Thanks Matt. Well put. Andrew
Get Outlook for iOS<https://aka.ms/o0ukef> ________________________________ From: Matthew Shearing <[email protected]> Sent: Thursday, September 8, 2022 12:39:37 PM To: Fernando Frediani <[email protected]>; [email protected] <[email protected]> Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable Fernando, very simply – if it was already against the rules, why this policy? There should be no need for clarification if this was already ‘illegal’ or ‘against the rules’ as you say. What is the point of this policy if it’s already clear? Further, you keep talking about IPv4 exhaustion and that we need to ‘deal with it’. The fact there exists a leasing market in the first place means that there are plenty of unused IPv4 resources. Otherwise, there would be no IPv4 addresses to lease. If APNIC wants to tackle ‘misuse’, that is also fine. However, why not start with those who have plenty of IP space? Why not build in guarantees that APNIC it revokes space from a large holder, any lessees currently using that space will get access to those IPv4 addresses, as they are the ones using them? Why is none of this even being discussed? It’s incredibly obvious this policy hurts mainly the smaller companies, by going after leases, not the big holdings themselves. By saying ‘there are ways to get blocks’ also tells me very clearly that you’ve either not tried recently, or you’re just willfully ignorant. For many companies, leasing is the only feasible ways to get blocks because we are priced out. Ideologically, we are all in agreement that an IPv6 world would be amazing. Unfortunately, those of us running businesses need to exist here in the real world, not in your imaginary world where we get everything we would like. If you want to help change that, we’ll all be here, cheering you on. Until then, businesses like ours don’t have the luxury of sitting around wishing – we’ve got customers we need to serve and employees we need to pay. These ‘emotional’ arguments are common because they are real. They are for businesses that exist in the real world, in an IP environment that APNIC (and other registrars) created. APNIC allowed the leasing paradigm to occur and did nothing about it. This is not some new thing – it is a mature market that has existed for a long time. It is incredibly irresponsible for APNIC to try and roll it back now, after many years of inaction, and disingenuous for people like you to somehow claim businesses that are just trying to do the best they can in the environment we currently have are somehow at fault. This problem can be laid squarely at the feet of APNIC – and for that reason, it can and will be held liable by those damaged if any changes are made now. This policy is approaching everything from the wrong direction. Its implementation will punish the smallest businesses while doing nothing about the largest legacy holders. If APNIC is serious about the IPv4 allocation issue, it should start with the swathes of latent resources and move backwards. This should be tempered by protections and policies which ensure smaller businesses aren’t ruined in the process. Maybe once that is solved, in several years time, it will be time to revisit this topic. For now though, this is far too premature. The reality is this – for many of us, leasing is right now the only viable option. Taking that away without proposing any kind of genuine alternatives (ie not the handwavium generalisations you’ve been engaging in) is reckless and will result in incredible damage to members who have simply been doing their best in an environment APNIC created in the first place. Cheers, Matt Shearing Chief Executive Officer [https://www.oneqode.com/img/email-pin.png] Brisbane, Australia (AEST) • [email protected]<mailto:[email protected]> • +61 406 778 038 [OneQode™]<https://www.oneqode.com/> [Follow us on LinkedIn]<https://www.linkedin.com/company/oneqode/> From: Fernando Frediani <[email protected]> Sent: Thursday, 8 September 2022 12:15 PM To: [email protected] Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable Unfortunately this shows a tentative to discuss something with lack of enough important information about the topic and also there was not proper follow of most of this thread discussion. First Internet Resources are not irrevocable assets that anyone who holds them can do whatever they like as if they own them. Unfortunately many people in this industry still don't know, but the fact that organizations hold a resource assigned to them does not mean they own it and therefore they must operate them under certain rules otherwise they risk to have them revoked, therefore they cannot be treated as an asset you purchased and may do whatever you like with it. If you purchase a server or a router it is yours and you sell or lease it for whatever amount you wish, but not with internet resources because you don't own them. It is unimportant that anything APNIC may do against those who using IPv4 blocks illegally and may have them revoked because they should never have used in that way in first instance. A while back, when they became members they have signed a contract agreeing they would use the resources according to the rules. Therefore if someone decided to do out of what has been previously agreed they did it in their own risk and cannot allege they are "being affected". Regardless how market evolves APNIC has full rights to revoke resources from members who