As per the original version of this policy, it still does not deal with a) assignment of address blocks to customers, which is a lease, and would be blocked by this policy b) issues with terminology creep - for instance a DHCP lease or delegation (a common term) c) the valid cases for non-assignment leasing that exist between providers and customers, growing networks or other valid use cases d) any assignment less than a /24 that would inadvertently be caught by this because of the clumsy wording
It seems clear the policy also wants APNIC to also investigate “breaches” of use rules; and while I do not generally oppose APNIC ensuring that customers comply with their rules, this policy would seem to also compel APNIC to do so, and it’s not clear that this is a helpful or valid use of the Secretariat’s time and limited resources. This policy continues to paint a complex issue in black and white terms, but in doing so continues in this revision to not react to feedback that it needs to be clarified, and address the valid use cases clearly, and potentially also over reaches its intent. We remain opposed to it in this form, and without a substantial rewrite will continue to hold this position. Also, given there seems to be very little support for it, I wonder how long we’ll continue to receive minor amendments to it, without the fundamental flaws in it being addressed. Andrew Sent from Outlook for iOS<https://aka.ms/o0ukef> ________________________________ From: Shaila Sharmin <[email protected]> Sent: Saturday, September 9, 2023 8:26:58 AM To: sig-policy <[email protected]> Subject: [sig-policy] New version: prop-148 - Clarification: Leasing of Resources is not Acceptable 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. The title of the proposal is changed to "Clarification: Leasing of Resources is not Acceptable unless justified in the original resource request". 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-v005: Clarification: Leasing of Resources is not Acceptable unless justified in the original resource request ---------------------------------------------------------------------------------------------------------------------- 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/NIRs 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/NIR, 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 any form of leasing of addresses is authorized, contrary to the original spirit of the policies and the very existence of the RIRs/NIRs, 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, unless it was documented and accepted with the original need justification. The existing policies of APNIC are not explicit about that, however current policies do not regard any form of 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 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 originally it was 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, any form of 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 transfers. APNIC should proactively investigate lack of compliance with the original resource request justification, including suspected cases for any form of leasing 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. APNIC can already do this today, however, existing policies don’t explicit them clearly. 6. Impact on resource holders ----------------------------- None, unless they violate policies, but this proposal don’t change that, only clarify it. 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
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