:* sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Unfortunately this shows a tentative to discuss something with lack of enough important information about the topic and also there was not proper follow of most of this thread discussion.
First Internet Resources are not irrevocable assets that anyone who holds them can do whatever they like as if they own them. Unfortunately many people in this industry still don't know, but the fact that organizations hold a resource assigned to them does not mean they own it and therefore they must operate them under certain rules otherwise they risk to have them revoked, therefore they cannot be treated as an asset you purchased and may do whatever you like with it. If you purchase a server or a router it is yours and you sell or lease it for whatever amount you wish, but not with internet resources because you don't own them.
It is unimportant that anything APNIC may do against those who using IPv4 blocks illegally and may have them revoked because they should never have used in that way in first instance. A while back, when they became members they have signed a contract agreeing they would use the resources according to the rules. Therefore if someone decided to do out of what has been previously agreed they did it in their own risk and cannot allege they are "being affected".
Regardless how market evolves APNIC has full rights to revoke resources from members who are misusing resources not in accordance with the contracts they have signed and agreed. And by doing that APNIC is protecting community interests in detriment to individual and very specific interests that wants to use internet resources for proposes they were never conceived for.
Seems that people still didn't accept IPv4 exhaustion and keep hoping for something that will never come instead of learn once for all how to deal with it. There are ways to get blocks, for example via transfers and other specific methods, but the scenario many were used for decades doesn't exist anymore and still seems people keep trying to make up stuff to benefit their own specific interest in detriment of everybody else and of the fairness with everybody involved. If a company doesn't have enough money to afford a transfer I am sorry, but that is the new reality for a while. Learn how to deal with it and use other alternatives available like getting from upstreams - who provide connectivity - until there is budget to get address via a transfer for example. And not less important, stop hiding from IPv6 saying that will not revolve.
APNIC has all rights to fight in courts and is fully legally covered to enforce what members using internet resources signed and agreed for. Hardly judges will overwrite such agreement because they fell sorry that some people still didn't accept and learned to live with IPv4 exhaustion. No 'difficult' scenario gives the right to a member to void a contract they signed and agreed and win that in court.
These 'emotional arguments' of people and companies that will suffer if no leasing is allowed is a common argument from organizations who profit from IP leasing and don't build any internet connectivity and is already old one. If people keep insisting in doing things out of the rules sooner or later they will have to pay the price and they should know the risk before they even started.
IP addresses were not made to be rented from a resource holder who don't need them anymore to one that needs and could get them directly from the RIR. Regardless of the most noble reason, going against the rules doesn't make they valid.
Fernando
On 07/09/2022 22:49, Matthew Shearing wrote:
Just wanted to chime in here and follow up on Mike's point (and those of several others).
What APNIC has done by its previous conduct is create a scarce asset collected in the hands of a number of large providers, with increasingly less being issued to small providers. As with any scarce asset in human history, this necessarily creates all the prerequisites for a fee market.
Just like real estate, vehicles and other commodities, leasing is a natural evolution of scarcity in an asset class with direct utility. Right now, IPv4 blocks are like houses - some own them, but some don't have the capital resources to outright own the amount they need. Simply looking at the prices which IPv4 blocks are going for on the open market will make it clear that many smaller businesses are priced out.
Leasing represents a viable option for companies to access the blocks they need and pay manageable, monthly or yearly payments for the use of those blocks. Many businesses are reliant on these currently.
Saying that APNIC will outright ban leasing and that this will somehow benefit businesses is abjectly false. Not only will it disrupt many current business operations, but there is no guarantee that a market with more perverse incentives won't emerge afterwards.
In our view, APNIC has already demonstrated by its statements and conduct with this policy that they have little grasp on how (and why) asset markets evolve. They've also done nothing to dissuade us that the new 'status quo' after this policy change won't be worse than the current one - which operates relatively fine.
Practically, for APNIC to say there will be no meaningful damage to current users and businesses (who are APNIC members in their own right) it must answer the following questions:
- What alternative does APNIC propose to the current IPv4 market and
particularly, leasing options available to smaller companies and new entrants? 2. How will terminating leases currently on foot result in a better outcome for the businesses currently relying on them? 3. How will new IPv4 addresses be allocated, what timeframes and costs will be involved in this allocation? 4. Can APNIC give guarantees to current lessees who are reliant on IPv4 address leases that they can continue to access those addresses or will have replacements of similar value, at less cost, instantly after the change is made? 5. Is APNIC prepared to be held liable in lawsuits or a class action for the damages incurred by this policy change? Has it considered this risk and informed members accordingly?
It appears that those that will not be affected by this policy or those who already have large IPv4 blocks are some of the largest proponents of it
- which makes sense. It is easy to vote for a change if it's only others
that will be affected.
However, there are a large number of SME businesses out there who rely on these leases to run their operations. For them, this isn't just some merely intellectual exercise. Rather, it's a question of hundreds of thousands, or even millions, of dollars.
It's their ability to remain operational. It's their employees' livelihoods and those of their families. It's a core part of how they operate and for many, the foundation which they've built their business on.
This policy change seems to almost be a * 'policy for policies sake'*. It is clear that the repercussions of this were either not considered, or not even known, as the policy notes listed 'nil' negative effects. That this is the opinion of APNIC (and it seems, of a significant portion of the community) is incredibly concerning, because it couldn't be further from the truth.
Many real businesses will be affected by this, with real people. And the flippancy with which many within APNIC are treating this proposal shows a concerning lack of empathy towards that - and a failure to grasp the nature of IPv4 addresses as a modern asset class.
Without the above questions answered, I don't see how this policy vote can go ahead - and I would implore everyone considering this policy to reject it outright. There may be issues with the current IPv4 paradigm but this is definitely not the solution.
Kind Regards
*Matt Shearing* *Chief Executive Officer*
Brisbane, Australia (AEST) • matt@oneqode.com • +61 406 778 038
[image: OneQode™] https://www.oneqode.com/
[image: Follow us on LinkedIn] https://www.linkedin.com/company/oneqode/
*From:* Mike Burns mike@iptrading.com mike@iptrading.com *Sent:* Thursday, 8 September 2022 6:52 AM *To:* 'Fernando Frediani' fhfrediani@gmail.com fhfrediani@gmail.com; sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Alas, Fernando, there is no alternative “drug” for people to live without IPv4.
Banning leasing hurts the smallest and poorest of companies most.
And you cannot elucidate any “major damages” suffered where leasing has actually, in reality, occurred for many years at RIPE.
Yet you use this evidence-free assertion as your major argument against leasing.
That some kind of serious damage will occur to the RIR system.
As a broker who as to talk to actual, real companies in need, who can’t afford to pay upfront, can you tell me what I should say when they ask me why leasing is forbidden? If I say it’s to avoid “major damages” and they ask what they are, can you tell me?
What major damages?
Regards, Mike
*From:* Fernando Frediani fhfrediani@gmail.com *Sent:* Wednesday, September 7, 2022 4:33 PM *To:* sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Do you understand the argument that certain drugs can alleviate certain pains but they remain forbidden because they cause a major damage to society in long term and there are alternatives for people be able to still live without have to use those type of damageable mechanisms. Companies can also live without that and still have other legally allowed mechanisms.
This discussion is unnecessary for this policy discussion as what it proposes is to make something *already forbidden* clear in to the text, not to discuss if leasing should exist or not.
If anyone opposes it please take attention to provide arguments and suggestions on how to address the issues raised about what the proposal really proposes.
Regards Fernando
On 07/09/2022 14:12, Mike Burns wrote:
Hi Fernando,
Do you understand my argument that smaller business cannot afford the full upfront payment but can afford monthly lease payments?
Please address that simple argument by telling me how the small business benefits by not having the lease option, but only having the purchase option.
Regards, Mike
*From:* Fernando Frediani fhfrediani@gmail.com fhfrediani@gmail.com *Sent:* Wednesday, September 7, 2022 1:01 PM *To:* sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
IP Leasing is already banned in most RIRs and should stay as is.
But yes it does help as it doesn't push even further up IPv4 pricing and makes it easier for these small companies to get IPv4 via the proper and allowed way which are transfers. Other then diverting totally the propose o IPv4 Allocation, Leasing market contributes significantly to price increasing fueling the market with more demand for that type of very wrong thing.
RIPE is normally not a good example for certain policies which don't seem to have receptivity in discussions on all other RIRs.
There are still mechanisms that allow companies to get IP addressing either directly from the RIR, via Transfers which is a pretty common way or from the Upstream providers. People may not have got used yet to learn to live with less address and they may believe they need a bunch of address.
IP Leasing will never help small companies. The ones who really benefit from it are the IP broker companies who profit from them and also the resource holders which don't justify anymore to keep those addresses and are also profiting from something that should have been re-assigned directly to those who really need and justify for them in order to build Internet Infrastructure and Connectivity and instead are leasing a asset they don't own.
Fernando
On 07/09/2022 12:39, Mike Burns wrote:
Hi Fernando,
So your argument is that banning leasing actually helps smaller companies in their quest for IPv4?
Are you aware that RIPE has allowed leasing for many years but is still a functioning RIR whose IPv4 sale prices are not more expensive despite the history of leasing there?
Can you reconcile that with your argument that leasing will raise prices for both leasing and transfers?
Are you aware that it’s not always possible to get IPv4 blocks from the company that is providing you with connectivity?
Regards, Mike
*From:* Fernando Frediani fhfrediani@gmail.com fhfrediani@gmail.com *Sent:* Wednesday, September 7, 2022 11:27 AM *To:* sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
This is exactly the opposite.
Allowing IP leasing to happen more than just tottaly divert the propose of IP assignments by RIRs it make it bad specially for smaller companies as it increases the cost for both leasing and transfers in long term. The cost of leasing is based on the transfer and if leasing is allowed then transfer prices will always go up which makes it even harder for smaller companies to go into the market.
Any form of IP leasing without a direct connection relationship to provide a connectivity service makes it more expensive for smaller companies to get IP addresses to operate.
Fernando
On 07/09/2022 11:15, Mike Burns wrote:
Hi Jordi,
It’s plain you feel that we should do all possible to raise the price of IPv4 and make it unattainable for small business in the vain hope that this will drive IPv6 adoption.
I don’t think making IPv4 more difficult to acquire is the job of the RIR system.
You have not addressed the inability of smaller companies to acquire necessary IPv4 blocks if you ban leasing.
Is that something you are comfortable with, in pursuit of the IPv6 grail?
It’s okay with you that this policy prevents small companies from growing?
Regards, Mike
*From:* JORDI PALET MARTINEZ via sig-policy sig-policy@lists.apnic.net sig-policy@lists.apnic.net *Sent:* Wednesday, September 7, 2022 10:11 AM *To:* sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Actually, I must disagree …
If organizations having unused resources, they need to transfer them or return them to the RIR. If prices keep going high, that could encourage faster IPv6 adoption, then transfer prices will go down, up to “no value”. It takes time, but it is just market.
Those that have more money, have more facilities to do a faster transition and not bother about IPv4.
Regards,
Jordi
@jordipalet
El 7/9/22, 16:05, "Mike Burns" mike@iptrading.com escribió:
Hello,
Per Gaurav’s statement that “only those with millions of dollars can think of getting ips”, this community should oppose this policy.
Because the only way small companies can afford to get ips today is by leasing them. The same way the small company can’t afford to purchase a big office building but instead rents an office. Leasing is the only way to finance IPv4 acquisitions today. No bank or other entity that I am aware of will do it. Purchasing addresses requires full upfront payment, but leasing allow for much smaller monthly payments.
If this community wants to ensure only the largest and richest companies can acquire new addresses, ban leasing.
But if the community tries to ban something with such a large business motivation behind it, it will find itself struggling against a powerful foe.
And for what purpose do we punish the small businesses? Leasing puts addresses in the hands of those who need them to build and operate networks. Isn’t that the primary goal of the RIR system?
Regards,
Mike
El 2/9/22, 9:23, "Gaurav Kansal" gaurav.kansal@nic.in escribió:
Hello everyone,
In my opinion, even Trading of IPs (leave apart the lease for making dollars) in the name of transfers must be stopped.
If organisation doesn’t need IPs , then those must be returned back so that smaller organisations can get it from the RIR.
Currently, only the one which have millions of dollars can think of getting IPs. In today’s scenario, no one can start the Data Centre, ISP business without investing millions in IPs. Even education and research org doesn’t have an option to get IPs from RIR.
