Hi Sunny, all,
In my opinion because the policy is just a clarification of a fact, it doesn’t change the situation for non-LIR/ISP account holders. Further to that, direct assignments from APNIC can’t be further sub-assigned, so clearly this disallows any type of “business” with addresses for those account holders. Do you think that’s sufficiently clear or do you think a small text clarification in the proposal is needed? Regarding your 2nd point, there is not already a generic contact email to let know APNIC if anything is wrong regarding policy compliance? It will be surprising that today anyone discovers some breach and can’t report it, so this will also apply the same to this proposal. Again, if you believe a text clarification is needed, we can make a new version for that. Finally, regarding your 3rd question, in my understanding the policy manual apply to *all the resources* unless we state otherwise. So not only those after being implemented are subjected to this proposal. And once more, the proposal is only a clarification, not changing what is the current reality. Anyway, we are happy to state it more clearly if needed. Tks! Regards, Jordi @jordipalet El 22/8/22, 2:45, "Srinivas (Sunny) Chendi" <[email protected]> escribió: Hi all, This is the secretariat's impact assessment for prop-148-v001, which is also available on the proposal page. http://www.apnic.net/policy/proposals/prop-148 APNIC notes that this proposal suggests explicitly stating in the APNIC Internet Number Resources policy document that leasing of IP addresses is not permitted in the APNIC region. Clarifications: Is this proposal restricted to LIRs/ISPs, or does it apply to all APNIC account holders? The proposal does not specify how an APNIC investigation should be initiated. Should there be a form to report this, similar to IRT escalation? Does this proposal apply to all existing allocations or only those delegated after the policy is implemented? Implementation: This proposal may require changes to the system. If this proposal reaches consensus, implementation may be completed within 3 months. Regards, Sunny APNIC Secretariat On 11/08/2022 5:01 pm, chku wrote: Dear SIG members, The proposal "prop-148: Leasing of Resources is not Acceptable" has been sent to the Policy SIG for review. It will be presented at the Open Policy Meeting (OPM) at APNIC 54 on Thursday, 15 September 2022. https://conference.apnic.net/54/program/schedule/#/day/8 We invite you to review and comment on the proposal on the mailing list before the OPM. The comment period on the mailing list before the OPM is an important part of the Policy Development Process (PDP). We encourage you to express your views on the proposal: - Do you support or oppose this proposal? - Does this proposal solve a problem you are experiencing? If so, tell the community about your situation. - Do you see any disadvantages in this proposal? - Is there anything in the proposal that is not clear? - What changes could be made to this proposal to make it more effective? Information about this proposal is appended below as well as available at: http://www.apnic.net/policy/proposals/prop-148 Regards, Bertrand, Shaila, and Ching-Heng APNIC Policy SIG Chairs --------------------------------------------------------------- prop-148-v001: Leasing of Resources is not Acceptable ---------------------------------------------------------------- Proposer: Jordi Palet Martinez ([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://aus01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.arin.net%2Fparticipate%2Fpolicy%2Fproposals%2F2022%2FARIN_prop_308_v2%2F&data=05%7C01%7C%7C10362f529b0e4536949408da7b677a41%7C127d8d0d7ccf473dab096e44ad752ded%7C0%7C0%7C637957981611076664%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=uhhDD0kaOyJOxHiWa7Z%2BckfPwe9ohLQsidzS9u4BUHo%3D&reserved=0 https://aus01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fpoliticas.lacnic.net%2Fpoliticas%2Fdetail%2Fid%2FLAC-2022-2%2Flanguage%2Fen&data=05%7C01%7C%7C10362f529b0e4536949408da7b677a41%7C127d8d0d7ccf473dab096e44ad752ded%7C0%7C0%7C637957981611076664%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=p7nZJRM2zzi2kBOyLeSA%2BOo1qGTU1rBB3VIvQoaLYz0%3D&reserved=0 _______________________________________________ sig-policy - https://mailman.apnic.net/[email protected]/ To unsubscribe send an email to [email protected] -- _______________________________________________________________________ Srinivas (Sunny) Chendi (he/him) Senior Advisor - Policy and Community Development Asia Pacific Network Information Centre (APNIC) | Tel: +61 7 3858 3100 PO Box 3646 South Brisbane, QLD 4101 Australia | Fax: +61 7 3858 3199 6 Cordelia Street, South Brisbane, QLD | http://www.apnic.net _______________________________________________________________________ NOTICE: This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. 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