As written, this policy is absurd.
Virtually all internet numbers in use are leased by the providers that they are
registered to.
The question here is whether or not to require that connectivity services be
provided as part of the lease arrangement.
I’m OK with whatever the community decides in this regard, though I think that
requiring connectivity services
isn’t going to actually have the desired policy effect (there are lots of cheap
ways to provide connectivity
to leased addresses that would circumvent the intent of the author).
The situation in other reasons is also mis-stated (or stated in a misleading
way). For example, in ARIN, the actual
staff determination (not specified in policy, so subject to challenge) is that
addresses utilized for leasing without
connectivity services associated with them do not count as utilized for
purposes of determining eligibility for an
additional allocation/assignment. There is no policy or procedure by which ARIN
would attempt to reclaim such
addresses based on the fact that they are utilized for non-connected leasing.
Examples of leased addresses in common practice:
1. Party Y gets a circuit from $ISP_A. $ISP_A provides party Y with a /24
and allows party Y to announce that /24 to its other providers.
2. $CABLECO issues DHCP leases of addresses to residential customers.
3. $CABLECO rents blocks of static addresses to Party Y for $X/Month.
4. Party Y places servers in a colocation facility and orders network
connecivity
services from $ISP_A, $ISP_B, and $ISP_C. Each of those ISPs provide
some
number of addresses to Party Y for the duration of their contract with
Party Y.
These are all examples of IP leasing that I am pretty sure the author does not
intend
to prohibit, yet would technically be prohibited by th policy as written.
Owen
> On Aug 4, 2023, at 09:59, Shaila Sharmin <[email protected]> wrote:
>
> Dear SIG members,
>
> A new version of the proposal "prop-148-v004: 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 Anupam
> APNIC Policy SIG Chairs
>
>
> -----------------------------------------------------------------------
>
> prop-148-v004: 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 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
> connectivity service, as it was documented with the original need
> justification.
>
> 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 a NIR,
> the justification of the need implies the need to use on their own
> infrastructure and/or network connectivity services provided to
> customers. As a result, any form of IP address leasing is unacceptable,
> nor does it justify the need, unless otherwise justified in the original
> request. 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 should 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
> --
> Regards,
> Shaila Sharmin
> +8801811447396
> _______________________________________________
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