Despite the information about RIPE, the main points to focus on Noah's response are very valid arguments about the objectives of the proposal and what it means in practice. The output of allowing such type of "transfers" (between quotes) as written can be very dangerous for the community and how IP allocation is handled.

Fernando

On 14/08/2024 04:45, jordi.palet--- via SIG-policy wrote:
Hi Noah,

I will agree that the most honest thing to do is to return the space that you don’t need to the corresponding RIR, and this is the reason I was since day 1, personally opposed to any kind of transfers. However, my view is not important, but the community one and that means that having “regulated” ways to do things instead of operations “under the table” is the right way to go.

Now, you’re wrong regarding the support of “leasing” in ARIN and RIPE NCC, as indicated in the proposal:
3. Situation in other regions
------------------------------
As far as we know, only in RIPE NCC temporary transfers are allowed. At the 
same time, RIPE NCC does not contemplate leasing, but it does not explicitly 
prohibit it either.

In AFRINIC and LACNIC, neither leasing nor temporary transfers are 
contemplated. However, an equivalent proposal has been submitted in LACNIC.

Temporary transfers are not contemplated in ARIN, and leasing is not a valid 
justification of the need. When leasing addresses, no more addresses can be 
requested. Additionally, certain blocks cannot be leased.

Also, in LACNIC there are 2 proposals being discussed in the same direction.

Regards,
Jordi

@jordipalet


El 13 ago 2024, a las 22:39, Noah <[email protected]> escribió:

Hi Bertrand

Thanks for sharing this version 3. I have been following the conversation from the first version keenly and I had hoped this proposal would be rejected vehemently by the community but I see the Author is still pushing it.

There is already an existing mechanism in place for RIR and LIR to sub-allocated or assign IPv4 address space for all the use cases and situations that the author is attempting to convey to the community about. There is no evidence today that a request by an end-user for small address space to be assigned to them by an LIR was rejected.

APNIC allows permanent transfer on IPv4 and that should be the only option for LIR with excessive and unused IPv4 space. We can not allow as a community a practice that turns IPv4 addresses into a commodity themselves which can be leased for a price as though they were real-estate housing. The address space was meant to be used by LIR to provide services to their end-users and not for them to be leased out to third parties for some price as though they were a service in themselves. An IPv4 is a means to an end. Period. The last thing we want as a community is proposals that will enable folks who stockpiled IPv4 addresses to turn the said address space into a commodity. *If you no longer have the need for IPv4 based on your initial request from the RIR, please transfer the IPv4 space to another LIR or End-User that has the need for it. SAY NO LEASING.
*

ARIN, AFRINIC, RIPE and LACNIC do not support leasing.

AFRINIC has indicated this even in recent times through a post here https://lists.afrinic.net/pipermail/community-discuss/2021-February/003907.html and I quote....

-------------------------
*AFRINIC Communication* comms at afrinic.net <mailto:community-discuss%40afrinic.net?Subject=Re:%20Re%3A%20%5BCommunity-Discuss%5D%20Notice%20to%20all%20the%20legacy%20netblocks%20holders%0A%20in%20AfriNIC&In-Reply-To=%3CFD31E7E3-E395-470B-AC87-EC7E8E3FCB0D%40afrinic.net%3E>
/Fri Feb 5 11:53:24 UTC 2021/

  * Previous message: [Community-Discuss] Notice to all the legacy
    netblocks holders&nbsp; &nbsp; &nbsp; &nbsp; in AfriNIC
    
<https://lists.afrinic.net/pipermail/community-discuss/2021-February/003941.html>
  * Next message: [Community-Discuss] Notice to all the legacy
    netblocks holders in AfriNIC
    
<https://lists.afrinic.net/pipermail/community-discuss/2021-February/003908.html>
  * *Messages sorted by:* [ date ]
    
<https://lists.afrinic.net/pipermail/community-discuss/2021-February/date.html#3907>
    [ thread ]
    
<https://lists.afrinic.net/pipermail/community-discuss/2021-February/thread.html#3907>
    [ subject ]
    
<https://lists.afrinic.net/pipermail/community-discuss/2021-February/subject.html#3907>
    [ author ]
    
<https://lists.afrinic.net/pipermail/community-discuss/2021-February/author.html#3907>


------------------------------------------------------------------------
Dear Frank,

AFRINIC has not approved any application for IP space for the purpose of leasing despite having received such requests.

Regards,

Ashil
-------------------------

The proposal therefore has a flawed problem statement and should be rejected by the wider community.