This is like horse trading and isn’t a good practice for the community as a whole.
Regards,
Gaurav Kansal
On 02-Sep-2022, at 12:20, rajesh@smartlinkindia.com wrote:
Dear Team,
As Mr. Satoru, mentioned there are changes, but if carefully implemented in phased manner, unauthorised leasing can be stopped.
For example in first phase, leasing among countries can be stopped, if the owner company doesn't provide any services beyond its home country. For example if a company in India doesn't have any operation in Singapore or Japan , can't lease resources to those companies in Singapore or Japan. This can be verified by taking business registration documents of both lease and lessor.
Once this is done same may be granularized at RIR level, where in country like India, leasing can be restricted to the licensed service area for service provider within their designated service area.
This may stop majority of issues, barring few exceptions.
Some more brainstorming is required for better understanding and precise implementation.
Regards,
Rajesh Panwala
For Smartlink Solutions Pvt Ltd
+91-9227886001
+91-9426110781
On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru stsuruma@bbix.net wrote:
Dear Colleagues,
I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team..
I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals.
Many participants support the intent of the proposal but felt that implementation would be challenging.
(comment details)
- It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses.
- I think this proposal would be useful if the concept of leasing is
accurately defined.
- Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement.
Regards,
Satoru Tsurumaki / JPOPF Steering Team
2022年8月26日(金) 17:27 Shaila Sharmin shaila.sharmin.ovi@gmail.com:
Dear SIG members,
A new version of the proposal "prop-148-v002: Clarification - Leasing of Resources is not Acceptable" has been sent to the Policy SIG for review.
Information about earlier versions is available from:
http://www.apnic.net/policy/proposals/prop-148
You are encouraged to express your views on the proposal:
- Do you support or oppose the proposal?
- Is there anything in the proposal that is not clear?
- What changes could be made to this proposal to make it more
effective?
Please find the text of the proposal below.
Regards, Bertrand, Shaila, and Ching-Heng APNIC Policy SIG Chairs
prop-148-v002: Clarification - 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 a 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 delegated by APNIC or an NIR, the justification of the need implies the need to use on their own infrastructure and/or network connectivity services provided directly to customers. As a result, any form of IP address leasing is unacceptable, 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.
APNIC may proactively investigate those cases and also initiate the investigation in case of reports by means of a form, email address or other means developed by APNIC.
If any form of leasing, regardless of when the delegation has been issued, is confirmed by an APNIC investigation, it will be considered a policy violation and revocation may apply against any account holders who are leasing or using them for any purposes not specified in the initial request.
- Advantages / Disadvantages
Advantages: Fulfilling the objective above indicated and making the policy clear.
Disadvantages: None.
- Impact on resource holders
None.
- 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 _______________________________________________ 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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I disagree with many of your assertions here about where policy and governance sit and the necessity of them.
APNIC needs to do more than charge fees and make money. It does provide a necessary and vital role in the health of the internet.
This is precisely why policy groups need to exist and precisely why policies need to be well written, sensible and offer value. But, the burden on policy makers is particularly to ensure their assumptions, foundational principals and statements are in fact correct, balanced and forward looking.
Policies should be few, measured, necessary and clear. Unfortunately I don’t think this proposal stacks up for the reasons I’ve already outlined.
Andrew
Get Outlook for iOShttps://aka.ms/o0ukef ________________________________ From: Lu Heng h.lu@anytimechinese.com Sent: Thursday, September 8, 2022 4:47:45 PM To: Andrew Yager andrew@rwts.com.au Cc: Fernando Frediani fhfrediani@gmail.com; sig-policy@lists.apnic.net sig-policy@lists.apnic.net Subject: Re: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Hi
Let me ask Secretariat a simple question:
There is currently one of largest APNIC members who are leasing IP addresses to millions of end users(I won't name who that is but people in business should know), if this policy is adopted, how will the secretariat plan to enforce it without being sued out of existence?
The problem of this policy development process is, the real community is not involved. The real community is the near 10000 members and billions of end users those members represent.
Yes, it could be argued it is their fault not to join this policy process, but in reality, most don't care.
So this small room of people, who have never actually had any real memberbase support, believe they can make policy and use APNIC's monopoly position to do things, is simply disconnecting itself from reality.
Before Jordi and Fernado claim "community wants people to return space", how about getting 50% members' signatures to prove that point?
And the transfer data simply proves no one wants to return the space, and the real community wants a market.
I believe in order for RIR to survive, the small room of policy specialists that claim to represent the entire earth's interest(especially Jordi who makes policy proposals everywhere but failed to even have 10% of members supporting him), has to stop.
Policy needs to be made by the real members of APNIC, and real end users who are using the internet and someone can get a large percentage of the population to agree to them.
Otherwise, let APNIC stick to the bookkeeper, that is what is all created for.
On Thu, 8 Sept 2022 at 11:14, Andrew Yager <andrew@rwts.com.aumailto:andrew@rwts.com.au> wrote: Fernando - you repeatedly state that there is an issue this policy is addressing. This is your base assumption.
I reiterate that to date the existing mechanisms are sufficient.
Feel free to demonstrate that they are not with evidence.
Andrew
Get Outlook for iOShttps://aka.ms/o0ukef ________________________________ From: Fernando Frediani <fhfrediani@gmail.commailto:fhfrediani@gmail.com> Sent: Thursday, September 8, 2022 1:11:49 PM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net <sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net> Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Andrew your understanding about my statements is wrong. it is unnecessary the secretariat to confirm such points, unless you have a concern about them.
There is an issue with leasing existing despite the current rules don't allow them. And all I said they should always be able to enforce regardless the scenario and have all legal cover and support to do this in courts if necessary. This proposal helps text helps them further to make it even clear to a court what can and cannot be done with Internet Resources.
Fernando
On 08/09/2022 00:08, Andrew Yager wrote: In response to your last paragaph
Can the secretariat confirm:
* they have an issue with enforcement now * They have an active need that they are unable to address under this framework * That the current membership agreement is inadequate to allow them to fulfil the tasks they have
Your statements infer that there is an issue, they can’t enforce behaviour and that the current policies are inadequate. I’m yet to see any evidence of this.
Andre
Get Outlook for iOShttps://aka.ms/o0ukef ________________________________ From: Fernando Frediani fhfrediani@gmail.commailto:fhfrediani@gmail.com Sent: Thursday, September 8, 2022 1:01:40 PM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Hi Matt, I am sorry but I don't really take some of these emotional arguments because they are created mostly by the ones who are most taking advantage from it. There are ways in the *real* world but there are also adjustments that must be made and many still seem to not have realized after a while. One thing I find it wrong is to blame APNIC for it and suggesting they should not stop this, despite the illegality presented and therefore the unfairness with the whole of community impacted.
It seems interesting however your idea of some tentative to transfer resources definitely to smaller companies, but not only from the larger holders but from *any* holder who is leasing them. In order words an idea of a proposal could be to allow a company who leases from a resources holders to have those resources forcibly transferred definitely to them regardless the permission of the resources holder if a leasing it shown to be happening there.
Sorry to disagree, but appealing to leasing as the only option available at this stage is a easy path to make it worst a scenario that is only causing more and more unfairness to all. If it is wrong - and it is - it must be stopped *right now* and how to act about what exists should be carried on being discussed (in another thread) in order to help APNIC how to deal with cases properly and have all the support it may require.
Regards Fernando
On 07/09/2022 23:39, Matthew Shearing wrote:
Fernando, very simply – if it was already against the rules, why this policy? There should be no need for clarification if this was already ‘illegal’ or ‘against the rules’ as you say. What is the point of this policy if it’s already clear?
Further, you keep talking about IPv4 exhaustion and that we need to ‘deal with it’. The fact there exists a leasing market in the first place means that there are plenty of unused IPv4 resources. Otherwise, there would be no IPv4 addresses to lease.
If APNIC wants to tackle ‘misuse’, that is also fine. However, why not start with those who have plenty of IP space? Why not build in guarantees that APNIC it revokes space from a large holder, any lessees currently using that space will get access to those IPv4 addresses, as they are the ones using them? Why is none of this even being discussed? It’s incredibly obvious this policy hurts mainly the smaller companies, by going after leases, not the big holdings themselves.
By saying ‘there are ways to get blocks’ also tells me very clearly that you’ve either not tried recently, or you’re just willfully ignorant. For many companies, leasing is the only feasible ways to get blocks because we are priced out.
Ideologically, we are all in agreement that an IPv6 world would be amazing. Unfortunately, those of us running businesses need to exist here in the real world, not in your imaginary world where we get everything we would like. If you want to help change that, we’ll all be here, cheering you on. Until then, businesses like ours don’t have the luxury of sitting around wishing – we’ve got customers we need to serve and employees we need to pay.
These ‘emotional’ arguments are common because they are real. They are for businesses that exist in the real world, in an IP environment that APNIC (and other registrars) created. APNIC allowed the leasing paradigm to occur and did nothing about it. This is not some new thing – it is a mature market that has existed for a long time.
It is incredibly irresponsible for APNIC to try and roll it back now, after many years of inaction, and disingenuous for people like you to somehow claim businesses that are just trying to do the best they can in the environment we currently have are somehow at fault. This problem can be laid squarely at the feet of APNIC – and for that reason, it can and will be held liable by those damaged if any changes are made now.
This policy is approaching everything from the wrong direction. Its implementation will punish the smallest businesses while doing nothing about the largest legacy holders. If APNIC is serious about the IPv4 allocation issue, it should start with the swathes of latent resources and move backwards. This should be tempered by protections and policies which ensure smaller businesses aren’t ruined in the process. Maybe once that is solved, in several years time, it will be time to revisit this topic. For now though, this is far too premature.
The reality is this – for many of us, leasing is right now the only viable option. Taking that away without proposing any kind of genuine alternatives (ie not the handwavium generalisations you’ve been engaging in) is reckless and will result in incredible damage to members who have simply been doing their best in an environment APNIC created in the first place.
Cheers,
Matt Shearing Chief Executive Officer
[X]
Brisbane, Australia (AEST) • matt@oneqode.commailto:matt@oneqode.com • +61 406 778 038
[OneQode™]https://www.oneqode.com/
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From: Fernando Frediani fhfrediani@gmail.commailto:fhfrediani@gmail.com Sent: Thursday, 8 September 2022 12:15 PM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Unfortunately this shows a tentative to discuss something with lack of enough important information about the topic and also there was not proper follow of most of this thread discussion.
First Internet Resources are not irrevocable assets that anyone who holds them can do whatever they like as if they own them. Unfortunately many people in this industry still don't know, but the fact that organizations hold a resource assigned to them does not mean they own it and therefore they must operate them under certain rules otherwise they risk to have them revoked, therefore they cannot be treated as an asset you purchased and may do whatever you like with it. If you purchase a server or a router it is yours and you sell or lease it for whatever amount you wish, but not with internet resources because you don't own them.
It is unimportant that anything APNIC may do against those who using IPv4 blocks illegally and may have them revoked because they should never have used in that way in first instance. A while back, when they became members they have signed a contract agreeing they would use the resources according to the rules. Therefore if someone decided to do out of what has been previously agreed they did it in their own risk and cannot allege they are "being affected".
Regardless how market evolves APNIC has full rights to revoke resources from members who are misusing resources not in accordance with the contracts they have signed and agreed. And by doing that APNIC is protecting community interests in detriment to individual and very specific interests that wants to use internet resources for proposes they were never conceived for.
Seems that people still didn't accept IPv4 exhaustion and keep hoping for something that will never come instead of learn once for all how to deal with it. There are ways to get blocks, for example via transfers and other specific methods, but the scenario many were used for decades doesn't exist anymore and still seems people keep trying to make up stuff to benefit their own specific interest in detriment of everybody else and of the fairness with everybody involved. If a company doesn't have enough money to afford a transfer I am sorry, but that is the new reality for a while. Learn how to deal with it and use other alternatives available like getting from upstreams - who provide connectivity - until there is budget to get address via a transfer for example. And not less important, stop hiding from IPv6 saying that will not revolve.
APNIC has all rights to fight in courts and is fully legally covered to enforce what members using internet resources signed and agreed for. Hardly judges will overwrite such agreement because they fell sorry that some people still didn't accept and learned to live with IPv4 exhaustion. No 'difficult' scenario gives the right to a member to void a contract they signed and agreed and win that in court.
