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Secretariat Impact Assessment: prop-148-v004
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APNIC notes that this proposal suggests explicitly stating in the
APNIC Internet Number Resources policy document that leasing of
addresses is not permitted in the APNIC region.
Questions/Comments:
-------------------
- Can the authors provide a clear definition of what is considered
'leasing'?
- How do the authors propose APNIC verifies that IP addresses are
being leased and how often do they suggest APNIC should be checking?
- Does this proposal apply to all existing delegations or only those
addresses delegated after the proposal is implemented (if it reaches
consensus)?
- How does this proposal apply to account holders who have previously
received delegations and use the IP addresses under different entities
(for example, subsidiaries using them in different locations)?
Implementation:
---------------
This proposal may require changes to APNIC systems. If this proposal
reaches consensus, implementation may be completed within three months.
Regards,
Sunny
On 5/08/2023 2:59 am, Shaila Sharmin 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
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prop-148-v004: Clarification - Leasing of Resources is not Acceptable
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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 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://www.arin.net/participate/policy/proposals/2022/ARIN_prop_308_v2/>
https://politicas.lacnic.net/politicas/detail/id/LAC-2022-2/language/en
<https://politicas.lacnic.net/politicas/detail/id/LAC-2022-2/language/en>
--
Regards,
Shaila Sharmin
+8801811447396
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