There is nothing in that statement that precludes apnic members from leasing
out their space. Nor is there anything in policy that prevents it. I
participated in that discussion on the transfer list and I suggest everybody
review it carefully. In this case apnic staff continues to muddy the waters by
conflating justification fraud with the act of leasing already acquired
addresses. I note we do not have any word on Jordi's prior assertion that a
fundamental change in usage renders the address block revocable.Will apnic
staff forbid the creation of an ROA by a member which includes the AS number
they do not own?Under which policy will Apnic staff forbid the creation of such
ROAs, as the secretariat threatened? An APNIC member has every right under
contract and policy to change the use of his addresses and also to lease them
out. Please please do not conflate the final /8 policies and justification
fraud with actual leasing. Fraud in justification has always been punishable
in every registry. It's not the issue here.Regards,Mike ---- On Tue, 23 Aug
2022 07:51:50 -0400 [email protected] wrote ----
Thanks for the clarification.
The makes it very clear that what we are doing is just willing to
make something that *already exist* clear in the policy text, for
the avoidance of doubt of all members and fair usage of allocated
resources by APNIC to those who really justify the need.
Fernando
On 23/08/2022 07:35, Srinivas (Sunny)
Chendi wrote:
Hi Jordi,
Please see our comments inline...
On 23/08/2022 9:40 am, JORDI PALET
MARTINEZ wrote:
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Hi Mike,
In at least, LACNIC and AFRINIC, it has been
made clear by staff, that leasing is not a valid
justification for getting resources, *THE SAME as in
APNIC*, so if you use that as a justification, the
request is denied. If you change the “usage” after the
request is passed, then you’re bypassing the original
justification, which is also *disallowed*.
I will let the secretariat to confirm if
leasing is allowed or not, actually responding to your
points on APNIC policies, even if this policy doesn't
reach consensus. However, in my opinion the policy manual
must be clear enough so nobody can interpret that
something is not allowed when actually is not.
The same topic was discussed on the apnic-transfers mailing list
sometime in June this year.
https://mailman.apnic.net/hyperkitty/list/[email protected]/thread/PDLAJK2JMT5RPILF4VZFH55PL4ROP5GG/
I'm copying and pasting my colleague Vivek's response here.
<quote>
APNIC delegates IP addresses to Members based on their
demonstrated need. What Members can do with that address space
once it is no longer needed is impacted by policy requirements. I
will provide two examples.
Example 1: Addresses delegated from the last /8 pool cannot be
transferred for a minimum of five years. During that time, if the
reason for the original request is no longer valid, the resources
must be returned to APNIC.
https://www.apnic.net/community/policy/resources#8.0.-IPv4-Transfers
https://www.apnic.net/community/policy/resources#4.0.-Resource-License
So in this instance, if a Member leases out their IP addresses
within five years of receiving the delegation from APNIC, they are
clearly not needed for their original declared purpose and must be
returned to APNIC.
Example 2: For addresses delegated to a Member more than five
years ago, if a Member no longer has the need for the address
space, APNIC policy says the Member can choose to transfer it to
another organization or return it to APNIC. APNIC policy does not
have provisions for leasing. So in the second example, APNIC
Members leasing addresses would be doing so outside the policy
framework and will not receive APNIC services such as whois
registration and RPKI/ROA access related to those addresses. This
in turn may make it difficult to freely utilise those addresses on
the Internet, due to lack of clear authorisation and a reliance on
the registered holder (lessor) to assist. Of course, if the
addresses being leased were not delegated by APNIC, then the
relevant RIR’s policies apply to those addresses.
<unquote>
Regards,
Sunny
APNIC Secretariat
Regards,
Jordi
@jordipalet
El 22/8/22, 12:17, "Mike Burns" <[email protected]>
escribió:
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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