Hi Andrew,

 

I will say otherwise. As it has been clearly stated by the secretariat that 
leasing is not allowed, and some people believe it should be allowed, the 
proposal just clarify it.

 

If we, as a community believe leasing should be allowed, then, a proposal to 
change that *in the current policy manual* is needed. Otherwise, this proposal 
is precisely helping to ensure that the current policy text is well understood.

 

 

Regards,

Jordi

@jordipalet

 

 

 

El 7/9/22, 22:00, "Andrew Yager" <and...@rwts.com.au> escribió:

 

Wow. This response shows the absurdity of this proposal in the scheme of the 
internet community today and also the issues attached to the poor definitive 
and understanding of terms.

 

This proposal is bad policy, poorly worded and should not be accepted.

 

We thoroughly oppose its adoption in its current form.

 

The existing provisions are more than ample, and this proposal does nothing to 
improve the internet community.

 

In practice, the proposal has still not actually justified it’s need for 
existence and why it should exist.

 

Both Jordi and Fernando have stated multiple times their intention is to see 
unused space returned to the registrar.

 

If that is the intention of this, then make a new proposal to justify that. But 
where will that stop? Will you require operators to issue contiguous 
allocations? Will you require space consolidation? Will you redefine the many 
ways that providers interconnect across exchanges, over long haul services? 
Will you decide that connectivity will be via a physical cable, removing VXCs? 
There is a very narrow view presented here and it is clear that there is an end 
goal in mind from this policy - but this is not the mechanism to achieve it.



Again, the existing member agreement provisions are already sufficient and this 
policy adds no value. If the intention is a different outcome (return of unused 
resources to RIR) make a proposal to do that.



Andrew 

 

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From: Fernando Frediani <fhfredi...@gmail.com>
Sent: Thursday, September 8, 2022 1:27 am
To: sig-policy@lists.apnic.net <sig-policy@lists.apnic.net>
Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of 
Resources is not Acceptable 

 

Hello Andrew

GRE tunnel is not a form of direct connectivity. In order to use a GRE tunnel 
it is already necessary to have a direct connectivity with a Internet Service 
Provider and Upstream who provide internet services.

Can you justify why you are against it if you recognize this is already 
prohibited under the membership agreement ? If something is already forbidden 
so what is the login of not willing to have in clear in the policy text in 
order to avoid any possible doubts ?

Again, this proposal is not changing the current status, so even without it the 
current status can already be circumvented and even if that happens eventually 
it does not invalidate the need to have something clear in the text to make it 
easier for members to understand and avoid that as also to help the RIR to 
stand for these points should a dispute gets to the courts.

Fernando

 

On 07/09/2022 07:48, Andrew Yager wrote:

I mean… to be devils advocate… a gre tunnel is pretty cheap to set up.

 

This type of policy is easily circumvented, and in my opinion unenforceable.

 

Additionally, this activity is already prohibited under the membership 
agreement and I still don’t see any value in adding this.

 

Andrew

 

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From: JORDI PALET MARTINEZ via sig-policy <sig-policy@lists.apnic.net>
Sent: Wednesday, September 7, 2022 8:30:23 PM
To: sig-policy <sig-policy@lists.apnic.net>
Subject: [sig-policy] Re: New version - prop-148: Clarification - Leasing of 
Resources is not Acceptable 

 

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" <stsur...@bbix.net> 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 <shaila.sharmin....@gmail.com>:
    >
    > 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 (jordi.palet@theipv6company.comAnupam)
    >            Amrita Choudhury (amritachoudh...@ccaoi.in)
    >            Fernando Frediani (fhfred...@gmail.com)
    >
    >
    > 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 - sig-policy@lists.apnic.net <https://mailman.apnic.net/<a 
href=>/">https://mailman.apnic.net/sig-policy@lists.apnic.net/
    > To unsubscribe send an email to sig-policy-le...@lists.apnic.net



    -- 
    --
    Satoru Tsurumaki
    BBIX, Inc
    _______________________________________________
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This electronic message contains information which may be privileged or 
confidential. The information is intended to be for the exclusive use of the 
individual(s) named above and further non-explicilty authorized disclosure, 
copying, distribution or use of the contents of this information, even if 
partially, including attached files, is strictly prohibited and will be 
considered a criminal offense. If you are not the intended recipient be aware 
that any disclosure, copying, distribution or use of the contents of this 
information, even if partially, including attached files, is strictly 
prohibited, will be considered a criminal offense, so you must reply to the 
original sender to inform about this communication and delete it.

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