Hi Jordi

My comments are inline

> 
> New version:
> 
> 2.2.3. Assigned address space
> Assigned address space is address space that is delegated to an LIR, or
> end-user, for exclusive use within the infrastructure they operate.

This is not simply clarifying the text. The existing text is explicit. This 
relaxes the policy.
Your proposal text mentions “As a consequence, if there is a request with a 
documented purpose, and in the future the assigned space is used for some other 
purposes, it will violate the policy”.

This is not an error. I’m quite certain the very restrictive wording is 
deliberate. The community expected Members to use the resources for *exactly* 
the demonstrated need and to return them if that demonstrated need no longer 
exists. This is evident in the text at 4.1. License Renewal, which says; 
“Licenses to organizations shall be renewable on the following conditions: - 
The original basis of the delegation remains valid”.

However, I suspect this activity already happens in practice. So I’m supportive 
of the spirit of this change if the community agrees that delegation of 
resources for generic ‘own infrastructure’ usage is currently acceptable. 

I would specifically like to caution the removal of the “may not be 
sub-assigned”. This is the *definition* for ‘assigned’ space at APNIC. In the 
impact assessment, the Secretariat says, “assigned address space cannot be 
sub-assigned to other networks”. Who says? If this is only a technical 
limitation of MyAPNIC and it is no longer stated explicitly in the policy, then 
it allows for open interpretation/argument. 

Is the Secretariat confident the “exclusive use within infrastructure they 
operate” phrase means the same thing? Please just be careful of unintended 
consequences to Section 4.0.

Regards,

Adam



> 
> Please, update the version number of this proposal with this change, which I 
> guess it clears your impact assesment as well.
> 
> Regards,
> Jordi
> @jordipalet
> 
> 
> 
> El 14/2/20 14:48, "Srinivas Chendi" <[email protected] en 
> nombre de [email protected]> escribió:
> 
>    Dear SIG members,
> 
>    Here is the Secretariat impact assessment for proposal “prop-133-v001: 
>    Clarification on Sub-Assignments” and the same is also published at:
> 
>         https://www.apnic.net/community/policy/proposals/prop-133/
> 
>    Staff comments
>    --------------
> 
>    This proposal appears to be straightforward. APNIC notes the expansion 
>    policy text to elaborate on IPv6 assignment, and it is unlikely to 
>    change current practices for evaluating IPv6 requests.
> 
>    The proposed text “and may not be sub-assigned to other networks.” is 
>    redundant as assigned address space cannot be sub-assigned to other 
>    networks.
> 
> 
>    Technical comments
>    ------------------
> 
>    No comments.
> 
> 
>    Legal comments
>    --------------
> 
>    No comments.
> 
> 
>    Implementation
>    --------------
> 
>    within 3 months.
> 
> 
>    Regards
>    Sunny
> 
> 
>    On 20/01/2020 10:18 am, Bertrand Cherrier wrote:
>> Dear SIG members
>> 
>> The proposal "prop-133-v001: Clarification on Sub-Assignments" has been
>> sent to the Policy SIG for review.
>> 
>> (This is a new version of "prop-124" proposal abandoned after APNIC 48
>> as it did not reach consensus at APNIC 46, APNIC 47, and APNIC 48.)
>> 
>> It will be presented during the Open Policy Meeting at APNIC 49 in
>> Melbourne, Australia on Thursday, 20 February 2020.
>> 
>> We invite you to review and comment on the proposal on the mailing list
>> before the meeting.
>> 
>> The comment period on the mailing list before an APNIC meeting is an
>> important part of the policy development process. We encourage you to
>> express your views on the proposal:
>> 
>>  * Do you support or oppose this proposal?
>>  * Does this proposal solve a problem you are experiencing? If so, tell
>>    the community about your situation.
>>  * Do you see any disadvantages in this proposal?
>>  * Is there anything in the proposal that is not clear?
>>  * What changes could be made to this proposal to make it more effective?
>> 
>> Information about this proposal is available at:
>> http://www.apnic.net/policy/proposals/prop-133
>> 
>> Regards
>> 
>> Sumon, Bertrand, Ching-Heng
>> APNIC Policy SIG Chairs
>> 
>> ------------------------------------------------------------------------
>> 
>> prop-133-v001: Clarification on Sub-Assignments
>> 
>> ------------------------------------------------------------------------
>> 
>> Proposer: Jordi Palet Martinez
>> [email protected] <mailto:[email protected]>
>> 
>> 
>>    1. Problem statement
>> 
>> Note that this proposal is ONLY relevant when end-users obtain direct
>> assignments from APNIC, or when a LIR obtains, also from APNIC, and 
>> assignment
>> for exclusive use within its infrastructure.
>> Consequently, this is NOT relevant in case of LIR allocations.
>> 
>> The intended goal of assignments is for usage by end-users or LIRs in
>> their own infrastructure (servers, equipment, interconnections, employees,
>> guest devices, subcontractors, only within that infrastructure),
>> not for sub-assignment in other networks.
>> 
>> The current text uses a “must” together with “documented purposes”. As a
>> consequence, if there is a request with a documented purpose, and in the
>> future the assigned space is used for some other purposes, it will
>> violate the policy.
>> 
>> For example, a university may document in the request, that the assigned
>> addressing space will be used for their own network devices and serves, but
>> afterwards they also sub-assign to the students in the campus
>> (still same infrastructure). This last purpose was not documented, so it
>> will fall out of the policy.
>> 
>> 
>>    2. Objective of policy change
>> 
>> Clarification of the text, by rewording it.
>> 
>> 
>>    3. Situation in other regions
>> 
>> This situation, has already been corrected in AFRINIC, ARIN, LACNIC and
>> RIPE.
>> 
>> 
>>    4. Proposed policy solution
>> 
>> Actual text:
>> 2.2.3. Assigned address space
>> Assigned address space is address space that is delegated to an LIR, or
>> end-user, for specific use within the Internet infrastructure they operate.
>> Assignments must only be made for specific, documented purposes and may not
>> be sub-assigned.
>> 
>> Proposed text:
>> 2.2.3. Assigned address space
>> Assigned address space is address space that is delegated to an LIR, or
>> end-user, for exclusive use within the infrastructure they operate, and may
>> not be sub-assigned to other networks.
>> 
>> 
>>    5. Advantages / Disadvantages
>> 
>> Advantages:
>> Advantages of the proposal:
>> Fulfilling the objective above indicated and making sure to match the
>> real situation in the market.
>> 
>> Disadvantages:
>> Disadvantages of the proposal:
>> None foreseen.
>> 
>> 
>>    6. Impact on resource holders
>> 
>> Impact on resource holders:
>> None.
>> 
>> 
>>    7. References
>> 
>> AFRINIC: https://www.afrinic.net/policy/2018-v6-002-d3#details
>> 
>> ARIN:
>> https://www.arin.net/participate/policy/nrpm/#2-5-allocation-assignment-reallocation-reassignment
>> and https://www.arin.net/participate/policy/drafts/2019_15/
>> 
>> LACNIC:
>> https://politicas.lacnic.net/politicas/detail/id/LAC-2018-7?language=en
>> 
>> RIPE NCC: https://www.ripe.net/participate/policies/proposals/2016-04
>> 
>> Cordialement,
>> 
>> ------------------------------------------------------------------------
>> 
>> Bertrand Cherrier
>> Micro Logic Systems
>> https://www.mls.nc
>> Tél : +687 24 99 24
>> VoIP : 65 24 99 24
>> SAV : +687 36 67 76 (58F/min)
>> 
>> 
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