Hello,
The revised Section 3 contains the same inaccuracy that I have pointed out before in other fora to the authors. Notably the situation described in RIPE below is false. RIPE only applies needs-tests to inbound inter-regional transfers, and in this case leasing them out is a justified use. If you don’t accept my assertion, I invite you to contact RIPE directly. Can the authors provide a succinct problem statement that states the problem we are trying to solve? The one I can see is the claim that there is an existing “security problem” on the Internet related directly to blocks being used outside the registrant’s “immediate physical control.” Maybe the proposal would be easier to understand if it was simplified to something like “Addresses may only be utilized by networks that the registrant has immediate physical control of.”? Because then it would be easier to block and filter content, making it safer for the community? Regards, Mike Burns From: Srinivas (Sunny) Chendi <[email protected]> Sent: Monday, August 21, 2023 7:30 PM To: [email protected] Subject: [sig-policy] Re: New version: prop-148 Clarification - Leasing of Resources is not Acceptable --------------------------------------------------------------- Secretariat Impact Assessment: prop-148-v004 ---------------------------------------------------------------- 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 ----------------------------------------------------------------------- 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 _______________________________________________ SIG-policy - https://mailman.apnic.net/[email protected]/ To unsubscribe send an email to [email protected] <mailto:[email protected]>
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