*I therefore want to go on record to OPPOSE this proposal for fundamental reasons some of which I have stated. *

Cheers,
*.**/noah*
*
*
*PS: Let us focus on IPv6 Adoption *https://www.google.com/intl/en/ipv6/statistics.html#tab=per-country-ipv6-adoption
*
*


On Mon, Aug 5, 2024 at 12:02 PM Bertrand Cherrier via SIG-policy <[email protected]> wrote:

    Dear SIG members,

    A new version of the proposal "prop-157-v003: Temporary IPv4
    Transfers"
    has been sent to the Policy SIG for review.

    Information about earlier versions is available from:

    http://www.apnic.net/policy/proposals/prop-157

    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-157-v003: Temporary IPv4 Transfers

    ----------------------------------------------------------------

    Proposer: Jordi Palet Martinez ([email protected])


    1. Problem statement
    ------------------------
    When in the community we discuss the need for leasing, understood
    broadly in any of its possible modalities, as one of the
    mechanisms to
    facilitate small sets of IPv4 addresses for the transition to IPv6,
    specially for new actors, there are mixed feelings about
    accepting the
    leasing or not. However, we are forgetting that there is already a
    mechanism, already accepted by the community, that could be slightly
    modified to be equivalent to a leasing, and yet have many
    advantages for
    both parties: temporary transfers.

    It is about guaranteeing compliance with the policies with a system
    equivalent to leasing, and that makes it easier to avoid security
    problems, keeping the control by the RIR/NIR, and the security of
    the
    return of the addresses when the leasing period concludes.

    At the same time, it seeks to cover the need to be flexible without
    excessive operational burden for the RIR/NIR, so that the leasing
    period
    can be simply extended, since it is understood that there may be
    situations in which the initially agreed period may be insufficient.

    It is important to emphasize that those who need these transfers,
    as a
    “leasing”, tend to be smaller entities or with more moderate initial
    investments and consequently are financially weaker. Therefore,
    given
    that the ultimate goal must be the deployment of IPv6, using
    IPv6-only
    and IPv4aaS, the number of IPv4 addresses that may be needed will be
    truly reduced. However, there may be other resons for such temporary
    transfers, so no limit on the prefix size is proposed.

    Finally, it seeks to prioritize the benefit of the region and
    therefore
    it makes sense that it is only applicable to operations carried out
    within the region. Furthermore, this prevents permanent transfers
    from
    losing reciprocity with those regions that require it.

    The EC could establish specific rates for this type of transfers
    and/or
    their extensions.


    2. Objective of policy change
    --------------------------------
    APNIC current policies only allow permanent IPv4 address transfers.

    This proposal specifies a change in the policy to allow temporary
    transfers.


    3. Situation in other regions
    ------------------------------
    As far as we know, only in RIPE NCC temporary transfers are
    allowed. At
    the same time, RIPE NCC does not contemplate leasing, but it does
    not
    explicitly prohibit it either.

    In AFRINIC and LACNIC, neither leasing nor temporary transfers are
    contemplated. However, an equivalent proposal has been submitted
    in LACNIC.

    Temporary transfers are not contemplated in ARIN, and leasing is
    not a
    valid justification of the need. When leasing addresses, no more
    addresses can be requested. Additionally, certain blocks cannot
    be leased.


    4. Proposed policy solution
    ------------------------------
    Actual text:
    11.0. IPv4 transfers
    …

    APNIC will maintain a public log of all number resource (IPv4, IPv6,
    ASN) transfers, including unused (market) transfer, merger and
    acquisitions, and historical resource transfer.


    11.1. IPv4 transfers within the APNIC region
    APNIC will process and record IPv4 address transfer requests between
    current APNIC account holders subject to the following conditions.


    11.1.1. Conditions on the space to be transferred

    The minimum transfer size is a /24.

    The address block must be:
    •    In the range of addresses administered by APNIC
    •    Allocated or assigned to a current APNIC account holder
    •    The address block will be subject to all current APNIC policies
    from the time of transfer.
    •    Addresses delegated from the 103/8 free pool cannot be
    transferred
    for a minimum of five years after the original delegation.

    11.1.3. Conditions on recipient of the transfer

    The recipient will be subject to current APNIC policies.
    Recipients that
    do not already hold IPv4 resources must demonstrate a detailed
    plan for
    the use of the transferred resource within 24 months. Recipients
    that
    already hold IPv4 resources must:

    •    Demonstrate a detailed plan for the use of the transferred
    resource
    within 24 months,
    •    Show past usage rate, and
    •    Provide evidence of compliance with APNIC policies with
    respect to
    past delegations.


