Re: [sig-policy]Proposal prop-014-v001.txt - Lowering minimum allocation
It is more or less the same as the comment I made on the ML last Dec,
but since a formal proposal was not posted back then, I will make the
comment again.
We discussed the issue in our last Open Policy Meeting and support the
idea of allowing more chances for startup ISPs to be an LIR.
However, the following concerns/suggestions were made from our
community:
- the criteria should prevent enduser networks without technical
reasons from receiving allocations, just because they want
portable addresses
- there could be other ways to implment the policy to meet the
intention
--> lowering the criteria but keeping the allocation size
unchanged(/20)
--> Apply multi-homing criteria instead of criteria based on
address size
- What kind of distinction does APNIC make between allocations and
portable assignments for small networks?
--> If there is an enduser network which can meet the allocation
criteria, can they receive allocations instead of assignments?
--> If yes, wouldn't this reduce the needs for portable assignment
policy?
Also, they are not direct comments regarding this proposal, but there
were following comments regarding the route aggregation.
- wouldn't it still be an issue for ISPs that are not able to afford
the latest router? The cost of router memories are very high
compared to those of PCs
- Latest routers have routing tables in i/f as well, so it cannot be
addressed by simply adding memories
- Wouldn't it use a lot of CPU to calculate the routes once the peer
drops?
These were the comments made when the specific criteria nor allocation
size was not clear, so we may get different feedbacks based on this
particular proposal.
We have translated the proposal in Japanese and going to seek for
comments from the JP community through our ML shortly.
Regards,
Izumi
JPNIC
From: Anne Lord <anne at apnic dot net>
Subject: [sig-policy]Proposal prop-014-v001.txt - Lowering minimum allocation size and
criteria
Date: Mon, 19 Jan 2004 12:41:04 +1000 (EST)
>
> Dear colleagues,
>
> Attached below is a proposal for the upcoming APNIC Open Policy
> Meeting in KL, Malaysia. It is being circulated one month before
> the meeting to give time for feedback.
>
> The proposal can also be found at:
>
> http://www.apnic.net/docs/policy/proposals/prop-014-v001.html
>
> Your comments on this proposal are greatly appreciated and should
> be sent to this mailing list.
>
> Best wishes,
>
> Anne
>
> _____________________________________________________________________
>
> A proposal to lower the IPv4 minimum allocation size and initial
> allocation criteria in the Asia Pacific region [prop-014-v001.txt]
> _____________________________________________________________________
>
>
> Proposed by: APNIC Secretariat
> Version: draft 1.0
> Date: January 2004
>
>
> 1 Summary and motivation
> ------------------------
>
> For more than 10 years, the RIR system has applied initial allocation
> criteria and a minimum size for IPv4 address allocations to Local
> Internet Registries (LIRs). This is done to limit address space
> fragmentation and encourage aggregation and it ensures that only ISPs
> with sufficiently large address needs are able to receive portable
> address space.
>
> The size of the minimum allocation in the APNIC region has changed
> previously in response to concerns and the consensus of the community.
> In late 2000, the APNIC community approved a proposal to lower the
> minimum allocation from /19 to /20.
>
> In December 2001, the APNIC community approved new criteria for
> initial allocations. Those criteria are consistent with the /20
> minimum allocation and include (among others) a requirement to have
> used a /22 from an upstream provider and a plan to use a /21 within
> a year.
>
> Nevertheless, members of the APNIC community have expressed concern
> that the barrier to entry remains too high, preventing many smaller
> ISPs from obtaining portable address space.
>
> This document proposes lowering the minimum allocation size and
> initial allocation criteria, in the interests of fairness and equity
> of access to addresses.
>
> Further, many in the community have argued that the goal of
> aggregation has reduced in importance in recent years, due to
> developments in router technology and routing protocol. It is argued
> that it is now possible to sustain reasonable growth in the
> Internet's routing tables without performance or stability problems.
>
> Please note that the minimum allocation size and the initial
> allocation criteria affect only the first allocation made to an ISP.
> Changing either of these factors would have no impact on the size of
> subsequent allocations.
