Dear SIG members,
The proposal "prop-148: Leasing of Resources is not Acceptable" has been
sent to the Policy SIG for review.
It will be presented at the Open Policy Meeting (OPM) at APNIC 54 on
Thursday, 15 September 2022.
https://conference.apnic.net/54/program/schedule/#/day/8
We invite you to review and comment on the proposal on the mailing list
before the OPM.
The comment period on the mailing list before the OPM is an important
part of the Policy Development Process (PDP). We encourage you to
express your views on the proposal:
- Do you support or oppose this proposal?
- Does this proposal solve a problem you are experiencing? If so,
tell the community about your situation.
- Do you see any disadvantages in this proposal?
- Is there anything in the proposal that is not clear?
- What changes could be made to this proposal to make it more effective?
Information about this proposal is appended below as well as available at:
http://www.apnic.net/policy/proposals/prop-148
Regards,
Bertrand, Shaila, and Ching-Heng
APNIC Policy SIG Chairs
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prop-148-v001: Leasing of Resources is not Acceptable
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Proposer: Jordi Palet Martinez ([email protected])
Amrita Choudhury ([email protected])
Fernando Frediani ([email protected])
1. Problem statement
--------------------
RIRs have been conceived to manage, allocate and assign resources according to
need, in such way that a LIR/ISP has addresses to be able to directly connect
its customers based on justified need. Addresses are not, therefore, a property
with which to trade or do business.
When the justification of the need disappears or changes, for whatever reasons,
the expected thing would be to return said addresses to the RIR, otherwise
according to Section 4.1. (“The original basis of the delegation remains
valid”) and 4.1.2. (“Made for a specific purpose that no longer exists, or
based on information that is later found to be false or incomplete”) of the
policy manual, APNIC is not enforced to renew the license. An alternative is to
transfer these resources using the appropriate transfer policy.
If the leasing of addresses is authorized, contrary to the original spirit of
the policies and the very existence of the RIRs, the link between connectivity
and addresses disappears, which also poses security problems, since, in the
absence of connectivity, the resource holder who has received the license to
use the addresses does not have immediate physical control to manage/filter
them, which can cause damage to the entire community.
Therefore, it should be made explicit in the Policies that the Internet
Resources should not be leased "per se", but only as part of a direct
connectivity service.
The existing policies of APNIC are not explicit about that, however current
policies do not regard the leasing of addresses as acceptable, if they are not
an integral part of a connectivity service. Specifically, the justification of
the need would not be valid for those blocks of addresses whose purpose is not
to directly connect customers of an LIR/ISP, and consequently the renewal of
the annual license for the use of the addresses would not be valid either.
Sections 3.2.6. (Address ownership), 3.2.7. (Address stockpiling) and 3.2.8.
(Reservations not supported) of the policy manual, are keys on this issue, but
an explicit clarification is required.
2. Objective of policy change
-----------------------------
Despite the fact that the intention in this regard underlies the entire Policy
Manual text and is thus applied to justify the need for resources, this
proposal makes this aspect explicit by adding the appropriate clarifying text.
3. Situation in other regions
-----------------------------
In other RIRs, the leasing of addresses is not authorized either and since it
is not explicit in their policy manuals either, this proposal will be presented
as well.
Nothing is currently mentioned in RIPE about this and it is not acceptable as a
justification of the need. In AFRINIC and LACNIC, the staff has confirmed that
address leasing is not considered as valid for the justification. In ARIN it is
not considered valid as justification of need.
A similar proposal is under discussion in LACNIC and ARIN.
4. Proposed policy solution
---------------------------
5.8. Leasing of Internet Number Resources
In the case of Internet number resources, the justification of the need implies
the need to directly connect customers. As a result, any form of IP address
leasing is not considered acceptable, nor does it justify the need, if it is
not part of a set of services based, at the very least, on direct connectivity.
Even for networks that are not connected to the Internet, leasing of IP
addresses is not permitted, because such sites can request direct assignments
from APNIC or the relevant NIR and, in the case of IPv4, use private addresses
or arrange market transfers.
If any form of leasing is confirmed by an APNIC investigation, APNIC may revoke
the IP resources of account holders who are leasing or using them for any
purposes not specified in the initial request.
This includes, but not limited to, the following:
- Removing delegations from the Whois database.
- Removing related ROAs.
- Stop providing APNIC services.
Members of the NIR are subject to the same policy.
5. Advantages / Disadvantages
-----------------------------
Advantages:
Fulfilling the objective above indicated and making the policy clear.
Disadvantages:
None.
6. Impact on resource holders
-----------------------------
None.
7. References
-------------
https://www.arin.net/participate/policy/proposals/2022/ARIN_prop_308_v2/
https://politicas.lacnic.net/politicas/detail/id/LAC-2022-2/language/en
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