These 'emotional arguments' of people and companies that will suffer if no leasing is allowed is a common argument from organizations who profit from IP leasing and don't build any internet connectivity and is already old one. If people keep insisting in doing things out of the rules sooner or later they will have to pay the price and they should know the risk before they even started.
IP addresses were not made to be rented from a resource holder who don't need them anymore to one that needs and could get them directly from the RIR. Regardless of the most noble reason, going against the rules doesn't make they valid.
Fernando
On 07/09/2022 22:49, Matthew Shearing wrote:
Just wanted to chime in here and follow up on Mike's point (and those of several others).
What APNIC has done by its previous conduct is create a scarce asset collected in the hands of a number of large providers, with increasingly less being issued to small providers. As with any scarce asset in human history, this necessarily creates all the prerequisites for a fee market.
Just like real estate, vehicles and other commodities, leasing is a natural evolution of scarcity in an asset class with direct utility. Right now, IPv4 blocks are like houses - some own them, but some don't have the capital resources to outright own the amount they need. Simply looking at the prices which IPv4 blocks are going for on the open market will make it clear that many smaller businesses are priced out.
Leasing represents a viable option for companies to access the blocks they need and pay manageable, monthly or yearly payments for the use of those blocks. Many businesses are reliant on these currently.
Saying that APNIC will outright ban leasing and that this will somehow benefit businesses is abjectly false. Not only will it disrupt many current business operations, but there is no guarantee that a market with more perverse incentives won't emerge afterwards.
In our view, APNIC has already demonstrated by its statements and conduct with this policy that they have little grasp on how (and why) asset markets evolve. They've also done nothing to dissuade us that the new 'status quo' after this policy change won't be worse than the current one - which operates relatively fine.
Practically, for APNIC to say there will be no meaningful damage to current users and businesses (who are APNIC members in their own right) it must answer the following questions:
1. What alternative does APNIC propose to the current IPv4 market and particularly, leasing options available to smaller companies and new entrants? 2. How will terminating leases currently on foot result in a better outcome for the businesses currently relying on them? 3. How will new IPv4 addresses be allocated, what timeframes and costs will be involved in this allocation? 4. Can APNIC give guarantees to current lessees who are reliant on IPv4 address leases that they can continue to access those addresses or will have replacements of similar value, at less cost, instantly after the change is made? 5. Is APNIC prepared to be held liable in lawsuits or a class action for the damages incurred by this policy change? Has it considered this risk and informed members accordingly?
It appears that those that will not be affected by this policy or those who already have large IPv4 blocks are some of the largest proponents of it - which makes sense. It is easy to vote for a change if it's only others that will be affected.
However, there are a large number of SME businesses out there who rely on these leases to run their operations. For them, this isn't just some merely intellectual exercise. Rather, it's a question of hundreds of thousands, or even millions, of dollars.
It's their ability to remain operational. It's their employees' livelihoods and those of their families. It's a core part of how they operate and for many, the foundation which they've built their business on.
This policy change seems to almost be a 'policy for policies sake'. It is clear that the repercussions of this were either not considered, or not even known, as the policy notes listed 'nil' negative effects. That this is the opinion of APNIC (and it seems, of a significant portion of the community) is incredibly concerning, because it couldn't be further from the truth.
Many real businesses will be affected by this, with real people. And the flippancy with which many within APNIC are treating this proposal shows a concerning lack of empathy towards that - and a failure to grasp the nature of IPv4 addresses as a modern asset class.
Without the above questions answered, I don't see how this policy vote can go ahead - and I would implore everyone considering this policy to reject it outright. There may be issues with the current IPv4 paradigm but this is definitely not the solution.
Kind Regards
Matt Shearing Chief Executive Officer
[X]
Brisbane, Australia (AEST) • matt@oneqode.commailto:matt@oneqode.com • +61 406 778 038
[OneQode™]https://www.oneqode.com/
[Follow us on LinkedIn]https://www.linkedin.com/company/oneqode/
From: Mike Burns mike@iptrading.commailto:mike@iptrading.com Sent: Thursday, 8 September 2022 6:52 AM To: 'Fernando Frediani' fhfrediani@gmail.commailto:fhfrediani@gmail.com; sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Alas, Fernando, there is no alternative “drug” for people to live without IPv4.
Banning leasing hurts the smallest and poorest of companies most.
And you cannot elucidate any “major damages” suffered where leasing has actually, in reality, occurred for many years at RIPE.
Yet you use this evidence-free assertion as your major argument against leasing.
That some kind of serious damage will occur to the RIR system.
As a broker who as to talk to actual, real companies in need, who can’t afford to pay upfront, can you tell me what I should say when they ask me why leasing is forbidden? If I say it’s to avoid “major damages” and they ask what they are, can you tell me?
What major damages?
Regards, Mike
From: Fernando Frediani <fhfrediani@gmail.commailto:fhfrediani@gmail.com> Sent: Wednesday, September 7, 2022 4:33 PM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Do you understand the argument that certain drugs can alleviate certain pains but they remain forbidden because they cause a major damage to society in long term and there are alternatives for people be able to still live without have to use those type of damageable mechanisms. Companies can also live without that and still have other legally allowed mechanisms.
This discussion is unnecessary for this policy discussion as what it proposes is to make something *already forbidden* clear in to the text, not to discuss if leasing should exist or not.
If anyone opposes it please take attention to provide arguments and suggestions on how to address the issues raised about what the proposal really proposes.
Regards Fernando
On 07/09/2022 14:12, Mike Burns wrote:
Hi Fernando,
Do you understand my argument that smaller business cannot afford the full upfront payment but can afford monthly lease payments?
Please address that simple argument by telling me how the small business benefits by not having the lease option, but only having the purchase option.
Regards, Mike
From: Fernando Frediani fhfrediani@gmail.commailto:fhfrediani@gmail.com Sent: Wednesday, September 7, 2022 1:01 PM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
IP Leasing is already banned in most RIRs and should stay as is.
But yes it does help as it doesn't push even further up IPv4 pricing and makes it easier for these small companies to get IPv4 via the proper and allowed way which are transfers. Other then diverting totally the propose o IPv4 Allocation, Leasing market contributes significantly to price increasing fueling the market with more demand for that type of very wrong thing.
RIPE is normally not a good example for certain policies which don't seem to have receptivity in discussions on all other RIRs.
There are still mechanisms that allow companies to get IP addressing either directly from the RIR, via Transfers which is a pretty common way or from the Upstream providers. People may not have got used yet to learn to live with less address and they may believe they need a bunch of address.
IP Leasing will never help small companies. The ones who really benefit from it are the IP broker companies who profit from them and also the resource holders which don't justify anymore to keep those addresses and are also profiting from something that should have been re-assigned directly to those who really need and justify for them in order to build Internet Infrastructure and Connectivity and instead are leasing a asset they don't own.
Fernando
On 07/09/2022 12:39, Mike Burns wrote:
Hi Fernando,
So your argument is that banning leasing actually helps smaller companies in their quest for IPv4?
Are you aware that RIPE has allowed leasing for many years but is still a functioning RIR whose IPv4 sale prices are not more expensive despite the history of leasing there?
Can you reconcile that with your argument that leasing will raise prices for both leasing and transfers?
Are you aware that it’s not always possible to get IPv4 blocks from the company that is providing you with connectivity?
Regards, Mike
From: Fernando Frediani fhfrediani@gmail.commailto:fhfrediani@gmail.com Sent: Wednesday, September 7, 2022 11:27 AM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
This is exactly the opposite.
Allowing IP leasing to happen more than just tottaly divert the propose of IP assignments by RIRs it make it bad specially for smaller companies as it increases the cost for both leasing and transfers in long term. The cost of leasing is based on the transfer and if leasing is allowed then transfer prices will always go up which makes it even harder for smaller companies to go into the market.
Any form of IP leasing without a direct connection relationship to provide a connectivity service makes it more expensive for smaller companies to get IP addresses to operate.
Fernando
On 07/09/2022 11:15, Mike Burns wrote:
Hi Jordi,
It’s plain you feel that we should do all possible to raise the price of IPv4 and make it unattainable for small business in the vain hope that this will drive IPv6 adoption.
I don’t think making IPv4 more difficult to acquire is the job of the RIR system.
You have not addressed the inability of smaller companies to acquire necessary IPv4 blocks if you ban leasing.
Is that something you are comfortable with, in pursuit of the IPv6 grail?
It’s okay with you that this policy prevents small companies from growing?
Regards, Mike
From: JORDI PALET MARTINEZ via sig-policy sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Sent: Wednesday, September 7, 2022 10:11 AM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Actually, I must disagree …
If organizations having unused resources, they need to transfer them or return them to the RIR. If prices keep going high, that could encourage faster IPv6 adoption, then transfer prices will go down, up to “no value”. It takes time, but it is just market.
Those that have more money, have more facilities to do a faster transition and not bother about IPv4.
Regards,
Jordi
@jordipalet
El 7/9/22, 16:05, "Mike Burns" <mike@iptrading.commailto:mike@iptrading.com> escribió:
Hello,
Per Gaurav’s statement that “only those with millions of dollars can think of getting ips”, this community should oppose this policy.
Because the only way small companies can afford to get ips today is by leasing them. The same way the small company can’t afford to purchase a big office building but instead rents an office. Leasing is the only way to finance IPv4 acquisitions today. No bank or other entity that I am aware of will do it. Purchasing addresses requires full upfront payment, but leasing allow for much smaller monthly payments.
If this community wants to ensure only the largest and richest companies can acquire new addresses, ban leasing.
But if the community tries to ban something with such a large business motivation behind it, it will find itself struggling against a powerful foe.
And for what purpose do we punish the small businesses? Leasing puts addresses in the hands of those who need them to build and operate networks. Isn’t that the primary goal of the RIR system?
Regards,
Mike
El 2/9/22, 9:23, "Gaurav Kansal" <gaurav.kansal@nic.inmailto:gaurav.kansal@nic.in> escribió:
Hello everyone,
In my opinion, even Trading of IPs (leave apart the lease for making dollars) in the name of transfers must be stopped.
If organisation doesn’t need IPs , then those must be returned back so that smaller organisations can get it from the RIR.
Currently, only the one which have millions of dollars can think of getting IPs. In today’s scenario, no one can start the Data Centre, ISP business without investing millions in IPs. Even education and research org doesn’t have an option to get IPs from RIR.
This is like horse trading and isn’t a good practice for the community as a whole.
Regards,
Gaurav Kansal
On 02-Sep-2022, at 12:20, rajesh@smartlinkindia.commailto:rajesh@smartlinkindia.com wrote:
Dear Team,
As Mr. Satoru, mentioned there are changes, but if carefully implemented in phased manner, unauthorised leasing can be stopped.
For example in first phase, leasing among countries can be stopped, if the owner company doesn't provide any services beyond its home country. For example if a company in India doesn't have any operation in Singapore or Japan , can't lease resources to those companies in Singapore or Japan. This can be verified by taking business registration documents of both lease and lessor.
Once this is done same may be granularized at RIR level, where in country like India, leasing can be restricted to the licensed service area for service provider within their designated service area.
This may stop majority of issues, barring few exceptions.
Some more brainstorming is required for better understanding and precise implementation.
Regards,
Rajesh Panwala
For Smartlink Solutions Pvt Ltd
+91-9227886001
+91-9426110781
On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru <stsuruma@bbix.netmailto:stsuruma@bbix.net> wrote:
Dear Colleagues,
I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team..
I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals.
Many participants support the intent of the proposal but felt that implementation would be challenging.
(comment details) - It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses. - I think this proposal would be useful if the concept of leasing is accurately defined. - Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement.
Regards,
Satoru Tsurumaki / JPOPF Steering Team
2022年8月26日(金) 17:27 Shaila Sharmin <shaila.sharmin.ovi@gmail.commailto:shaila.sharmin.ovi@gmail.com>:
Dear SIG members,
A new version of the proposal "prop-148-v002: Clarification - Leasing of Resources is not Acceptable" has been sent to the Policy SIG for review.
Information about earlier versions is available from:
http://www.apnic.net/policy/proposals/prop-148
You are encouraged to express your views on the proposal:
- Do you support or oppose the proposal?
- Is there anything in the proposal that is not clear?
- What changes could be made to this proposal to make it more effective?
Please find the text of the proposal below.