>
>
> 2 Background and problem
> ------------------------
>
> The APNIC Secretariat receives feedback from members and the wider AP
> community through channels including training events, the helpdesk
> and hostmaster services, and seminars and workshops. Consistently,
> small ISPs express concern at the difficulty of obtaining address
> space from APNIC under current policies.
>
> As noted above, under current policies, to be eligible for an initial
> /20 allocation, an ISP must (among other requirements):
>
> - have used a /22 from their upstream provider or demonstrate an
> immediate need for a /22;
>
> - demonstrate a detailed plan for use of a /21 within a year.
>
> This proposal adopts a quantitative approach to analyse the impact of
> the current policies by comparing the number of APNIC members (ISPs
> which have qualified to receive portable address space) with the
> number of ISPs actually operating in various economies of the region.
>
> The total number of APNIC members broken down by economy (excluding
> NIRs) is shown below. (Note that the totals here also include
> associate members and members who have received portable assignments).
>
> AU 195
> HK 110
> IN 104
> PH 48
> JP 44
> SG 44
> NZ 37
> PK 34
> TH 33
> MY 31
> CN 30
> AP 29
> BD 25
> TW 25
> Other 84
>
> The total number of ISPs operating in an economy can be obtained where
> a licensing or registration regime is in place, or where other survey
> data is available. The following countries were examined.
>
> India (104 APNIC members)
>
> Data for India obtained at http://www.dotindia.com/isp/ispindex.htm
> shows that for 39 A, B, and C licenses issued, 191 ISPs had started
> business as of August 2003[1]. APNIC has 104 members in India. It
> can be concluded that approximately half of the ISPs operating in
> India have not obtained portable address space allocations from
> APNIC.
>
>
> Hong Kong (110 APNIC members)
>
> At http://www.ofta.gov.hk/tele-lic/operator-licensees/opr-isp.html#s4
> it states that in Hong Kong, there were 216 licensed ISPs in August
> 2003 (there are many more ISPs which are not licensed). Of these, 110
> are APNIC members. Again approximately half of the ISPs in Hong Kong
> have not obtained portable address space allocations from APNIC.
>
>
> Australia (195 APNIC members)
>
> In Australia, 964 ISPs are registered with the Telecommunications
> Industry Ombudsman (http://www.tio.com.au/) and 195 of these are
> registered APNIC members.
>
>
> Indonesia (96 APJII members)
>
> According to information supplied by APJII, the NIR for Indonesia,
> there are two types of ISP licence in Indonesia: 'initial' and
> 'secondary' licences. Both are required before an ISP can operate.
> The 'secondary' licence requires portable address space from APNIC.
>
> According to the Department of Post and Telecommunications, 83 ISPs
> hold initial licences only. These ISPs do not have any portable
> address space. A further 96 ISPs are operating with both initial and
> secondary ISP licences. Therefore, just under half of Indonesian
> ISPs have not obtained portable allocations from APNIC.
>
>
> 3 Other RIRs
> ------------
>
> 3.1 RIPE NCC
>
> In the RIPE region, following consensus at RIPE 46, from 1 January
> 2004, the minimum allocation size was lowered from a /20 to a /21.
> Further, it is no longer necessary to demonstrate efficient
> utilisation of a /22 to request an initial allocation.
>
> The motivation for the proposal was that it was difficult or
> impossible for many start-up LIRs to get a PA allocation. As explained
> in the proposal:
>
> "..startup LIRs that do not already hold address space cannot get
> an initial PA allocation (which would be a /20 as of today, or
> bigger), because in many cases, they cannot demonstrate immediate
> need, or prior utilization of sufficient address space."
>
>
> 3.2 ARIN
>
> The ARIN community has made no change to the /20 minimum allocation
> size. However, at ARIN XII, there was consensus on changing the
> multihomed networks policy as follows:
>
> "Multi-homed organizations may justify and obtain a block of
> address space with prefix length extending to /22 directly from
> ARIN. When prefixes are longer than /20, these micro-allocations
> or micro-assignments will be from a reserved block for that
> purpose."
>
> Although there was no change to the minimum allocation size, the
> multihoming policy now allows smaller allocations to be made, to a
> minimum of /22.
>
> The ARIN community also reached consensus on allowing an exception for
> organisations located in the AFRINIC region, which now have a minimum
> allocation of /22.
