There are a number of problems with this policy.
First let’s start with Jordi stating the policy is just a clarification
of fact.
If so, why is it necessary? Actually it is not a fact as leasing is
occurring in APNIC and there is nothing in policy preventing it. So
this needs to be considered as a change in policy.
Second, there are inaccuracies in the verbiage associated with the
policy, particularly in reference to the status of leasing at other
RIRs. How can you make the statement “ In other RIRs, the leasing of
addresses is not authorized either and since it is not explicit in
their policy manuals…”?
Are you unilaterally deciding that things which are not mentioned in
policy are by definition “unauthorized”? I think this is wrong, and
it’s better to consider things as authorized unless they are forbidden
by policy. However, either way there is no language in any RIR
regarding leasing and you can’t make assumptions based on your own
feelings.
You are also wrong in stating that “Nothing is currently mentioned in
RIPE about this and it is not acceptable as a justification of the
need.” In actual fact, RIPE will accept leased-out addresses as
justification of need in the only case where RIPE actually has a needs
test, and that is with inter-regional transfers sourced in ARIN. It
bears remembering that RIPE simply has no needs test for transfers and
this has been the policy for many years. You may wonder what the point
of a needs-test for transfers is, since the recipients are paying for
the addresses.
ARIN staff has made it known that leasing addresses is not against
policy at all, but leased-out addresses can’t be used to justify
transfers. However a policy explicitly allowing leased-out addresses to
be used as justification is under consideration.
Also leases can be used to justify addresses in ARIN if any tiny
connectivity is created between the lessor and lessee. For example, a
small VPN can be created, even though it carries no (or nearly no)
traffic. If you want to get technical, the lessor and the lessee both
advertise the block, but the lessor advertises a longer and more
expensive route than the lessee, who will receive all the traffic
except for any loose packets that find their way to the lessor, who
will send them down the tunnel to the lessee.
The issue of retention of a needs test should be reconsidered by the
APNIC community in the face of evidence garnered from the RIPE
experiment. RIPE has had no needs test and APNIC had also removed the
needs-test for transfers but only restored it at the behest of ARIN,
who at the time was the only source for desperate APNIC members faced
with APNIC exhaust. Now there are other sources for inter-regional
transfers to APNIC, and APNIC can take the path of RIPE in performing
needs test only for inbound ARIN transfers so that source would not be
precluded. So why not return to APNIC’s previous position of removing
the needs test from transfers?
Leasing is a natural progression of the IPv4 market that provides
benefits to both lessee and lessor, and that is why it is inevitable
and why it exists today. There are those who hold unused addresses but
who don’t want to sell for some reason. There are those who need IPv4
but who can’t afford to pay for it all at once. There are those with a
temporary need. Leasing is the answer for the smaller organizations
that need IPv4. There are no addresses left in the free pool, so it’s
either buy or lease. No other options.
Today APNIC (and ARIN and RIPE) will allow existing address holders to
lease their blocks to non-connected customers. This is not a policy
violation and addresses can’t be revoked for reasons of utilization or
non-utilization. I believe that contra this policy, leasing should be
authorized explicitly and that leased out addresses in-use on an
operational network should logically be accepted as justification,
because does it really matter whose network they are used on? Isn’t the
salient point that they are in use?
I am against this policy.
Regards,
Mike Burns
From: JORDI PALET MARTINEZ via sig-policy <[email protected]>
Sent: Monday, August 22, 2022 9:21 AM
To: Srinivas (Sunny) Chendi <[email protected]>;
[email protected]
Subject: [sig-policy] Re: prop-148-v001: Leasing of Resources is not
Acceptable
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
-------------
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