Regards, Bertrand, Shaila, and Ching-Heng APNIC Policy SIG Chairs
prop-148-v002: Clarification - Leasing of Resources is not Acceptable
Proposer: Jordi Palet Martinez (jordi.palet@theipv6company.comAnupammailto:jordi.palet@theipv6company.comAnupam) Amrita Choudhury (amritachoudhury@ccaoi.inmailto:amritachoudhury@ccaoi.in) Fernando Frediani (fhfredani@gmail.commailto:fhfredani@gmail.com)
- Problem statement
RIRs have been conceived to manage, allocate and assign resources according to need, in such a 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 delegated by APNIC or an NIR, the justification of the need implies the need to use on their own infrastructure and/or network connectivity services provided directly to customers. As a result, any form of IP address leasing is unacceptable, 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.
APNIC may proactively investigate those cases and also initiate the investigation in case of reports by means of a form, email address or other means developed by APNIC.
If any form of leasing, regardless of when the delegation has been issued, is confirmed by an APNIC investigation, it will be considered a policy violation and revocation may apply against any account holders who are leasing or using them for any purposes not specified in the initial request.
- Advantages / Disadvantages
Advantages: Fulfilling the objective above indicated and making the policy clear.
Disadvantages: None.
- Impact on resource holders
None.
- 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 _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.netmailto:sig-policy-leave@lists.apnic.net
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Hi Andrew:
Yes, policies need to be well written.
But the fundamental question here is, where is the policy limitation? Or even more simply put, what is policy?
In my view, *policy is a set of operation principles to best operate in a global coodicated registration database, nothing more, nothing less.*
RIR are created as bookkeepers, and they should and have to stay that way.
As you rightfully point out, someone using the master power to alter the registration database that APNIC has, to
1. Interfere how business is being operated.
2. To claim APNIC owns the unique registration value of the IP address(or the community, but since those people believe APNIC can reclaim and redistribute at its will, so practically APNIC)
3. To threaten to disconnect end users if its member does not obey their interference.
Is simply disconnects itself from reality. APNIC is a small private company, it can not tell how the other party operates their business, operating a registration database does not give you god-like power to put whatever into policy and use disconnection to threaten people.
And this is exactly what this policy, and many of Jordi's other policies are trying to achieve.
Only nations have such power to impose regulations, APNIC does not.
Hence in my last email, unless and until Jordi can show he actually has most members agreeing with him by actual petition, I think an empty claim of "community will" does not hold water.
It's ok to make operation principles, it is not ok to use so called policy to tell people how to run their business.
In other words, I believe this policy, and many other policy jordi have proposed, are out of scope for the policy discussion.
Unless, someone believes policy made here, has the same power as a nation's regulation.
On Thu, 8 Sept 2022 at 14:54, Andrew Yager andrew@rwts.com.au wrote:
I disagree with many of your assertions here about where policy and governance sit and the necessity of them.
APNIC needs to do more than charge fees and make money. It does provide a necessary and vital role in the health of the internet.
This is precisely why policy groups need to exist and precisely why policies need to be well written, sensible and offer value. But, the burden on policy makers is particularly to ensure their assumptions, foundational principals and statements are in fact correct, balanced and forward looking.
Policies should be few, measured, necessary and clear. Unfortunately I don’t think this proposal stacks up for the reasons I’ve already outlined.
Andrew
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*From:* Lu Heng h.lu@anytimechinese.com *Sent:* Thursday, September 8, 2022 4:47:45 PM *To:* Andrew Yager andrew@rwts.com.au *Cc:* Fernando Frediani fhfrediani@gmail.com; sig-policy@lists.apnic.net sig-policy@lists.apnic.net *Subject:* Re: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Hi
Let me ask Secretariat a simple question:
There is currently one of largest APNIC members who are leasing IP addresses to millions of end users(I won't name who that is but people in business should know), if this policy is adopted, how will the secretariat plan to enforce it without being sued out of existence?
The problem of this policy development process is, the real community is not involved. The real community is the near 10000 members and billions of end users those members represent.
Yes, it could be argued it is their fault not to join this policy process, but in reality, most don't care.
So this small room of people, who have never actually had any real memberbase support, believe they can make policy and use APNIC's monopoly position to do things, is simply disconnecting itself from reality.
Before Jordi and Fernado claim "community wants people to return space", how about getting 50% members' signatures to prove that point?
And the transfer data simply proves no one wants to return the space, and the real community wants a market.
I believe in order for RIR to survive, the small room of policy specialists that claim to represent the entire earth's interest(especially Jordi who makes policy proposals everywhere but failed to even have 10% of members supporting him), has to stop.
Policy needs to be made by the real members of APNIC, and real end users who are using the internet and someone can get a large percentage of the population to agree to them.
Otherwise, let APNIC stick to the bookkeeper, that is what is all created for.
On Thu, 8 Sept 2022 at 11:14, Andrew Yager andrew@rwts.com.au wrote:
Fernando - you repeatedly state that there is an issue this policy is addressing. This is your base assumption.
I reiterate that to date the existing mechanisms are sufficient.
Feel free to demonstrate that they are not with evidence.
Andrew
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*From:* Fernando Frediani fhfrediani@gmail.com *Sent:* Thursday, September 8, 2022 1:11:49 PM *To:* sig-policy@lists.apnic.net sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Andrew your understanding about my statements is wrong. it is unnecessary the secretariat to confirm such points, unless you have a concern about them.
There is an issue with leasing existing despite the current rules don't allow them. And all I said they should always be able to enforce regardless the scenario and have all legal cover and support to do this in courts if necessary. This proposal helps text helps them further to make it even clear to a court what can and cannot be done with Internet Resources.
Fernando On 08/09/2022 00:08, Andrew Yager wrote:
In response to your last paragaph
Can the secretariat confirm:
- they have an issue with enforcement now
- They have an active need that they are unable to address under this
framework
- That the current membership agreement is inadequate to allow them to
fulfil the tasks they have
Your statements infer that there is an issue, they can’t enforce behaviour and that the current policies are inadequate. I’m yet to see any evidence of this.
Andre
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*From:* Fernando Frediani fhfrediani@gmail.com fhfrediani@gmail.com *Sent:* Thursday, September 8, 2022 1:01:40 PM *To:* sig-policy@lists.apnic.net sig-policy@lists.apnic.net sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Hi Matt, I am sorry but I don't really take some of these emotional arguments because they are created mostly by the ones who are most taking advantage from it. There are ways in the *real* world but there are also adjustments that must be made and many still seem to not have realized after a while. One thing I find it wrong is to blame APNIC for it and suggesting they should not stop this, despite the illegality presented and therefore the unfairness with the whole of community impacted.
It seems interesting however your idea of some tentative to transfer resources definitely to smaller companies, but not only from the larger holders but from *any* holder who is leasing them. In order words an idea of a proposal could be to allow a company who leases from a resources holders to have those resources forcibly transferred definitely to them regardless the permission of the resources holder if a leasing it shown to be happening there.
Sorry to disagree, but appealing to leasing as the only option available at this stage is a easy path to make it worst a scenario that is only causing more and more unfairness to all. If it is wrong - and it is - it must be stopped *right now* and how to act about what exists should be carried on being discussed (in another thread) in order to help APNIC how to deal with cases properly and have all the support it may require.
Regards Fernando On 07/09/2022 23:39, Matthew Shearing wrote:
Fernando, very simply – if it was already against the rules, why this policy? There should be no need for clarification if this was already ‘illegal’ or ‘against the rules’ as you say. What is the point of this policy if it’s already clear?
Further, you keep talking about IPv4 exhaustion and that we need to ‘deal with it’. The fact there exists a leasing market in the first place means that there are plenty of unused IPv4 resources. Otherwise, there would be no IPv4 addresses to lease.
If APNIC wants to tackle ‘misuse’, that is also fine. However, why not start with those who have plenty of IP space? Why not build in guarantees that APNIC it revokes space from a large holder, any lessees currently using that space will get access to those IPv4 addresses, as they are the ones using them? Why is none of this even being discussed? It’s incredibly obvious this policy hurts mainly the smaller companies, by going after *leases*, not the big holdings themselves.
By saying *‘there are ways to get blocks’* also tells me very clearly that you’ve either not tried recently, or you’re just willfully ignorant. For many companies, leasing is the only feasible ways to get blocks because we are priced out.
Ideologically, we are all in agreement that an IPv6 world would be amazing. Unfortunately, those of us running businesses need to exist here in the real world, not in your imaginary world where we get everything we would like. If you want to help change that, we’ll all be here, cheering you on. Until then, businesses like ours don’t have the luxury of sitting around wishing – we’ve got customers we need to serve and employees we need to pay.
These ‘emotional’ arguments are common because they are *real*. They are for businesses that exist in the real world, in an IP environment that APNIC (and other registrars) created. APNIC allowed the leasing paradigm to occur and did nothing about it. This is not some new thing – it is a mature market that has existed for a long time.
It is incredibly irresponsible for APNIC to try and roll it back now, after many years of inaction, and disingenuous for people like you to somehow claim businesses that are just trying to do the best they can in the environment we currently have are somehow at fault. This problem can be laid squarely at the feet of APNIC – and for that reason, it can and will be held liable by those damaged if any changes are made now.
This policy is approaching everything from the wrong direction. Its implementation will punish the smallest businesses while doing nothing about the largest legacy holders. If APNIC is serious about the IPv4 allocation issue, it should start with the swathes of latent resources and move backwards. This should be tempered by protections and policies which ensure smaller businesses aren’t ruined in the process. Maybe once that is solved, in several years time, it will be time to revisit this topic. For now though, this is far too premature.
The reality is this – for many of us, leasing is right now the only viable option. Taking that away without proposing any kind of genuine alternatives (ie not the handwavium generalisations you’ve been engaging in) is reckless and will result in incredible damage to members who have simply been doing their best in an environment APNIC created in the first place.
Cheers,
*Matt Shearing* *Chief Executive Officer*
Brisbane, Australia (AEST) • matt@oneqode.com • +61 406 778 038
[image: OneQode™] https://www.oneqode.com/
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*From:* Fernando Frediani fhfrediani@gmail.com fhfrediani@gmail.com *Sent:* Thursday, 8 September 2022 12:15 PM *To:* sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Unfortunately this shows a tentative to discuss something with lack of enough important information about the topic and also there was not proper follow of most of this thread discussion.
First Internet Resources are not irrevocable assets that anyone who holds them can do whatever they like as if they own them. Unfortunately many people in this industry still don't know, but the fact that organizations hold a resource assigned to them does not mean they own it and therefore they must operate them under certain rules otherwise they risk to have them revoked, therefore they cannot be treated as an asset you purchased and may do whatever you like with it. If you purchase a server or a router it is yours and you sell or lease it for whatever amount you wish, but not with internet resources because you don't own them.
It is unimportant that anything APNIC may do against those who using IPv4 blocks illegally and may have them revoked because they should never have used in that way in first instance. A while back, when they became members they have signed a contract agreeing they would use the resources according to the rules. Therefore if someone decided to do out of what has been previously agreed they did it in their own risk and cannot allege they are "being affected".
Regardless how market evolves APNIC has full rights to revoke resources from members who are misusing resources not in accordance with the contracts they have signed and agreed. And by doing that APNIC is protecting community interests in detriment to individual and very specific interests that wants to use internet resources for proposes they were never conceived for.
Seems that people still didn't accept IPv4 exhaustion and keep hoping for something that will never come instead of learn once for all how to deal with it. There are ways to get blocks, for example via transfers and other specific methods, but the scenario many were used for decades doesn't exist anymore and still seems people keep trying to make up stuff to benefit their own specific interest in detriment of everybody else and of the fairness with everybody involved. If a company doesn't have enough money to afford a transfer I am sorry, but that is the new reality for a while. Learn how to deal with it and use other alternatives available like getting from upstreams - who provide connectivity - until there is budget to get address via a transfer for example. And not less important, stop hiding from IPv6 saying that will not revolve.
APNIC has all rights to fight in courts and is fully legally covered to enforce what members using internet resources signed and agreed for. Hardly judges will overwrite such agreement because they fell sorry that some people still didn't accept and learned to live with IPv4 exhaustion. No 'difficult' scenario gives the right to a member to void a contract they signed and agreed and win that in court.
These 'emotional arguments' of people and companies that will suffer if no leasing is allowed is a common argument from organizations who profit from IP leasing and don't build any internet connectivity and is already old one. If people keep insisting in doing things out of the rules sooner or later they will have to pay the price and they should know the risk before they even started.
IP addresses were not made to be rented from a resource holder who don't need them anymore to one that needs and could get them directly from the RIR. Regardless of the most noble reason, going against the rules doesn't make they valid.