>
>
> 3.3 LACNIC
>
> The minimum allocation size is a /20.
>
>
> 4 Discussion
> ------------
>
> 4.1 Lowering the minimum allocation size and initial allocation
> criteria
>
> A possible response to concerns about the barrier to entry for small
> ISPs is to lower the minimum allocation size and initial allocation
> criteria. The following discussion considers the effect of lowering
> the minimum allocation size from a /20 to a /21.
>
> Of a total of 734 current open APNIC members, 468 (63%) of those have
> received one allocation only. Further, of those 468 members, 378 have
> had their allocation for longer than one year. In other words, more
> than half (51%) of all APNIC members have held a single allocation for
> longer than one year, without returning to APNIC for additional
> address space.
>
>
> 4.2 Impact on routing tables
>
> Lowering the barrier to entry would have some impact on the size of
> the routing tables. The number of discrete allocations will be
> increased as more entities are able to receive portable prefixes.
> However, it is argued that the impact to the routing table will not be
> significant. The survey of ISP numbers in a number of economies in the
> region (see section 2 above) indicates that the total number of
> additional allocations at the /21 level would number in the hundreds,
> and the incremental impact on the global routing table, currently
> carrying some 130,000 entries, would be negligible.
>
> This conclusion is based upon data analysis of the 3 December 2003
> routing table report[2] which shows that /19 prefixes account for 6%
> of the global routing table, /20 prefixes account for 7%, whereas /24s
> account for almost 55%. Policy changes in recent years (in particular
> the move from a /19 to a /20) have not resulted in significant changes
> to this profile. The largest factor contributing to routing table
> growth remains the advertisement of /24 prefixes, either from legacy
> allocated space or from more specific prefixes of portable space.
>
>
> 4.3 Impact on conservation
>
> Recent research work[3] (which extrapolated allocation practices and
> demand, using an exponential growth model derived from the best of
> 2000-2003 data) concluded that RIRs could continue making IPv4
> allocations on the current basis for the next two decades.
>
> There are many factors that could affect this prediction. Changes in
> RIR allocation policies are one such factor. However, analysis
> suggests that this policy impact is not highly significant. For
> instance, global rates of RIR consumption have been: 4.47 /8s per year
> in 2000; 5.47 /8s per year in 2001; and 3.08 /8s per year in 2002.
> During this preiod the minimum allocation was changed from a /19 to a
> /20 in all regions.
>
> Based on this previous experience of the effect of policy change on
> address consumption, the current proposal is not expected to conflict
> with the RIR goal of conservation.
>
>
> 4.4 Impact on RIR operations
>
> A lower minimum allocation would require some changes to RIR
> hostmaster operations. Specifically, to be able to support contiguous
> allocations, hostmasters would need to reserve address space for a
> longer period. Currently, reservations are held for 12 months,
> extending to 15 months in some cases.
>
>
> 4.5 Impact to NIRs
>
> It is anticipated that the NIRs will conduct their Open Policy
> Meetings with a view to adopting a consistent minimum allocation size
> and allocation criteria.
>
>
> 5 Proposal
> ----------
> It is proposed that the current size of the minimum allocation should
> be lowered from a /20 to a /21. It is also proposed that the
> respective criteria for an initial allocation should be amended such
> that the LIR must:
>
> - have used a /23 from their upstream provider or demonstrate an
> immediate need for a /23; and
>
> - demonstrate a detailed plan for use of a /22 within a year;
>
> All other aspects of the policy would remain unchanged.
>
>
> 6 Implementation
> ----------------
>
> If consensus is reached, it is proposed to implement this policy three
> months after the policy has been approved by the APNIC Executive
> Council (EC).
>
>
> Notes and references
> --------------------
>
> 1 ISPs are not the only type of organisation who become APNIC members
> and receive allocations of portable address space.
>
> 2 The Routing Table report is archived at
> http://www.apnic.net/mailing-lists/bgp-stats/
>
> 3 IPv4 Address Lifetime Expectancy - 2003, Geoff Huston
> http://www.apnic.net/community/presentations/docs/ietf/200307/35
>
>
> --
>
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