Folks, I think there is still some misunderstanding about this proposal text. I am starting to have the feeling that some people are just discussing it based on the subject and not in the proper text.

The proposal text is quiet clear about:

- RIRs were 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 - the absence of connectivity poses security problems since 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. - Internet Resources should not be leased “per se”

Is it still hard to understand this does NOT impact an traditional Internet Service Provider who allocates Internet Resources to their customer they provide connectivity ? This is the way things have always been and that is not touched anywhere in the proposal. This is the way organizations build Internet Infrastructure and connectivity and there is nothing wrong with it.

The proposal is very clear about leasing resources "per se", without any kind of direct connectivity. What else need to be clarified about it ? Just review the text and it will answer all these concerns. In other words a resource holder who have received many blocks in the past and don't have use for them anymore to should not rent them to another organization who is able to get them assigned directly from the RIR, via a Transfer for example.

During the previous impact assessment from secretariat and the last Webinar there were specific points pointed about making some points more clear about the intentions of the proposal and those which were valid points were resolved by the authors with a new version presented. Those opposing the proposal should do the same that has been done regarding suggesting specific text issues and changes to be adjusted showing how that will damage APNIC community.

Regards Fernando

On 07/09/2022 09:40, Brett O'Hara wrote:
Hi Jordi,

You have stated that you do need a definition because "any form of leasing is unacceptable", and yet I was verbally assured at the APNIC 54 Policy Proposals Webinar on the 25th of August, that several examples of leasing were acceptable, but not documented in the proposal.  My request for a definition in the proposal was positively received by the SIG and we left the issue to the authors.  If the response from the authors is that the definition is not necessary, I can't see how we can endorse the proposal.

Regards,
    Brett

On Wed, Sep 7, 2022 at 8:30 PM JORDI PALET MARTINEZ via sig-policy <[email protected]> wrote:

    Hi Satoru, all,

    We haven't defined leasing, because it is common English term, not
    something specific to "addresses".  I can understand that in other
    languages, it may not be the same, but because the policies are
    bound to the English language, we didn't feel the need to define it.

    In fact, we had a similar discussion about that in LACNIC 6 months
    ago, and we decided to make a new version, which is the same as we
    published in APNIC. The point was to stress that "any form of
    leasing" is unacceptable. If you read that in the context of the
    policy, it starts, as you already mention "own infrastructure or
    directly connected customers". So, anything beyond that will be a
    form of leasing (never mind if you pay a fee for the addresses or
    they are free of charge, or you pay before you use them or
    afterwards, etc., basically "anything not linked to connectivity").

    I don't think the implementation is a problem. We know that many
    proposals come with some challenges, however, the community,
    anyone, can and should help on that. Anyone knowing or getting a
    leasing offer should communicate about that. And by the way, I
    think will not be so dificult to create an automated way of
    detecting it, just by ensuring that the users of any APNIC block
    is directly connected to the AS of the resource holder.

    Regards,
    Jordi
    @jordipalet



    El 2/9/22, 7:15, "Tsurumaki, Satoru" <[email protected]> escribió:

        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
        > _______________________________________________
        > sig-policy - [email protected]
    <https://mailman.apnic.net/<a
    href=>/">https://mailman.apnic.net/[email protected]/
        > To unsubscribe send an email to [email protected]



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        Satoru Tsurumaki
        BBIX, Inc
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