are misusing resources not in accordance with the contracts they have signed and agreed. And by doing that APNIC is protecting community interests in detriment to individual and very specific interests that wants to use internet resources for proposes they were never conceived for. Seems that people still didn't accept IPv4 exhaustion and keep hoping for something that will never come instead of learn once for all how to deal with it. There are ways to get blocks, for example via transfers and other specific methods, but the scenario many were used for decades doesn't exist anymore and still seems people keep trying to make up stuff to benefit their own specific interest in detriment of everybody else and of the fairness with everybody involved. If a company doesn't have enough money to afford a transfer I am sorry, but that is the new reality for a while. Learn how to deal with it and use other alternatives available like getting from upstreams - who provide connectivity - until there is budget to get address via a transfer for example. And not less important, stop hiding from IPv6 saying that will not revolve. APNIC has all rights to fight in courts and is fully legally covered to enforce what members using internet resources signed and agreed for. Hardly judges will overwrite such agreement because they fell sorry that some people still didn't accept and learned to live with IPv4 exhaustion. No 'difficult' scenario gives the right to a member to void a contract they signed and agreed and win that in court. These 'emotional arguments' of people and companies that will suffer if no leasing is allowed is a common argument from organizations who profit from IP leasing and don't build any internet connectivity and is already old one. If people keep insisting in doing things out of the rules sooner or later they will have to pay the price and they should know the risk before they even started. IP addresses were not made to be rented from a resource holder who don't need them anymore to one that needs and could get them directly from the RIR. Regardless of the most noble reason, going against the rules doesn't make they valid. Fernando On 07/09/2022 22:49, Matthew Shearing wrote: Just wanted to chime in here and follow up on Mike's point (and those of several others). What APNIC has done by its previous conduct is create a scarce asset collected in the hands of a number of large providers, with increasingly less being issued to small providers. As with any scarce asset in human history, this necessarily creates all the prerequisites for a fee market. Just like real estate, vehicles and other commodities, leasing is a natural evolution of scarcity in an asset class with direct utility. Right now, IPv4 blocks are like houses - some own them, but some don't have the capital resources to outright own the amount they need. Simply looking at the prices which IPv4 blocks are going for on the open market will make it clear that many smaller businesses are priced out. Leasing represents a viable option for companies to access the blocks they need and pay manageable, monthly or yearly payments for the use of those blocks. Many businesses are reliant on these currently. Saying that APNIC will outright ban leasing and that this will somehow benefit businesses is abjectly false. Not only will it disrupt many current business operations, but there is no guarantee that a market with more perverse incentives won't emerge afterwards. In our view, APNIC has already demonstrated by its statements and conduct with this policy that they have little grasp on how (and why) asset markets evolve. They've also done nothing to dissuade us that the new 'status quo' after this policy change won't be worse than the current one - which operates relatively fine. Practically, for APNIC to say there will be no meaningful damage to current users and businesses (who are APNIC members in their own right) it must answer the following questions: 1. What alternative does APNIC propose to the current IPv4 market and particularly, leasing options available to smaller companies and new entrants? 2. How will terminating leases currently on foot result in a better outcome for the businesses currently relying on them? 3. How will new IPv4 addresses be allocated, what timeframes and costs will be involved in this allocation? 4. Can APNIC give guarantees to current lessees who are reliant on IPv4 address leases that they can continue to access those addresses or will have replacements of similar value, at less cost, instantly after the change is made? 5. Is APNIC prepared to be held liable in lawsuits or a class action for the damages incurred by this policy change? Has it considered this risk and informed members accordingly? It appears that those that will not be affected by this policy or those who already have large IPv4 blocks are some of the largest proponents of it - which makes sense. It is easy to vote for a change if it's only others that will be affected. However, there are a large number of SME businesses out there who rely on these leases to run their operations. For them, this isn't just some merely intellectual exercise. Rather, it's a question of hundreds of thousands, or even millions, of dollars. It's their ability to remain operational. It's their employees' livelihoods and those of their families. It's a core part of how they operate and for many, the foundation which they've built their business on. This policy