[sig-policy] Re: NEW version - prop-148-v003: Clarification - Leasing of Resource s is not Acceptable
Exactly. As explained many times in the list and in the meeting today, the proposal doesn’t change the situation, just clarify it: leasing *in any form* is not allowed. Could you please if IPXO justified the need in APNIC or any other RIRs, indicating that the addresses will be used for leasing? Regards, Jordi @jordipalet El 15/9/22, 6:40, "Fernando Frediani" escribió: This is not a proposal about if Leasing should be allow/disallowed, but to make something clear in the policy text about what already exists and is what it is. Fernando On 14/09/2022 10:35, Evelina Eidukaitė via sig-policy wrote: Dear Colleagues, My name is Evelina, I represent IPXO, the largest IP leasing platform and we don’t support the proposal "prop-148-v003: Clarification - Leasing of Resources is not Acceptable", because it opposes to the concept of free, open, and equal Internet. 1. Growing scarcity of IPv4 addresses. RIRs have exhausted their supply of IPv4 and their stated purpose is to assist growth. We believe leasing improves this, and opposite, by prohibiting lease and not offering any alternative way to receive IPv4 addresses RIR is limiting access to IPv4 addresses and free, open and equal internet. 2. By limiting the access for everyone to IPv4 addresses and denying the right to lease IPv4 addresses, RIR would create situation of monopoly, because bigger and wealthy organizations are able to obtain even more resources, on the other hand, smaller organizations can’t get the access. In our opinion it should be opposite, and RIR should liberalize the market for IPv4 addresses by showing more flexibility. RIR should stand for a good faith position that promotes an equitable system of Internet number assignment. 3. We think that RIR should open and govern the market of lease, prohibiting it would lead to the users’ activities where they mask the lease; and again, it will lead to cybersecurity issues. RIR should serve as gatekeeper and registrar of IPv4 assets and encourage better transparency, not opposite. 4. If RIR wants to control lease or transfer of LIR’s assets, it creates situation, where RIR interferes into the business model or business plan of the LIR’s entity. If RIR prohibits LIR to make one or other transaction, it acts ultra vires, - beyond the authority of RIR to perform. It is not an audit or supervisory institution, and should encourage the community to grow and develop, but not control, interfere, or prohibit commercial transactions of LIR companies. 5. Some RIR members that strive to prohibit IP Lease explain this initiative as encouragement for organizations to migrate to IPv6, however, it is not a road to IPv6 adoption, but merely a roadblock. It should be known that bureaucratic and police state methods have never led to the progress or development. In this case, if IP lease would be prohibited, it would only create artificial problems for smaller entities which need and would like to lease IP addresses. So, instead of contributing to internet growth, RIR would “audit” LIR’s business activities and discourage trust and collaboration of RIR members. 6. The authors of this proposal overloaded it with biased and misleading information. For example, the argument of authors that “IP Leasing is already banned in most RIRs and should stay as is” is wrong and misleading. According to the official statement of RIPE in the very similar discussion on analogous authors’ suggestion in ARIN region, “In the RIPE region the term "leasing" is not defined and therefore it does not play a role in the request evaluation.” Posting desperate and fabricated authors’ slogans in APNIC and ARIN policy suggestion groups do not turn them into the facts. Actually, it is very clear, that the authors of this suggestion seek “to encourage faster IPv6 adoption” because they are interested parties. However, they suggest achieving IPv6 adoption by simply banning the access of IPv4, which is completely illogical and primitive way. 7. The text of the suggestion is full of obscurities. Here are some of them: “Network connectivity services provided directly to customers” – how it is going to be checked if services are provided “directly to customers”? What the word “directly” means in this context? Is RIR obliged to have the list of each LIR’s customers and check the contractual obligations of LIR and customer? “any form of IP address leasing” – the term of “leasing” in the 3rd latest version is finally added as a “Note”, however, definition raised more questions than answers. First, it says that leasing is providing resources “for a price or even for free” and this is the core of the definition, however, it doesn’t define parties of such “transaction”, or who provides resources to whom. Second, what kind of “leasing” is defined, if it also can be “for free”? Third, with this construction, even "transfer"
[sig-policy] Re: NEW version - prop-148-v003: Clarification - Leasing of Resource s is not Acceptable
This is not a proposal about if Leasing should be allow/disallowed, but to make something clear in the policy text about what already exists and is what it is. Fernando On 14/09/2022 10:35, Evelina Eidukaitė via sig-policy wrote: Dear Colleagues, My name is Evelina, I represent IPXO, the largest IP leasing platform and we don’t support the proposal "prop-148-v003: Clarification - Leasing of Resources is not Acceptable"*, *because it**opposes to the concept of free, open, and equal Internet. 1. Growing scarcity of IPv4 addresses. RIRs have exhausted their supply of IPv4 and their stated purpose is to assist growth. We believe leasing improves this, and opposite, by prohibiting lease and not offering any alternative way to receive IPv4 addresses RIR is limiting access to IPv4 addresses and free, open and equal internet. 