Fernando
On 07/09/2022 22:49, Matthew Shearing wrote:
Just wanted to chime in here and follow up on Mike's point (and those of several others).
What APNIC has done by its previous conduct is create a scarce asset collected in the hands of a number of large providers, with increasingly less being issued to small providers. As with any scarce asset in human history, this necessarily creates all the prerequisites for a fee market.
Just like real estate, vehicles and other commodities, leasing is a natural evolution of scarcity in an asset class with direct utility. Right now, IPv4 blocks are like houses - some own them, but some don't have the capital resources to outright own the amount they need. Simply looking at the prices which IPv4 blocks are going for on the open market will make it clear that many smaller businesses are priced out.
Leasing represents a viable option for companies to access the blocks they need and pay manageable, monthly or yearly payments for the use of those blocks. Many businesses are reliant on these currently.
Saying that APNIC will outright ban leasing and that this will somehow benefit businesses is abjectly false. Not only will it disrupt many current business operations, but there is no guarantee that a market with more perverse incentives won't emerge afterwards.
In our view, APNIC has already demonstrated by its statements and conduct with this policy that they have little grasp on how (and why) asset markets evolve. They've also done nothing to dissuade us that the new 'status quo' after this policy change won't be worse than the current one - which operates relatively fine.
Practically, for APNIC to say there will be no meaningful damage to current users and businesses (who are APNIC members in their own right) it must answer the following questions:
- What alternative does APNIC propose to the current IPv4 market and
particularly, leasing options available to smaller companies and new entrants? 2. How will terminating leases currently on foot result in a better outcome for the businesses currently relying on them? 3. How will new IPv4 addresses be allocated, what timeframes and costs will be involved in this allocation? 4. Can APNIC give guarantees to current lessees who are reliant on IPv4 address leases that they can continue to access those addresses or will have replacements of similar value, at less cost, instantly after the change is made? 5. Is APNIC prepared to be held liable in lawsuits or a class action for the damages incurred by this policy change? Has it considered this risk and informed members accordingly?
It appears that those that will not be affected by this policy or those who already have large IPv4 blocks are some of the largest proponents of it
- which makes sense. It is easy to vote for a change if it's only others
that will be affected.
However, there are a large number of SME businesses out there who rely on these leases to run their operations. For them, this isn't just some merely intellectual exercise. Rather, it's a question of hundreds of thousands, or even millions, of dollars.
It's their ability to remain operational. It's their employees' livelihoods and those of their families. It's a core part of how they operate and for many, the foundation which they've built their business on.
This policy change seems to almost be a *'policy for policies sake'*. It is clear that the repercussions of this were either not considered, or not even known, as the policy notes listed 'nil' negative effects. That this is the opinion of APNIC (and it seems, of a significant portion of the community) is incredibly concerning, because it couldn't be further from the truth.
Many real businesses will be affected by this, with real people. And the flippancy with which many within APNIC are treating this proposal shows a concerning lack of empathy towards that - and a failure to grasp the nature of IPv4 addresses as a modern asset class.
Without the above questions answered, I don't see how this policy vote can go ahead - and I would implore everyone considering this policy to reject it outright. There may be issues with the current IPv4 paradigm but this is definitely not the solution.
Kind Regards
*Matt Shearing* *Chief Executive Officer*
Brisbane, Australia (AEST) • matt@oneqode.com • +61 406 778 038
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*From:* Mike Burns mike@iptrading.com mike@iptrading.com *Sent:* Thursday, 8 September 2022 6:52 AM *To:* 'Fernando Frediani' fhfrediani@gmail.com fhfrediani@gmail.com; sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Alas, Fernando, there is no alternative “drug” for people to live without IPv4.
Banning leasing hurts the smallest and poorest of companies most.
And you cannot elucidate any “major damages” suffered where leasing has actually, in reality, occurred for many years at RIPE.
Yet you use this evidence-free assertion as your major argument against leasing.
That some kind of serious damage will occur to the RIR system.
As a broker who as to talk to actual, real companies in need, who can’t afford to pay upfront, can you tell me what I should say when they ask me why leasing is forbidden? If I say it’s to avoid “major damages” and they ask what they are, can you tell me?
What major damages?
Regards, Mike
*From:* Fernando Frediani fhfrediani@gmail.com *Sent:* Wednesday, September 7, 2022 4:33 PM *To:* sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Do you understand the argument that certain drugs can alleviate certain pains but they remain forbidden because they cause a major damage to society in long term and there are alternatives for people be able to still live without have to use those type of damageable mechanisms. Companies can also live without that and still have other legally allowed mechanisms.
This discussion is unnecessary for this policy discussion as what it proposes is to make something *already forbidden* clear in to the text, not to discuss if leasing should exist or not.
If anyone opposes it please take attention to provide arguments and suggestions on how to address the issues raised about what the proposal really proposes.
Regards Fernando
On 07/09/2022 14:12, Mike Burns wrote:
Hi Fernando,
Do you understand my argument that smaller business cannot afford the full upfront payment but can afford monthly lease payments?
Please address that simple argument by telling me how the small business benefits by not having the lease option, but only having the purchase option.
Regards, Mike
*From:* Fernando Frediani fhfrediani@gmail.com fhfrediani@gmail.com *Sent:* Wednesday, September 7, 2022 1:01 PM *To:* sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
IP Leasing is already banned in most RIRs and should stay as is.
But yes it does help as it doesn't push even further up IPv4 pricing and makes it easier for these small companies to get IPv4 via the proper and allowed way which are transfers. Other then diverting totally the propose o IPv4 Allocation, Leasing market contributes significantly to price increasing fueling the market with more demand for that type of very wrong thing.
RIPE is normally not a good example for certain policies which don't seem to have receptivity in discussions on all other RIRs.
There are still mechanisms that allow companies to get IP addressing either directly from the RIR, via Transfers which is a pretty common way or from the Upstream providers. People may not have got used yet to learn to live with less address and they may believe they need a bunch of address.
IP Leasing will never help small companies. The ones who really benefit from it are the IP broker companies who profit from them and also the resource holders which don't justify anymore to keep those addresses and are also profiting from something that should have been re-assigned directly to those who really need and justify for them in order to build Internet Infrastructure and Connectivity and instead are leasing a asset they don't own.
Fernando
On 07/09/2022 12:39, Mike Burns wrote:
Hi Fernando,
So your argument is that banning leasing actually helps smaller companies in their quest for IPv4?
Are you aware that RIPE has allowed leasing for many years but is still a functioning RIR whose IPv4 sale prices are not more expensive despite the history of leasing there?
Can you reconcile that with your argument that leasing will raise prices for both leasing and transfers?
Are you aware that it’s not always possible to get IPv4 blocks from the company that is providing you with connectivity?
Regards, Mike
*From:* Fernando Frediani fhfrediani@gmail.com fhfrediani@gmail.com *Sent:* Wednesday, September 7, 2022 11:27 AM *To:* sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
This is exactly the opposite.
Allowing IP leasing to happen more than just tottaly divert the propose of IP assignments by RIRs it make it bad specially for smaller companies as it increases the cost for both leasing and transfers in long term. The cost of leasing is based on the transfer and if leasing is allowed then transfer prices will always go up which makes it even harder for smaller companies to go into the market.
Any form of IP leasing without a direct connection relationship to provide a connectivity service makes it more expensive for smaller companies to get IP addresses to operate.
Fernando
On 07/09/2022 11:15, Mike Burns wrote:
Hi Jordi,
It’s plain you feel that we should do all possible to raise the price of IPv4 and make it unattainable for small business in the vain hope that this will drive IPv6 adoption.
I don’t think making IPv4 more difficult to acquire is the job of the RIR system.
You have not addressed the inability of smaller companies to acquire necessary IPv4 blocks if you ban leasing.
Is that something you are comfortable with, in pursuit of the IPv6 grail?
It’s okay with you that this policy prevents small companies from growing?
Regards, Mike
*From:* JORDI PALET MARTINEZ via sig-policy sig-policy@lists.apnic.net sig-policy@lists.apnic.net *Sent:* Wednesday, September 7, 2022 10:11 AM *To:* sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Actually, I must disagree …
If organizations having unused resources, they need to transfer them or return them to the RIR. If prices keep going high, that could encourage faster IPv6 adoption, then transfer prices will go down, up to “no value”. It takes time, but it is just market.
Those that have more money, have more facilities to do a faster transition and not bother about IPv4.
Regards,
Jordi
@jordipalet
El 7/9/22, 16:05, "Mike Burns" mike@iptrading.com escribió:
Hello,
Per Gaurav’s statement that “only those with millions of dollars can think of getting ips”, this community should oppose this policy.
Because the only way small companies can afford to get ips today is by leasing them. The same way the small company can’t afford to purchase a big office building but instead rents an office. Leasing is the only way to finance IPv4 acquisitions today. No bank or other entity that I am aware of will do it. Purchasing addresses requires full upfront payment, but leasing allow for much smaller monthly payments.
If this community wants to ensure only the largest and richest companies can acquire new addresses, ban leasing.
But if the community tries to ban something with such a large business motivation behind it, it will find itself struggling against a powerful foe.
And for what purpose do we punish the small businesses? Leasing puts addresses in the hands of those who need them to build and operate networks. Isn’t that the primary goal of the RIR system?
Regards,
Mike
El 2/9/22, 9:23, "Gaurav Kansal" gaurav.kansal@nic.in escribió:
Hello everyone,
In my opinion, even Trading of IPs (leave apart the lease for making dollars) in the name of transfers must be stopped.
If organisation doesn’t need IPs , then those must be returned back so that smaller organisations can get it from the RIR.
Currently, only the one which have millions of dollars can think of getting IPs. In today’s scenario, no one can start the Data Centre, ISP business without investing millions in IPs. Even education and research org doesn’t have an option to get IPs from RIR.
This is like horse trading and isn’t a good practice for the community as a whole.
Regards,
Gaurav Kansal
On 02-Sep-2022, at 12:20, rajesh@smartlinkindia.com wrote:
Dear Team,
As Mr. Satoru, mentioned there are changes, but if carefully implemented in phased manner, unauthorised leasing can be stopped.
For example in first phase, leasing among countries can be stopped, if the owner company doesn't provide any services beyond its home country. For example if a company in India doesn't have any operation in Singapore or Japan , can't lease resources to those companies in Singapore or Japan. This can be verified by taking business registration documents of both lease and lessor.
Once this is done same may be granularized at RIR level, where in country like India, leasing can be restricted to the licensed service area for service provider within their designated service area.
This may stop majority of issues, barring few exceptions.
Some more brainstorming is required for better understanding and precise implementation.
Regards,
Rajesh Panwala
For Smartlink Solutions Pvt Ltd
+91-9227886001
+91-9426110781
On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru stsuruma@bbix.net wrote:
Dear Colleagues,
I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team..
I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals.
Many participants support the intent of the proposal but felt that implementation would be challenging.
(comment details)
- It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses.
- I think this proposal would be useful if the concept of leasing is
accurately defined.
- Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement.
Regards,
Satoru Tsurumaki / JPOPF Steering Team
2022年8月26日(金) 17:27 Shaila Sharmin shaila.sharmin.ovi@gmail.com:
Dear SIG members,
A new version of the proposal "prop-148-v002: Clarification - Leasing of Resources is not Acceptable" has been sent to the Policy SIG for review.
Information about earlier versions is available from:
http://www.apnic.net/policy/proposals/prop-148
You are encouraged to express your views on the proposal:
- Do you support or oppose the proposal?
- Is there anything in the proposal that is not clear?
- What changes could be made to this proposal to make it more
effective?
Please find the text of the proposal below.
Regards, Bertrand, Shaila, and Ching-Heng APNIC Policy SIG Chairs
prop-148-v002: Clarification - 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 a 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 delegated by APNIC or an NIR, the justification of the need implies the need to use on their own infrastructure and/or network connectivity services provided directly to customers. As a result, any form of IP address leasing is unacceptable, 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.
APNIC may proactively investigate those cases and also initiate the investigation in case of reports by means of a form, email address or other means developed by APNIC.
If any form of leasing, regardless of when the delegation has been issued, is confirmed by an APNIC investigation, it will be considered a policy violation and revocation may apply against any account holders who are leasing or using them for any purposes not specified in the initial request.
- Advantages / Disadvantages
Advantages: Fulfilling the objective above indicated and making the policy clear.
