Hi Jordi,
Please see our comments inline...
On 22/08/2022 11:20 pm, JORDI PALET MARTINEZ wrote:
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?
We are seeking clarification because the current text is not clear enough.
Regarding your 2^nd 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.
We do have generic contact information on the APNIC website here
https://help.apnic.net/s/contactsupport
In the proposed policy solution of this proposal, it says "If any form
of leasing is confirmed by an APNIC
investigation...", but it does not state that these investigations
should be conducted in accordance with the
current procedure and refers to this in the policy document, nor does it
state whether the Secretariat
should proactively identify cases of leasing or only investigate cases
that are reported or detected when
processing resource requests. So, we are seeking clarification in order
to have a clear understanding of this.
Finally, regarding your 3^rd 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.
As we all know, this is questionable.
In the past, authors either provided clear clarification in their
proposal or clarified later after the impact assessment was provided.
For example, prop-125, your own proposal, provided a clear clarity with
details that were required for everyone's understanding.
Regards,
Sunny
APNIC Secretariat
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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