2. By limiting the access for everyone to IPv4 addresses and denying the right to lease IPv4 addresses, RIR would create situation of monopoly, because bigger and wealthy organizations are able to obtain even more resources, on the other hand, smaller organizations can’t get the access. In our opinion it should be opposite, and RIR should liberalize the market for IPv4 addresses by showing more flexibility. RIR should stand for a good faith position that promotes an equitable system of Internet number assignment. 3. We think that RIR should open and govern the market of lease, prohibiting it would lead to the users’ activities where they mask the lease; and again, it will lead to cybersecurity issues. RIR should serve as gatekeeper and registrar of IPv4 assets and encourage better transparency, not opposite. 4. If RIR wants to control lease or transfer of LIR’s assets, it creates situation, where RIR interferes into the business model or business plan of the LIR’s entity. If RIR prohibits LIR to make one or other transaction, it acts ultra vires, - beyond the authority of RIR to perform. It is not an audit or supervisory institution, and should encourage the community to grow and develop, but not control, interfere, or prohibit commercial transactions of LIR companies. 5. Some RIR members that strive to prohibit IP Lease explain this initiative as encouragement for organizations to migrate to IPv6, however, it is not a road to IPv6 adoption, but merely a roadblock. It should be known that bureaucratic and police state methods have never led to the progress or development. In this case, if IP lease would be prohibited, it would only create artificial problems for smaller entities which need and would like to lease IP addresses. So, instead of contributing to internet growth, RIR would “audit” LIR’s business activities and discourage trust and collaboration of RIR members. 6. The authors of this proposal overloaded it with biased and misleading information. For example, the argument of authors that “IP Leasing is already banned in most RIRs and should stay as is” is wrong and misleading. According to the official statement of RIPE in the very similar discussion on analogous authors’ suggestion in ARIN region, “In the RIPE region the term "leasing" is not defined and therefore it does not play a role in the request evaluation.” Posting desperate and fabricated authors’ slogans in APNIC and ARIN policy suggestion groups do not turn them into the facts. Actually, it is very clear, that the authors of this suggestion seek “to encourage faster IPv6 adoption” because they are interested parties. However, they suggest achieving IPv6 adoption by simply banning the access of IPv4, which is completely illogical and primitive way. 7. The text of the suggestion is full of obscurities. Here are some of them: “*Network connectivity services provided directly to customers*” – how it is going to be checked if services are provided “directly to customers”? What the word “directly” means in this context? Is RIR obliged to have the list of each LIR’s customers and check the contractual obligations of LIR and customer? “*any form of IP address leasing*” – the term of “leasing” in the 3^rd latest version is finally added as a “Note”, however, definition raised more questions than answers. First, it says that leasing is providing resources “for a price or even for free” and this is the core of the definition, however, it doesn’t define parties of such “transaction”, or who provides resources to whom. Second, what kind of “leasing” is defined, if it also can be “for free”? Third, with this construction, even "transfer" could go under this definition, because it’s not mentioned that resources are provided "for a specified time" or "temporary". “*if it is not part of a set of services based*” – again, what is a “set of services based”? is there a data base or list of all and any activities
[sig-policy] Re: NEW version - prop-148-v003: Clarification - Leasing of Resource s is not Acceptable
Dear Colleagues, My name is Evelina, I represent IPXO, the largest IP leasing platform and we don’t support the proposal "prop-148-v003: Clarification - Leasing of Resources is not Acceptable", because it opposes to the concept of free, open, and equal Internet. 1. Growing scarcity of IPv4 addresses. RIRs have exhausted their supply of IPv4 and their stated purpose is to assist growth. We believe leasing improves this, and opposite, by prohibiting lease and not offering any alternative way to receive IPv4 addresses RIR is limiting access to IPv4 addresses and free, open and equal internet. 2. By limiting the access for everyone to IPv4 addresses and denying the right to lease IPv4 addresses, RIR would create situation of monopoly, because bigger and wealthy organizations are able to obtain even more resources, on the other hand, smaller organizations can’t get the access. In our opinion it should be opposite, and RIR should liberalize the market for IPv4 addresses by showing more flexibility. RIR should stand for a good faith position that promotes an equitable system of Internet number assignment. 3. We think that RIR should open and govern the market of lease, prohibiting it would lead to the users’ activities where they mask the lease; and again, it will lead to cybersecurity issues. RIR should serve as gatekeeper and registrar of IPv4 assets and encourage better transparency, not opposite. 4. If RIR wants to control lease or transfer of LIR’s assets, it creates situation, where RIR interferes into the business model or business plan of the LIR’s entity. If RIR prohibits LIR to make one or other transaction, it acts ultra vires, - beyond the authority of RIR to perform. It is not an audit or supervisory institution, and should encourage the community to grow and develop, but not control, interfere, or prohibit commercial transactions of LIR companies. 