Disadvantages: None.
- Impact on resource holders
None.
- 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 _______________________________________________ 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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Kind regards. Lu
This thread is probably not the place for this discussion - but the internet as a distributed, co-regulated body is absolutely partly regulated by APNIC - and APNIC works hand in hand with government to do that.
They absolutely have some level of authority to the extent of the jurisdiction.
Let’s try and keep this conversation to this policy though.
Leasing of the type this policy seeks to restrict is currently prohibited by the member agreement. Although this policy may accidentally do more than it intends. Or maybe that’s the intention.
But this policy does not need to exist. All the required things are already in the member agreement, and I’m yet to see any evidence that there is, in fact, a problem with the status quo that requires this policy or is likely to.
This policy shouldn’t proceed - precisely because it’s not needed.
If we need to have a discussion about members returning unused resources, someone should propose such a policy and debate it.
Andrew
Get Outlook for iOShttps://aka.ms/o0ukef ________________________________ From: Lu Heng h.lu@anytimechinese.com Sent: Thursday, September 8, 2022 5:22:56 PM To: Andrew Yager andrew@rwts.com.au Cc: Fernando Frediani fhfrediani@gmail.com; sig-policy@lists.apnic.net sig-policy@lists.apnic.net Subject: Re: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Hi Andrew:
Yes, policies need to be well written.
But the fundamental question here is, where is the policy limitation? Or even more simply put, what is policy?
In my view, policy is a set of operation principles to best operate in a global coodicated registration database, nothing more, nothing less.
RIR are created as bookkeepers, and they should and have to stay that way.
As you rightfully point out, someone using the master power to alter the registration database that APNIC has, to
1. Interfere how business is being operated.
2. To claim APNIC owns the unique registration value of the IP address(or the community, but since those people believe APNIC can reclaim and redistribute at its will, so practically APNIC)
3. To threaten to disconnect end users if its member does not obey their interference.
Is simply disconnects itself from reality. APNIC is a small private company, it can not tell how the other party operates their business, operating a registration database does not give you god-like power to put whatever into policy and use disconnection to threaten people.
And this is exactly what this policy, and many of Jordi's other policies are trying to achieve.
Only nations have such power to impose regulations, APNIC does not.
Hence in my last email, unless and until Jordi can show he actually has most members agreeing with him by actual petition, I think an empty claim of "community will" does not hold water.
It's ok to make operation principles, it is not ok to use so called policy to tell people how to run their business.
In other words, I believe this policy, and many other policy jordi have proposed, are out of scope for the policy discussion.
Unless, someone believes policy made here, has the same power as a nation's regulation.
On Thu, 8 Sept 2022 at 14:54, Andrew Yager <andrew@rwts.com.aumailto:andrew@rwts.com.au> wrote: I disagree with many of your assertions here about where policy and governance sit and the necessity of them.
APNIC needs to do more than charge fees and make money. It does provide a necessary and vital role in the health of the internet.
This is precisely why policy groups need to exist and precisely why policies need to be well written, sensible and offer value. But, the burden on policy makers is particularly to ensure their assumptions, foundational principals and statements are in fact correct, balanced and forward looking.
Policies should be few, measured, necessary and clear. Unfortunately I don’t think this proposal stacks up for the reasons I’ve already outlined.
Andrew
Get Outlook for iOShttps://aka.ms/o0ukef ________________________________ From: Lu Heng <h.lu@anytimechinese.commailto:h.lu@anytimechinese.com> Sent: Thursday, September 8, 2022 4:47:45 PM To: Andrew Yager <andrew@rwts.com.aumailto:andrew@rwts.com.au> Cc: Fernando Frediani <fhfrediani@gmail.commailto:fhfrediani@gmail.com>; sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net <sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net> Subject: Re: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Hi
Let me ask Secretariat a simple question:
There is currently one of largest APNIC members who are leasing IP addresses to millions of end users(I won't name who that is but people in business should know), if this policy is adopted, how will the secretariat plan to enforce it without being sued out of existence?
The problem of this policy development process is, the real community is not involved. The real community is the near 10000 members and billions of end users those members represent.
Yes, it could be argued it is their fault not to join this policy process, but in reality, most don't care.
So this small room of people, who have never actually had any real memberbase support, believe they can make policy and use APNIC's monopoly position to do things, is simply disconnecting itself from reality.
Before Jordi and Fernado claim "community wants people to return space", how about getting 50% members' signatures to prove that point?
And the transfer data simply proves no one wants to return the space, and the real community wants a market.
I believe in order for RIR to survive, the small room of policy specialists that claim to represent the entire earth's interest(especially Jordi who makes policy proposals everywhere but failed to even have 10% of members supporting him), has to stop.
Policy needs to be made by the real members of APNIC, and real end users who are using the internet and someone can get a large percentage of the population to agree to them.
Otherwise, let APNIC stick to the bookkeeper, that is what is all created for.
On Thu, 8 Sept 2022 at 11:14, Andrew Yager <andrew@rwts.com.aumailto:andrew@rwts.com.au> wrote: Fernando - you repeatedly state that there is an issue this policy is addressing. This is your base assumption.
I reiterate that to date the existing mechanisms are sufficient.
Feel free to demonstrate that they are not with evidence.
Andrew
Get Outlook for iOShttps://aka.ms/o0ukef ________________________________ From: Fernando Frediani <fhfrediani@gmail.commailto:fhfrediani@gmail.com> Sent: Thursday, September 8, 2022 1:11:49 PM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net <sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net> Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Andrew your understanding about my statements is wrong. it is unnecessary the secretariat to confirm such points, unless you have a concern about them.
There is an issue with leasing existing despite the current rules don't allow them. And all I said they should always be able to enforce regardless the scenario and have all legal cover and support to do this in courts if necessary. This proposal helps text helps them further to make it even clear to a court what can and cannot be done with Internet Resources.
Fernando
On 08/09/2022 00:08, Andrew Yager wrote: In response to your last paragaph
Can the secretariat confirm:
* they have an issue with enforcement now * They have an active need that they are unable to address under this framework * That the current membership agreement is inadequate to allow them to fulfil the tasks they have
Your statements infer that there is an issue, they can’t enforce behaviour and that the current policies are inadequate. I’m yet to see any evidence of this.
Andre
Get Outlook for iOShttps://aka.ms/o0ukef ________________________________ From: Fernando Frediani fhfrediani@gmail.commailto:fhfrediani@gmail.com Sent: Thursday, September 8, 2022 1:01:40 PM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Hi Matt, I am sorry but I don't really take some of these emotional arguments because they are created mostly by the ones who are most taking advantage from it. There are ways in the *real* world but there are also adjustments that must be made and many still seem to not have realized after a while. One thing I find it wrong is to blame APNIC for it and suggesting they should not stop this, despite the illegality presented and therefore the unfairness with the whole of community impacted.
It seems interesting however your idea of some tentative to transfer resources definitely to smaller companies, but not only from the larger holders but from *any* holder who is leasing them. In order words an idea of a proposal could be to allow a company who leases from a resources holders to have those resources forcibly transferred definitely to them regardless the permission of the resources holder if a leasing it shown to be happening there.
Sorry to disagree, but appealing to leasing as the only option available at this stage is a easy path to make it worst a scenario that is only causing more and more unfairness to all. If it is wrong - and it is - it must be stopped *right now* and how to act about what exists should be carried on being discussed (in another thread) in order to help APNIC how to deal with cases properly and have all the support it may require.
Regards Fernando
On 07/09/2022 23:39, Matthew Shearing wrote:
Fernando, very simply – if it was already against the rules, why this policy? There should be no need for clarification if this was already ‘illegal’ or ‘against the rules’ as you say. What is the point of this policy if it’s already clear?
Further, you keep talking about IPv4 exhaustion and that we need to ‘deal with it’. The fact there exists a leasing market in the first place means that there are plenty of unused IPv4 resources. Otherwise, there would be no IPv4 addresses to lease.
If APNIC wants to tackle ‘misuse’, that is also fine. However, why not start with those who have plenty of IP space? Why not build in guarantees that APNIC it revokes space from a large holder, any lessees currently using that space will get access to those IPv4 addresses, as they are the ones using them? Why is none of this even being discussed? It’s incredibly obvious this policy hurts mainly the smaller companies, by going after leases, not the big holdings themselves.
By saying ‘there are ways to get blocks’ also tells me very clearly that you’ve either not tried recently, or you’re just willfully ignorant. For many companies, leasing is the only feasible ways to get blocks because we are priced out.
Ideologically, we are all in agreement that an IPv6 world would be amazing. Unfortunately, those of us running businesses need to exist here in the real world, not in your imaginary world where we get everything we would like. If you want to help change that, we’ll all be here, cheering you on. Until then, businesses like ours don’t have the luxury of sitting around wishing – we’ve got customers we need to serve and employees we need to pay.
These ‘emotional’ arguments are common because they are real. They are for businesses that exist in the real world, in an IP environment that APNIC (and other registrars) created. APNIC allowed the leasing paradigm to occur and did nothing about it. This is not some new thing – it is a mature market that has existed for a long time.
It is incredibly irresponsible for APNIC to try and roll it back now, after many years of inaction, and disingenuous for people like you to somehow claim businesses that are just trying to do the best they can in the environment we currently have are somehow at fault. This problem can be laid squarely at the feet of APNIC – and for that reason, it can and will be held liable by those damaged if any changes are made now.
This policy is approaching everything from the wrong direction. Its implementation will punish the smallest businesses while doing nothing about the largest legacy holders. If APNIC is serious about the IPv4 allocation issue, it should start with the swathes of latent resources and move backwards. This should be tempered by protections and policies which ensure smaller businesses aren’t ruined in the process. Maybe once that is solved, in several years time, it will be time to revisit this topic. For now though, this is far too premature.
The reality is this – for many of us, leasing is right now the only viable option. Taking that away without proposing any kind of genuine alternatives (ie not the handwavium generalisations you’ve been engaging in) is reckless and will result in incredible damage to members who have simply been doing their best in an environment APNIC created in the first place.
Cheers,
Matt Shearing Chief Executive Officer
[X]
Brisbane, Australia (AEST) • matt@oneqode.commailto:matt@oneqode.com • +61 406 778 038
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From: Fernando Frediani fhfrediani@gmail.commailto:fhfrediani@gmail.com Sent: Thursday, 8 September 2022 12:15 PM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Unfortunately this shows a tentative to discuss something with lack of enough important information about the topic and also there was not proper follow of most of this thread discussion.
First Internet Resources are not irrevocable assets that anyone who holds them can do whatever they like as if they own them. Unfortunately many people in this industry still don't know, but the fact that organizations hold a resource assigned to them does not mean they own it and therefore they must operate them under certain rules otherwise they risk to have them revoked, therefore they cannot be treated as an asset you purchased and may do whatever you like with it. If you purchase a server or a router it is yours and you sell or lease it for whatever amount you wish, but not with internet resources because you don't own them.
It is unimportant that anything APNIC may do against those who using IPv4 blocks illegally and may have them revoked because they should never have used in that way in first instance. A while back, when they became members they have signed a contract agreeing they would use the resources according to the rules. Therefore if someone decided to do out of what has been previously agreed they did it in their own risk and cannot allege they are "being affected".
Regardless how market evolves APNIC has full rights to revoke resources from members who are misusing resources not in accordance with the contracts they have signed and agreed. And by doing that APNIC is protecting community interests in detriment to individual and very specific interests that wants to use internet resources for proposes they were never conceived for.
Seems that people still didn't accept IPv4 exhaustion and keep hoping for something that will never come instead of learn once for all how to deal with it. There are ways to get blocks, for example via transfers and other specific methods, but the scenario many were used for decades doesn't exist anymore and still seems people keep trying to make up stuff to benefit their own specific interest in detriment of everybody else and of the fairness with everybody involved. If a company doesn't have enough money to afford a transfer I am sorry, but that is the new reality for a while. Learn how to deal with it and use other alternatives available like getting from upstreams - who provide connectivity - until there is budget to get address via a transfer for example. And not less important, stop hiding from IPv6 saying that will not revolve.
APNIC has all rights to fight in courts and is fully legally covered to enforce what members using internet resources signed and agreed for. Hardly judges will overwrite such agreement because they fell sorry that some people still didn't accept and learned to live with IPv4 exhaustion. No 'difficult' scenario gives the right to a member to void a contract they signed and agreed and win that in court.
