Hello Mr Satoru and Rajesh
Thanks for your comments.
It is very important to clarify that this proposal does not require any
implementation simply because it does not intend to change the current
status about leasing - which is already forbidden - but only make it
clear in the policy text for the avoidance of doubt.
It is also important to highlight that leasing that the proposal refers
is only about when a resource holder organization leases out addresses
to another which they don't provide any connectivity acting like a RIR
rather than an organization that builds up internet infrastructure and
connectivity.
This does not affect in any way the ability of organizations to allocate
IP addresses to customers they provide connectivity wherever the local
they are in the region.
Best regards
Fernando
On 02/09/2022 03:50, Rajesh Panwala wrote:
Dear Team,
As Mr. Satoru, mentioned there are changes, but if carefully
implemented in phased manner, unauthorised leasing can be stopped.
For example in first phase, leasing among countries can be stopped, if
the owner company doesn't provide any services beyond its home
country. For example if a company in India doesn't have any operation
in Singapore or Japan , can't lease resources to those companies in
Singapore or Japan. This can be verified by taking business
registration documents of both lease and lessor.
Once this is done same may be granularized at RIR level, where in
country like India, leasing can be restricted to the licensed service
area for service provider within their designated service area.
This may stop majority of issues, barring few exceptions.
Some more brainstorming is required for better understanding and
precise implementation.
Regards,
Rajesh Panwala
For Smartlink Solutions Pvt Ltd
+91-9227886001
+91-9426110781
On Fri, Sep 2, 2022, 10:44 AM Tsurumaki, Satoru <[email protected]> wrote:
Dear Colleagues,
I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team..
I would like to share key feedback in our community for prop-148,
based on a meeting we organised on 29th Aug to discuss these
proposals.
Many participants support the intent of the proposal but felt that
implementation would be challenging.
(comment details)
- It is undisputed that the current policy allows for the distribution
of IP addresses according to the actual demand of one's own
organization or directly connected customers, and does not allow for
the leasing of IP addresses.
- I think this proposal would be useful if the concept of leasing is
accurately defined.
- Leasing IP addresses that damage the accuracy of whois information
should not be allowed, but I find it difficult to implement.
Regards,
Satoru Tsurumaki / JPOPF Steering Team
2022年8月26日(金) 17:27 Shaila Sharmin <[email protected]>:
>
> Dear SIG members,
>
> A new version of the proposal "prop-148-v002: Clarification -
Leasing of
> Resources is not Acceptable" has been sent to the Policy SIG for
review.
>
> Information about earlier versions is available from:
>
> http://www.apnic.net/policy/proposals/prop-148
>
> You are encouraged to express your views on the proposal:
>
> - Do you support or oppose the proposal?
> - Is there anything in the proposal that is not clear?
> - What changes could be made to this proposal to make it more
effective?
>
> Please find the text of the proposal below.
>
> Regards,
> Bertrand, Shaila, and Ching-Heng
> APNIC Policy SIG Chairs
>
>
>
----------------------------------------------------------------------
> prop-148-v002: Clarification - 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 a 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 delegated by APNIC or
an NIR,
> the justification of the need implies the need to use on their own
> infrastructure and/or network connectivity services provided
directly to
> customers. As a result, any form of IP address leasing is
unacceptable,
> 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.
>
> APNIC may proactively investigate those cases and also initiate the
> investigation in case of reports by means of a form, email
address or
> other means developed by APNIC.
>
> If any form of leasing, regardless of when the delegation has been
> issued, is confirmed by an APNIC investigation, it will be
considered a
> policy violation and revocation may apply against any account
holders
> who are leasing or using them for any purposes not specified in the
> initial request.
>
>
> 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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--
--
Satoru Tsurumaki
BBIX, Inc
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