    Proposed text:
    11.0. IPv4 transfers
    …

    APNIC will maintain a public log of all number resource (IPv4, IPv6,
    ASN) transfers, including unused (market) transfer, merger and
    acquisitions, and historical resource transfer.

    In the case of temporary IPv4 transfers, the public log will
    contain the
    initial date of the transfer, as well as the final one.
    The final date must be updated if the transfer period is extended by
    agreement of both parties, which must be legitimized by APNIC.
    In the case of temporary transfers, APNIC will restore the original
    registration information in the Whois Database once the transfer
    period
    is over.
    11.1. IPv4 permanent and temporary transfers within the APNIC region
    APNIC will process and record permanent and temporary IPv4 address
    transfer requests between current APNIC account holders subject
    to the
    following conditions.

    11.1.1. Conditions on the space to be transferred

    The minimum transfer size is a /24.

    The address block must be:
    •    In the range of addresses administered by APNIC
    •    Allocated or assigned to a current APNIC account holder
    •    The address block will be subject to all current APNIC policies
    from the time of transfer.
    •    Addresses delegated from the 103/8 free pool cannot be
    transferred
    for a minimum of five years after the original delegation.

    11.1.3. Conditions on recipient of the transfer

    The recipient will be subject to current APNIC policies.
    Recipients that
    do not already hold IPv4 resources must demonstrate a detailed
    plan for
    the use of the transferred resource within 24 months. Recipients
    that
    already hold IPv4 resources must:

    •    Demonstrate a detailed plan for the use of the transferred
    resource
    within 24 months (initial transfer period in case of temporary
    transfers),
    •    Show past usage rate, and
    •    Provide evidence of compliance with APNIC policies with
    respect to
    past delegations.

    11.1.4. Additional conditions for temporary transfers

    Temporary transfers are subjected to additional conditions, that
    must be
    warranted by the transfer contract among the parties:
    •    Must include terms of immediate transfer cancellation in
    case of
    usage of the resources for network abuse.
    •    The recipient must have an ASN to announce the transferred
    resources.
    •    The recipient must announce the IPv4 transferred resources
    as well
    the IPv6 resources and plan for the IPv6 deployment.
    •    The recipient must have RPKI for the transferred resources.
    •    The IRR and geolocation must be correctly updated.
    •    The recipient must follow MANRS best practices.

    The source is responsible for the oversight of those conditions.
    APNIC
    will be able to establish operational practices to ensure compliance.

    In case of lack of due diligence by a source, even with different
    temporary transfers or recipients, APNIC will initiate a warning,
    which,
    if ignored will trigger the immediate revocation of the resources
    involved.


    5. Advantages / Disadvantages
    ----------------------------------
    Advantages:
    It allows a way to obtain resources in a temporary basis, in
    order to
    facilitate the IPv6 deployment in a convenient and cheaper way than
    permanent transfers, which is especially important for smaller
    organizations and newcomers. It also offers a solution of other
    cases
    that can benefit from this proposal.


    Disadvantages:
    None.


    6. Impact on resource holders
    --------------------------------
    None.


    7. References
    --------------

    _______________________________________________
    SIG-policy - https://mailman.apnic.net/[email protected]/
    To unsubscribe send an email to [email protected]

_______________________________________________
SIG-policy - https://mailman.apnic.net/[email protected]/
To unsubscribe send an email to [email protected]


**********************************************
IPv4 is over
Are you ready for the new Internet ?
http://www.theipv6company.com
The IPv6 Company

This electronic message contains information which may be privileged or confidential. The information is intended to be for the exclusive use of the individual(s) named above and further non-explicilty authorized disclosure, copying, distribution or use of the contents of this information, even if partially, including attached files, is strictly prohibited and will be considered a criminal offense. If you are not the intended recipient be aware that any disclosure, copying, distribution or use of the contents of this information, even if partially, including attached files, is strictly prohibited, will be considered a criminal offense, so you must reply to the original sender to inform about this communication and delete it.


_______________________________________________
SIG-policy -https://mailman.apnic.net/[email protected]/
To unsubscribe send an email [email protected]
_______________________________________________
SIG-policy - https://mailman.apnic.net/[email protected]/
To unsubscribe send an email to [email protected]

Reply via email to