These 'emotional arguments' of people and companies that will suffer if no leasing is allowed is a common argument from organizations who profit from IP leasing and don't build any internet connectivity and is already old one. If people keep insisting in doing things out of the rules sooner or later they will have to pay the price and they should know the risk before they even started.
IP addresses were not made to be rented from a resource holder who don't need them anymore to one that needs and could get them directly from the RIR. Regardless of the most noble reason, going against the rules doesn't make they valid.
Fernando
On 07/09/2022 22:49, Matthew Shearing wrote:
Just wanted to chime in here and follow up on Mike's point (and those of several others).
What APNIC has done by its previous conduct is create a scarce asset collected in the hands of a number of large providers, with increasingly less being issued to small providers. As with any scarce asset in human history, this necessarily creates all the prerequisites for a fee market.
Just like real estate, vehicles and other commodities, leasing is a natural evolution of scarcity in an asset class with direct utility. Right now, IPv4 blocks are like houses - some own them, but some don't have the capital resources to outright own the amount they need. Simply looking at the prices which IPv4 blocks are going for on the open market will make it clear that many smaller businesses are priced out.
Leasing represents a viable option for companies to access the blocks they need and pay manageable, monthly or yearly payments for the use of those blocks. Many businesses are reliant on these currently.
Saying that APNIC will outright ban leasing and that this will somehow benefit businesses is abjectly false. Not only will it disrupt many current business operations, but there is no guarantee that a market with more perverse incentives won't emerge afterwards.
In our view, APNIC has already demonstrated by its statements and conduct with this policy that they have little grasp on how (and why) asset markets evolve. They've also done nothing to dissuade us that the new 'status quo' after this policy change won't be worse than the current one - which operates relatively fine.
Practically, for APNIC to say there will be no meaningful damage to current users and businesses (who are APNIC members in their own right) it must answer the following questions:
1. What alternative does APNIC propose to the current IPv4 market and particularly, leasing options available to smaller companies and new entrants? 2. How will terminating leases currently on foot result in a better outcome for the businesses currently relying on them? 3. How will new IPv4 addresses be allocated, what timeframes and costs will be involved in this allocation? 4. Can APNIC give guarantees to current lessees who are reliant on IPv4 address leases that they can continue to access those addresses or will have replacements of similar value, at less cost, instantly after the change is made? 5. Is APNIC prepared to be held liable in lawsuits or a class action for the damages incurred by this policy change? Has it considered this risk and informed members accordingly?
It appears that those that will not be affected by this policy or those who already have large IPv4 blocks are some of the largest proponents of it - which makes sense. It is easy to vote for a change if it's only others that will be affected.
However, there are a large number of SME businesses out there who rely on these leases to run their operations. For them, this isn't just some merely intellectual exercise. Rather, it's a question of hundreds of thousands, or even millions, of dollars.
It's their ability to remain operational. It's their employees' livelihoods and those of their families. It's a core part of how they operate and for many, the foundation which they've built their business on.
This policy change seems to almost be a 'policy for policies sake'. It is clear that the repercussions of this were either not considered, or not even known, as the policy notes listed 'nil' negative effects. That this is the opinion of APNIC (and it seems, of a significant portion of the community) is incredibly concerning, because it couldn't be further from the truth.
Many real businesses will be affected by this, with real people. And the flippancy with which many within APNIC are treating this proposal shows a concerning lack of empathy towards that - and a failure to grasp the nature of IPv4 addresses as a modern asset class.
Without the above questions answered, I don't see how this policy vote can go ahead - and I would implore everyone considering this policy to reject it outright. There may be issues with the current IPv4 paradigm but this is definitely not the solution.
Kind Regards
Matt Shearing Chief Executive Officer
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From: Mike Burns mike@iptrading.commailto:mike@iptrading.com Sent: Thursday, 8 September 2022 6:52 AM To: 'Fernando Frediani' fhfrediani@gmail.commailto:fhfrediani@gmail.com; sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Alas, Fernando, there is no alternative “drug” for people to live without IPv4.
Banning leasing hurts the smallest and poorest of companies most.
And you cannot elucidate any “major damages” suffered where leasing has actually, in reality, occurred for many years at RIPE.
Yet you use this evidence-free assertion as your major argument against leasing.
That some kind of serious damage will occur to the RIR system.
As a broker who as to talk to actual, real companies in need, who can’t afford to pay upfront, can you tell me what I should say when they ask me why leasing is forbidden? If I say it’s to avoid “major damages” and they ask what they are, can you tell me?
What major damages?
Regards, Mike
From: Fernando Frediani <fhfrediani@gmail.commailto:fhfrediani@gmail.com> Sent: Wednesday, September 7, 2022 4:33 PM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Do you understand the argument that certain drugs can alleviate certain pains but they remain forbidden because they cause a major damage to society in long term and there are alternatives for people be able to still live without have to use those type of damageable mechanisms. Companies can also live without that and still have other legally allowed mechanisms.
This discussion is unnecessary for this policy discussion as what it proposes is to make something *already forbidden* clear in to the text, not to discuss if leasing should exist or not.
If anyone opposes it please take attention to provide arguments and suggestions on how to address the issues raised about what the proposal really proposes.
Regards Fernando
On 07/09/2022 14:12, Mike Burns wrote:
Hi Fernando,
Do you understand my argument that smaller business cannot afford the full upfront payment but can afford monthly lease payments?
Please address that simple argument by telling me how the small business benefits by not having the lease option, but only having the purchase option.
Regards, Mike
From: Fernando Frediani fhfrediani@gmail.commailto:fhfrediani@gmail.com Sent: Wednesday, September 7, 2022 1:01 PM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
IP Leasing is already banned in most RIRs and should stay as is.
But yes it does help as it doesn't push even further up IPv4 pricing and makes it easier for these small companies to get IPv4 via the proper and allowed way which are transfers. Other then diverting totally the propose o IPv4 Allocation, Leasing market contributes significantly to price increasing fueling the market with more demand for that type of very wrong thing.
RIPE is normally not a good example for certain policies which don't seem to have receptivity in discussions on all other RIRs.
There are still mechanisms that allow companies to get IP addressing either directly from the RIR, via Transfers which is a pretty common way or from the Upstream providers. People may not have got used yet to learn to live with less address and they may believe they need a bunch of address.
IP Leasing will never help small companies. The ones who really benefit from it are the IP broker companies who profit from them and also the resource holders which don't justify anymore to keep those addresses and are also profiting from something that should have been re-assigned directly to those who really need and justify for them in order to build Internet Infrastructure and Connectivity and instead are leasing a asset they don't own.
Fernando
On 07/09/2022 12:39, Mike Burns wrote:
Hi Fernando,
So your argument is that banning leasing actually helps smaller companies in their quest for IPv4?
Are you aware that RIPE has allowed leasing for many years but is still a functioning RIR whose IPv4 sale prices are not more expensive despite the history of leasing there?
Can you reconcile that with your argument that leasing will raise prices for both leasing and transfers?
Are you aware that it’s not always possible to get IPv4 blocks from the company that is providing you with connectivity?
Regards, Mike
From: Fernando Frediani fhfrediani@gmail.commailto:fhfrediani@gmail.com Sent: Wednesday, September 7, 2022 11:27 AM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
This is exactly the opposite.
Allowing IP leasing to happen more than just tottaly divert the propose of IP assignments by RIRs it make it bad specially for smaller companies as it increases the cost for both leasing and transfers in long term. The cost of leasing is based on the transfer and if leasing is allowed then transfer prices will always go up which makes it even harder for smaller companies to go into the market.
Any form of IP leasing without a direct connection relationship to provide a connectivity service makes it more expensive for smaller companies to get IP addresses to operate.
Fernando
On 07/09/2022 11:15, Mike Burns wrote:
Hi Jordi,
It’s plain you feel that we should do all possible to raise the price of IPv4 and make it unattainable for small business in the vain hope that this will drive IPv6 adoption.
I don’t think making IPv4 more difficult to acquire is the job of the RIR system.
You have not addressed the inability of smaller companies to acquire necessary IPv4 blocks if you ban leasing.
Is that something you are comfortable with, in pursuit of the IPv6 grail?
It’s okay with you that this policy prevents small companies from growing?
Regards, Mike
From: JORDI PALET MARTINEZ via sig-policy sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Sent: Wednesday, September 7, 2022 10:11 AM To: sig-policy@lists.apnic.netmailto:sig-policy@lists.apnic.net Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Actually, I must disagree …
If organizations having unused resources, they need to transfer them or return them to the RIR. If prices keep going high, that could encourage faster IPv6 adoption, then transfer prices will go down, up to “no value”. It takes time, but it is just market.
Those that have more money, have more facilities to do a faster transition and not bother about IPv4.
Regards,
Jordi
@jordipalet
El 7/9/22, 16:05, "Mike Burns" <mike@iptrading.commailto:mike@iptrading.com> escribió:
Hello,
Per Gaurav’s statement that “only those with millions of dollars can think of getting ips”, this community should oppose this policy.
Because the only way small companies can afford to get ips today is by leasing them. The same way the small company can’t afford to purchase a big office building but instead rents an office. Leasing is the only way to finance IPv4 acquisitions today. No bank or other entity that I am aware of will do it. Purchasing addresses requires full upfront payment, but leasing allow for much smaller monthly payments.
If this community wants to ensure only the largest and richest companies can acquire new addresses, ban leasing.
But if the community tries to ban something with such a large business motivation behind it, it will find itself struggling against a powerful foe.
And for what purpose do we punish the small businesses? Leasing puts addresses in the hands of those who need them to build and operate networks. Isn’t that the primary goal of the RIR system?
Regards,
Mike
El 2/9/22, 9:23, "Gaurav Kansal" <gaurav.kansal@nic.inmailto:gaurav.kansal@nic.in> escribió:
Hello everyone,
In my opinion, even Trading of IPs (leave apart the lease for making dollars) in the name of transfers must be stopped.
If organisation doesn’t need IPs , then those must be returned back so that smaller organisations can get it from the RIR.
Currently, only the one which have millions of dollars can think of getting IPs. In today’s scenario, no one can start the Data Centre, ISP business without investing millions in IPs. Even education and research org doesn’t have an option to get IPs from RIR.
This is like horse trading and isn’t a good practice for the community as a whole.
Regards,
Gaurav Kansal
On 02-Sep-2022, at 12:20, rajesh@smartlinkindia.commailto:rajesh@smartlinkindia.com wrote:
Dear Team,
As Mr. Satoru, mentioned there are changes, but if carefully implemented in phased manner, unauthorised leasing can be stopped.
For example in first phase, leasing among countries can be stopped, if the owner company doesn't provide any services beyond its home country. For example if a company in India doesn't have any operation in Singapore or Japan , can't lease resources to those companies in Singapore or Japan. This can be verified by taking business registration documents of both lease and lessor.
Once this is done same may be granularized at RIR level, where in country like India, leasing can be restricted to the licensed service area for service provider within their designated service area.
This may stop majority of issues, barring few exceptions.
Some more brainstorming is required for better understanding and precise implementation.
Regards,
Rajesh Panwala
For Smartlink Solutions Pvt Ltd
+91-9227886001
+91-9426110781
On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru <stsuruma@bbix.netmailto:stsuruma@bbix.net> wrote:
Dear Colleagues,
I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team..
I would like to share key feedback in our community for prop-148, based on a meeting we organised on 29th Aug to discuss these proposals.
Many participants support the intent of the proposal but felt that implementation would be challenging.
(comment details) - It is undisputed that the current policy allows for the distribution of IP addresses according to the actual demand of one's own organization or directly connected customers, and does not allow for the leasing of IP addresses. - I think this proposal would be useful if the concept of leasing is accurately defined. - Leasing IP addresses that damage the accuracy of whois information should not be allowed, but I find it difficult to implement.
Regards,
Satoru Tsurumaki / JPOPF Steering Team
2022年8月26日(金) 17:27 Shaila Sharmin <shaila.sharmin.ovi@gmail.commailto:shaila.sharmin.ovi@gmail.com>:
Dear SIG members,
A new version of the proposal "prop-148-v002: Clarification - Leasing of Resources is not Acceptable" has been sent to the Policy SIG for review.
Information about earlier versions is available from:
http://www.apnic.net/policy/proposals/prop-148
You are encouraged to express your views on the proposal:
- Do you support or oppose the proposal?
- Is there anything in the proposal that is not clear?
- What changes could be made to this proposal to make it more effective?
Please find the text of the proposal below.