change seems to almost be a 'policy for policies sake'. It is clear that the repercussions of this were either not considered, or not even known, as the policy notes listed 'nil' negative effects. That this is the opinion of APNIC (and it seems, of a significant portion of the community) is incredibly concerning, because it couldn't be further from the truth. Many real businesses will be affected by this, with real people. And the flippancy with which many within APNIC are treating this proposal shows a concerning lack of empathy towards that - and a failure to grasp the nature of IPv4 addresses as a modern asset class. Without the above questions answered, I don't see how this policy vote can go ahead - and I would implore everyone considering this policy to reject it outright. There may be issues with the current IPv4 paradigm but this is definitely not the solution. Kind Regards Matt Shearing Chief Executive Officer [https://www.oneqode.com/img/email-pin.png] Brisbane, Australia (AEST) • [email protected]<mailto:[email protected]> • +61 406 778 038 [OneQode™]<https://www.oneqode.com/> [Follow us on LinkedIn]<https://www.linkedin.com/company/oneqode/> From: Mike Burns <[email protected]><mailto:[email protected]> Sent: Thursday, 8 September 2022 6:52 AM To: 'Fernando Frediani' <[email protected]><mailto:[email protected]>; [email protected]<mailto:[email protected]> Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable Alas, Fernando, there is no alternative “drug” for people to live without IPv4. Banning leasing hurts the smallest and poorest of companies most. And you cannot elucidate any “major damages” suffered where leasing has actually, in reality, occurred for many years at RIPE. Yet you use this evidence-free assertion as your major argument against leasing. That some kind of serious damage will occur to the RIR system. As a broker who as to talk to actual, real companies in need, who can’t afford to pay upfront, can you tell me what I should say when they ask me why leasing is forbidden? If I say it’s to avoid “major damages” and they ask what they are, can you tell me? What major damages? Regards, Mike From: Fernando Frediani <[email protected]<mailto:[email protected]>> Sent: Wednesday, September 7, 2022 4:33 PM To: [email protected]<mailto:[email protected]> Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable Do you understand the argument that certain drugs can alleviate certain pains but they remain forbidden because they cause a major damage to society in long term and there are alternatives for people be able to still live without have to use those type of damageable mechanisms. Companies can also live without that and still have other legally allowed mechanisms. This discussion is unnecessary for this policy discussion as what it proposes is to make something *already forbidden* clear in to the text, not to discuss if leasing should exist or not. If anyone opposes it please take attention to provide arguments and suggestions on how to address the issues raised about what the proposal really proposes. Regards Fernando On 07/09/2022 14:12, Mike Burns wrote: Hi Fernando, Do you understand my argument that smaller business cannot afford the full upfront payment but can afford monthly lease payments? Please address that simple argument by telling me how the small business benefits by not having the lease option, but only having the purchase option. Regards, Mike From: Fernando Frediani <[email protected]><mailto:[email protected]> Sent: Wednesday, September 7, 2022 1:01 PM To: [email protected]<mailto:[email protected]> Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable IP Leasing is already banned in most RIRs and should stay as is. But yes it does help as it doesn't push even further up IPv4 pricing and makes it easier for these small companies to get IPv4 via the proper and allowed way which are transfers. Other then diverting totally the propose o IPv4 Allocation, Leasing market contributes significantly to price increasing fueling the market with more demand for that type of very wrong thing. RIPE is normally not a good example for certain policies which don't seem to have receptivity in discussions on all other RIRs. There are still mechanisms that allow companies to get IP addressing either directly from the RIR, via Transfers which is a pretty common way or from the Upstream providers. People may not have got used yet to learn to live with less address and they may believe they need a bunch of address. IP Leasing will never help small companies. The ones who really benefit from it are the IP broker companies who profit from them and also the resource holders which don't justify anymore to keep those addresses and are also profiting from something that should have been re-assigned directly to those who really need and justify for them in order to build Internet Infrastructure and Connectivity and instead are leasing a asset they don't own. Fernando On 07/09/2022 12:39, Mike Burns wrote: Hi Fernando, So your argument is that banning leasing actually helps smaller companies in their quest for IPv4? Are you aware that RIPE has allowed leasing for many years but is still a functioning RIR whose IPv4 sale prices are not more expensive despite the history of leasing there? Can you reconcile that with your argument that leasing will raise prices for both leasing and transfers? Are you aware that it’s not always possible to get IPv4 blocks from the