5. Some RIR members that strive to prohibit IP Lease explain this initiative as encouragement for organizations to migrate to IPv6, however, it is not a road to IPv6 adoption, but merely a roadblock. It should be known that bureaucratic and police state methods have never led to the progress or development. In this case, if IP lease would be prohibited, it would only create artificial problems for smaller entities which need and would like to lease IP addresses. So, instead of contributing to internet growth, RIR would “audit” LIR’s business activities and discourage trust and collaboration of RIR members. 6. The authors of this proposal overloaded it with biased and misleading information. For example, the argument of authors that “IP Leasing is already banned in most RIRs and should stay as is” is wrong and misleading. According to the official statement of RIPE in the very similar discussion on analogous authors’ suggestion in ARIN region, “In the RIPE region the term "leasing" is not defined and therefore it does not play a role in the request evaluation.” Posting desperate and fabricated authors’ slogans in APNIC and ARIN policy suggestion groups do not turn them into the facts. Actually, it is very clear, that the authors of this suggestion seek “to encourage faster IPv6 adoption” because they are interested parties. However, they suggest achieving IPv6 adoption by simply banning the access of IPv4, which is completely illogical and primitive way. 7. The text of the suggestion is full of obscurities. Here are some of them: “Network connectivity services provided directly to customers” – how it is going to be checked if services are provided “directly to customers”? What the word “directly” means in this context? Is RIR obliged to have the list of each LIR’s customers and check the contractual obligations of LIR and customer? “any form of IP address leasing” – the term of “leasing” in the 3rd latest version is finally added as a “Note”, however, definition raised more questions than answers. First, it says that leasing is providing resources “for a price or even for free” and this is the core of the definition, however, it doesn’t define parties of such “transaction”, or who provides resources to whom. Second, what kind of “leasing” is defined, if it also can be “for free”? Third, with this construction, even "transfer" could go under this definition, because it’s not mentioned that resources are provided "for a specified time" or "temporary". “if it is not part of a set of services based” – again, what is a “set of services based”? is there a data base or list of all and any activities permitted? “such sites can request direct assignments from APNIC or the relevant NIR” – “can request” is not a policy wording and for sure it’s not the same as “should receive”. In other words, there is no warranty or assurance that LIR will get the resources, only a moral, what they can do. “APNIC investigation” – with this proposal, the authors are willing to introduce the
[sig-policy] Re: NEW version - prop-148-v003: Clarification - Leasing of Resource s is not Acceptable
This late edit retains false information regarding the situation at RIPE even though it has been clarified on this list. The new proposal states: " Nothing is currently mentioned in RIPE about this and it is not acceptable as a justification of the need." And this is patently false. RIPE does not have any justification of need except in one particular situation. And in that situation leasing is acceptable as justification. (That situation is an inter-regional sourced in ARIN). Why can't you just get it right? I presented the actual text of a message from RIPE last month stating this. A true statement would be: "Nothing is mentioned in RIPE about leasing, leases are accepted as valid assignments in RIPE, and RIPE allows leasing as a justification of need in transfers." Not at all what your statement implies. You might also point out that in ARIN, any address holder is free to lease out addresses to non-connected customers and receive all ARIN services supporting this, including assignments to non-connected customers and the ability to generate ROAs for them. Regards, Mike -Original Message- From: chku Sent: Tuesday, September 13, 2022 11:59 PM To: sig-policy Subject: [sig-policy] NEW version - prop-148-v003: Clarification - Leasing of Resource s is not Acceptable Dear SIG members, A new version of the proposal "prop-148-v003: 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-v003: Clarification - Leasing of Resources is not Acceptable -- Proposer: Jordi Palet Martinez (jordi.pa...@theipv6company.com) Amrita Choudhury (amritachoudh...@ccaoi.in) Fernando Frediani (fhfred...@gmail.com) 1. Problem statement RIRs have been conceived to manage, allocate and assign resources according to need, in such way that a LIR/ISP has addresses to be able to directly connect its customers based on justified need. Addresses are not, therefore, a property with which to trade or do business. When the justification of the need disappears or changes, for whatever reasons, the expected thing would be to return said addresses to the RIR, otherwise according to Section 4.1. (“The original basis of the delegation remains valid”) and 4.1.2. (“Made for a specific purpose that no longer exists, or based on information that is later found to be false or incomplete”) of the policy manual, APNIC is not enforced to renew the license. An alternative is to transfer these resources using the appropriate transfer policy. If the leasing of addresses is authorized, contrary to the original spirit of the policies and the very existence of the RIRs, the link between connectivity and addresses disappears, which also poses security problems, since, in the absence of connectivity, the resource holder who has received the license to use the addresses does not have immediate physical control to manage/filter them, which can cause damage to the entire community. Therefore, it should be made explicit in the Policies that the Internet Resources should not be leased “per se”, but only as part of a 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
