APNIC existing policies are different in that respect than RIPE and ARIN ones. 
The proposal aims to make sure that it is crystal clear, as I just mention in a 
previous reply.

Regards,
Jordi

@jordipalet


> El 30 ago 2023, a las 13:46, Mike Burns <[email protected]> escribió:
> 
> Hi Jordi,
> 
> Thanks for the reply.
> I understand your point about original justification at ripe. But that has 
> not been the policy for a decade now, so I do think your information is 
> inaccurate.
> 
> More to the point, Ripe will, in fact, consider leased out addresses as a 
> justified need whenever they do a needs test.
> 
> That cuts directly against the implication of your text.
> 
> What's more, Arin is perfectly fine with address holders leasing out their 
> addresses. And  Arin can not revoke address space for being leased out or for 
> being unused.
> 
> What is the problem you are asking the Apnic community to solve with your 
> proposal?
> 
> Is it the insecurity of address holders relinquishing "immediate direct 
> control" by allowing another party to use the addresses?
> 
> That's all that I could get from the problem statement.
> 
> Regards,
> Mike
> 
> 
> 
> ---- On Wed, 30 Aug 2023 04:32:11 -0400 [email protected] wrote ----
> 
> Hi Mike,
> 
> There is no inaccuracy on the RIPE point. Long time ago I made the question 
> to RIPE staff and a justification on an original request for IP resources for 
> leasing will not have been accepted as a valid one. Not talking about 
> transfers here, just original justification of the need.
> 
> Working in a new version following all the inputs. Tks!
> 
> Regards,
> Jordi
> 
> @jordipalet
> 
> 
> El 22 ago 2023, a las 16:19, Mike Burns <[email protected] 
> <mailto:[email protected]>> escribió:
> 
> 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] <mailto:[email protected]>> 
> Sent: Monday, August 21, 2023 7:30 PM
> To: [email protected] <mailto:[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
> 
> 
> _______________________________________________
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individual(s) named above and further non-explicilty authorized disclosure, 
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