company that is providing you with connectivity? Regards, Mike From: Fernando Frediani <[email protected]><mailto:[email protected]> Sent: Wednesday, September 7, 2022 11:27 AM To: [email protected]<mailto:[email protected]> Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable This is exactly the opposite. Allowing IP leasing to happen more than just tottaly divert the propose of IP assignments by RIRs it make it bad specially for smaller companies as it increases the cost for both leasing and transfers in long term. The cost of leasing is based on the transfer and if leasing is allowed then transfer prices will always go up which makes it even harder for smaller companies to go into the market. Any form of IP leasing without a direct connection relationship to provide a connectivity service makes it more expensive for smaller companies to get IP addresses to operate. Fernando On 07/09/2022 11:15, Mike Burns wrote: Hi Jordi, It’s plain you feel that we should do all possible to raise the price of IPv4 and make it unattainable for small business in the vain hope that this will drive IPv6 adoption. I don’t think making IPv4 more difficult to acquire is the job of the RIR system. You have not addressed the inability of smaller companies to acquire necessary IPv4 blocks if you ban leasing. Is that something you are comfortable with, in pursuit of the IPv6 grail? It’s okay with you that this policy prevents small companies from growing? Regards, Mike From: JORDI PALET MARTINEZ via sig-policy <[email protected]><mailto:[email protected]> Sent: Wednesday, September 7, 2022 10:11 AM To: [email protected]<mailto:[email protected]> Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of Resources is not Acceptable Actually, I must disagree … If organizations having unused resources, they need to transfer them or return them to the RIR. If prices keep going high, that could encourage faster IPv6 adoption, then transfer prices will go down, up to “no value”. It takes time, but it is just market. Those that have more money, have more facilities to do a faster transition and not bother about IPv4. Regards, Jordi @jordipalet El 7/9/22, 16:05, "Mike Burns" <[email protected]<mailto:[email protected]>> escribió: Hello, Per Gaurav’s statement that “only those with millions of dollars can think of getting ips”, this community should oppose this policy. Because the only way small companies can afford to get ips today is by leasing them. The same way the small company can’t afford to purchase a big office building but instead rents an office. Leasing is the only way to finance IPv4 acquisitions today. No bank or other entity that I am aware of will do it. Purchasing addresses requires full upfront payment, but leasing allow for much smaller monthly payments. If this community wants to ensure only the largest and richest companies can acquire new addresses, ban leasing. But if the community tries to ban something with such a large business motivation behind it, it will find itself struggling against a powerful foe. And for what purpose do we punish the small businesses? Leasing puts addresses in the hands of those who need them to build and operate networks. Isn’t that the primary goal of the RIR system? Regards, Mike El 2/9/22, 9:23, "Gaurav Kansal" <[email protected]<mailto:[email protected]>> escribió: Hello everyone, In my opinion, even Trading of IPs (leave apart the lease for making dollars) in the name of transfers must be stopped. If organisation doesn’t need IPs , then those must be returned back so that smaller organisations can get it from the RIR. Currently, only the one which have millions of dollars can think of getting IPs. In today’s scenario, no one can start the Data Centre, ISP business without investing millions in IPs. Even education and research org doesn’t have an option to get IPs from RIR. This is like horse trading and isn’t a good practice for the community as a whole. Regards, Gaurav Kansal On 02-Sep-2022, at 12:20, [email protected]<mailto:[email protected]> 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]<mailto:[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]<mailto:[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]<mailto:[email protected]>) > Amrita Choudhury > ([email protected]<mailto:[email protected]>) > Fernando Frediani ([email protected]<mailto:[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 - https://mailman.apnic.net/[email protected]/ > To unsubscribe send an email to > [email protected]<mailto:[email protected]> -- -- Satoru Tsurumaki BBIX, Inc _______________________________________________ sig-policy - https://mailman.apnic.net/[email protected]/ To unsubscribe send an email to [email protected]<mailto:[email protected]> _______________________________________________ sig-policy - https://mailman.apnic.net/[email protected]/ To unsubscribe send an email to [email protected]<mailto:[email protected]> [https://email.gov.in/videos/images/75.jpg]<https://amritmahotsav.nic.in/> _______________________________________________ sig-policy - https://mailman.apnic.net/[email protected]/ To unsubscribe send an email to [email protected]<mailto:[email protected]> ********************************************** IPv4 is over Are you ready for the new Internet ? http://www.theipv6company.com The IPv6 Company This electronic message contains information which may be privileged or confidential. 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