Regards, Bertrand, Shaila, and Ching-Heng APNIC Policy SIG Chairs
prop-148-v002: Clarification - Leasing of Resources is not Acceptable
Proposer: Jordi Palet Martinez (jordi.palet@theipv6company.comAnupammailto:jordi.palet@theipv6company.comAnupam) Amrita Choudhury (amritachoudhury@ccaoi.inmailto:amritachoudhury@ccaoi.in) Fernando Frediani (fhfredani@gmail.commailto:fhfredani@gmail.com)
- Problem statement
RIRs have been conceived to manage, allocate and assign resources according to need, in such a 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 delegated by APNIC or an NIR, the justification of the need implies the need to use on their own infrastructure and/or network connectivity services provided directly to customers. As a result, any form of IP address leasing is unacceptable, 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.
APNIC may proactively investigate those cases and also initiate the investigation in case of reports by means of a form, email address or other means developed by APNIC.
If any form of leasing, regardless of when the delegation has been issued, is confirmed by an APNIC investigation, it will be considered a policy violation and revocation may apply against any account holders who are leasing or using them for any purposes not specified in the initial request.
- Advantages / Disadvantages
Advantages: Fulfilling the objective above indicated and making the policy clear.
Disadvantages: None.
- Impact on resource holders
None.
- 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 _______________________________________________ sig-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-leave@lists.apnic.netmailto:sig-policy-leave@lists.apnic.net
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Hi Andrew:
No, APNIC does not work hand in hand with the government and does not have any regulatory power.
Multi stakeholder and bottom up, community driven are the slogans for the RIRs.
Secretariat welcome to state publicly if after Paul Wilson's top down letter to the Mauritius government, APNIC has changed from bottom up to "work hand in hand with government".
I think this is very relevant to the policy discussion because it decides the very scope of the polices.
Is policy as I believed, just
*policy is a set of operation principles to best operate in a global coodicated registration database, nothing more, nothing less."*
*Or *
*Policy carries regulatory power, so I believe people in this discussion list will need to be elected by all economies served by APNIC or appointed by the elected officials of each government, otherwise how few people in this room claim to represent the community and billions of people in Asia?*
On Thu, 8 Sept 2022 at 15:31, Andrew Yager andrew@rwts.com.au wrote:
This thread is probably not the place for this discussion - but the internet as a distributed, co-regulated body is absolutely partly regulated by APNIC - and APNIC works hand in hand with government to do that.
They absolutely have some level of authority to the extent of the jurisdiction.
Let’s try and keep this conversation to this policy though.
Leasing of the type this policy seeks to restrict is currently prohibited by the member agreement. Although this policy may accidentally do more than it intends. Or maybe that’s the intention.
But this policy does not need to exist. All the required things are already in the member agreement, and I’m yet to see any evidence that there is, in fact, a problem with the status quo that requires this policy or is likely to.
This policy shouldn’t proceed - precisely because it’s not needed.
If we need to have a discussion about members returning unused resources, someone should propose such a policy and debate it.
Andrew
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*From:* Lu Heng h.lu@anytimechinese.com *Sent:* Thursday, September 8, 2022 5:22:56 PM *To:* Andrew Yager andrew@rwts.com.au *Cc:* Fernando Frediani fhfrediani@gmail.com; sig-policy@lists.apnic.net sig-policy@lists.apnic.net *Subject:* Re: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Hi Andrew:
Yes, policies need to be well written.
But the fundamental question here is, where is the policy limitation? Or even more simply put, what is policy?
In my view, *policy is a set of operation principles to best operate in a global coodicated registration database, nothing more, nothing less.*
RIR are created as bookkeepers, and they should and have to stay that way.
As you rightfully point out, someone using the master power to alter the registration database that APNIC has, to
Interfere how business is being operated.
To claim APNIC owns the unique registration value of the IP address(or
the community, but since those people believe APNIC can reclaim and redistribute at its will, so practically APNIC)
- To threaten to disconnect end users if its member does not obey their
interference.
Is simply disconnects itself from reality. APNIC is a small private company, it can not tell how the other party operates their business, operating a registration database does not give you god-like power to put whatever into policy and use disconnection to threaten people.
And this is exactly what this policy, and many of Jordi's other policies are trying to achieve.
Only nations have such power to impose regulations, APNIC does not.
Hence in my last email, unless and until Jordi can show he actually has most members agreeing with him by actual petition, I think an empty claim of "community will" does not hold water.
It's ok to make operation principles, it is not ok to use so called policy to tell people how to run their business.
In other words, I believe this policy, and many other policy jordi have proposed, are out of scope for the policy discussion.
Unless, someone believes policy made here, has the same power as a nation's regulation.
On Thu, 8 Sept 2022 at 14:54, Andrew Yager andrew@rwts.com.au wrote:
I disagree with many of your assertions here about where policy and governance sit and the necessity of them.
APNIC needs to do more than charge fees and make money. It does provide a necessary and vital role in the health of the internet.
This is precisely why policy groups need to exist and precisely why policies need to be well written, sensible and offer value. But, the burden on policy makers is particularly to ensure their assumptions, foundational principals and statements are in fact correct, balanced and forward looking.
Policies should be few, measured, necessary and clear. Unfortunately I don’t think this proposal stacks up for the reasons I’ve already outlined.
Andrew
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*From:* Lu Heng h.lu@anytimechinese.com *Sent:* Thursday, September 8, 2022 4:47:45 PM *To:* Andrew Yager andrew@rwts.com.au *Cc:* Fernando Frediani fhfrediani@gmail.com; sig-policy@lists.apnic.net sig-policy@lists.apnic.net *Subject:* Re: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Hi
Let me ask Secretariat a simple question:
There is currently one of largest APNIC members who are leasing IP addresses to millions of end users(I won't name who that is but people in business should know), if this policy is adopted, how will the secretariat plan to enforce it without being sued out of existence?
The problem of this policy development process is, the real community is not involved. The real community is the near 10000 members and billions of end users those members represent.
Yes, it could be argued it is their fault not to join this policy process, but in reality, most don't care.
So this small room of people, who have never actually had any real memberbase support, believe they can make policy and use APNIC's monopoly position to do things, is simply disconnecting itself from reality.
Before Jordi and Fernado claim "community wants people to return space", how about getting 50% members' signatures to prove that point?
And the transfer data simply proves no one wants to return the space, and the real community wants a market.
I believe in order for RIR to survive, the small room of policy specialists that claim to represent the entire earth's interest(especially Jordi who makes policy proposals everywhere but failed to even have 10% of members supporting him), has to stop.
Policy needs to be made by the real members of APNIC, and real end users who are using the internet and someone can get a large percentage of the population to agree to them.
Otherwise, let APNIC stick to the bookkeeper, that is what is all created for.
On Thu, 8 Sept 2022 at 11:14, Andrew Yager andrew@rwts.com.au wrote:
Fernando - you repeatedly state that there is an issue this policy is addressing. This is your base assumption.
I reiterate that to date the existing mechanisms are sufficient.
Feel free to demonstrate that they are not with evidence.
Andrew
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*From:* Fernando Frediani fhfrediani@gmail.com *Sent:* Thursday, September 8, 2022 1:11:49 PM *To:* sig-policy@lists.apnic.net sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Andrew your understanding about my statements is wrong. it is unnecessary the secretariat to confirm such points, unless you have a concern about them.
There is an issue with leasing existing despite the current rules don't allow them. And all I said they should always be able to enforce regardless the scenario and have all legal cover and support to do this in courts if necessary. This proposal helps text helps them further to make it even clear to a court what can and cannot be done with Internet Resources.
Fernando On 08/09/2022 00:08, Andrew Yager wrote:
In response to your last paragaph
Can the secretariat confirm:
- they have an issue with enforcement now
- They have an active need that they are unable to address under this
framework
- That the current membership agreement is inadequate to allow them to
fulfil the tasks they have
Your statements infer that there is an issue, they can’t enforce behaviour and that the current policies are inadequate. I’m yet to see any evidence of this.
Andre
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*From:* Fernando Frediani fhfrediani@gmail.com fhfrediani@gmail.com *Sent:* Thursday, September 8, 2022 1:01:40 PM *To:* sig-policy@lists.apnic.net sig-policy@lists.apnic.net sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Hi Matt, I am sorry but I don't really take some of these emotional arguments because they are created mostly by the ones who are most taking advantage from it. There are ways in the *real* world but there are also adjustments that must be made and many still seem to not have realized after a while. One thing I find it wrong is to blame APNIC for it and suggesting they should not stop this, despite the illegality presented and therefore the unfairness with the whole of community impacted.
It seems interesting however your idea of some tentative to transfer resources definitely to smaller companies, but not only from the larger holders but from *any* holder who is leasing them. In order words an idea of a proposal could be to allow a company who leases from a resources holders to have those resources forcibly transferred definitely to them regardless the permission of the resources holder if a leasing it shown to be happening there.
Sorry to disagree, but appealing to leasing as the only option available at this stage is a easy path to make it worst a scenario that is only causing more and more unfairness to all. If it is wrong - and it is - it must be stopped *right now* and how to act about what exists should be carried on being discussed (in another thread) in order to help APNIC how to deal with cases properly and have all the support it may require.
Regards Fernando On 07/09/2022 23:39, Matthew Shearing wrote:
Fernando, very simply – if it was already against the rules, why this policy? There should be no need for clarification if this was already ‘illegal’ or ‘against the rules’ as you say. What is the point of this policy if it’s already clear?
Further, you keep talking about IPv4 exhaustion and that we need to ‘deal with it’. The fact there exists a leasing market in the first place means that there are plenty of unused IPv4 resources. Otherwise, there would be no IPv4 addresses to lease.
If APNIC wants to tackle ‘misuse’, that is also fine. However, why not start with those who have plenty of IP space? Why not build in guarantees that APNIC it revokes space from a large holder, any lessees currently using that space will get access to those IPv4 addresses, as they are the ones using them? Why is none of this even being discussed? It’s incredibly obvious this policy hurts mainly the smaller companies, by going after *leases*, not the big holdings themselves.
By saying *‘there are ways to get blocks’* also tells me very clearly that you’ve either not tried recently, or you’re just willfully ignorant. For many companies, leasing is the only feasible ways to get blocks because we are priced out.
Ideologically, we are all in agreement that an IPv6 world would be amazing. Unfortunately, those of us running businesses need to exist here in the real world, not in your imaginary world where we get everything we would like. If you want to help change that, we’ll all be here, cheering you on. Until then, businesses like ours don’t have the luxury of sitting around wishing – we’ve got customers we need to serve and employees we need to pay.
These ‘emotional’ arguments are common because they are *real*. They are for businesses that exist in the real world, in an IP environment that APNIC (and other registrars) created. APNIC allowed the leasing paradigm to occur and did nothing about it. This is not some new thing – it is a mature market that has existed for a long time.
It is incredibly irresponsible for APNIC to try and roll it back now, after many years of inaction, and disingenuous for people like you to somehow claim businesses that are just trying to do the best they can in the environment we currently have are somehow at fault. This problem can be laid squarely at the feet of APNIC – and for that reason, it can and will be held liable by those damaged if any changes are made now.
This policy is approaching everything from the wrong direction. Its implementation will punish the smallest businesses while doing nothing about the largest legacy holders. If APNIC is serious about the IPv4 allocation issue, it should start with the swathes of latent resources and move backwards. This should be tempered by protections and policies which ensure smaller businesses aren’t ruined in the process. Maybe once that is solved, in several years time, it will be time to revisit this topic. For now though, this is far too premature.
The reality is this – for many of us, leasing is right now the only viable option. Taking that away without proposing any kind of genuine alternatives (ie not the handwavium generalisations you’ve been engaging in) is reckless and will result in incredible damage to members who have simply been doing their best in an environment APNIC created in the first place.
Cheers,
*Matt Shearing* *Chief Executive Officer*
Brisbane, Australia (AEST) • matt@oneqode.com • +61 406 778 038
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*From:* Fernando Frediani fhfrediani@gmail.com fhfrediani@gmail.com *Sent:* Thursday, 8 September 2022 12:15 PM *To:* sig-policy@lists.apnic.net *Subject:* [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable
Unfortunately this shows a tentative to discuss something with lack of enough important information about the topic and also there was not proper follow of most of this thread discussion.
First Internet Resources are not irrevocable assets that anyone who holds them can do whatever they like as if they own them. Unfortunately many people in this industry stil