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Re: [sig-policy] prop-029-v001: Proposal for Discrete Networks and National Peering

Hi Uchenna,
Many thanks for your proposal. I have just a couple of questions to assist me in my understanding.
At APNIC17 a similar proposal to this one was presented by Norman Hoy of MCI on behalf of Dawn Martin: (http://www.apnic.net/docs/policy/proposals/prop-013-v001.html).
The minutes from that meeting document a recommendation to look at the HD ratio proposal as a possible solution to the problems that were raised. Although this is not in your proposal, I would be interested to know if you looked at this at all?
For more details see: http://www.apnic.net/docs/policy/proposals/prop-020-v001.html 

One clarification w.r.t item 4:

>>4. This proposal does not conflict with current APNIC policy;
This is not in fact quite right. Current policy does not support the allocation of large blocks of address space in the way that you describe. The policies under the suspended 'confederation' membership did operate in this way in the past, but today they are very different and in fact are now in line with the way the rest of the membership receives its resources. The parent company does not get a super-block to 'manage' and sub-allocate. Each 'discrete' network is handled directly by APNIC hostmasters in terms of the their resource requests and assignment window requests.
I hope this clarifies things for you (and please dont hesitate to ask if not!) 

Best wishes,
Anne
--



Here is the proposal for review and comments.
---------------------------------------------------------------------------- 
Proposal to permit large ISPs to manage multiple country accounts under a
single APNIC membership using discrete network concept.
---------------------------------------------------------------------------- 

Summary
---------------------------------------------------------------------------- 
This Proposal is intended to simplify the management of multiple country
accounts hereby each country account would be considered a discrete network. 
>

This proposal will support Global/Continental-Regional/National peering
policies and would be vital for the implementation of the IPv6 routing
policies.

Benefits
---------------------------------------------------------------------------- 

1.  Simplify management of multiple country accounts;

>
Currently large ISPs such as MCI with multiple APNIC accounts (one per country) using the concept of discrete network can simplify their procedures by combining their membership accounts under a single account, while 
managing each country IP allocation as separate discrete networks.

2.  Simplify Billing;

>

      This concept will simplify the billing requirement for APNIC, hereby
reducing the number of member accounts per ISP and unify the billing cycles. 

3. Peering;
      Most large ISPs with International networks spanning multiple
continent and regions have peering policies implemented on their network.
Currently, MCI has 3 levels of peering, namely global-peering,
continental-regional peering and National peering.   In order to make
national peering work in IPv6, we will need to advertise a single aggregate
per country.  This will typically a /32, each country /32 should be able to
be aggregate into a single aggregate so that a single announcement could be
made to customers and continental-regional peers.

>

      In some countries, it is required by law that we peer with other ISPs
or interconnect at NAP (Network Access Point).  In this case, the issue of
peering is required and this can only be done using aggregated IPv6
addresses which will be based on the level of peering (It can be
Global/Continental-regional/National peering).

4. This proposal does not conflict with current APNIC policy; only seeks to
simplify current APNIC operational requirements, frameworks for management
and allocation of IPv6/IPv4 addresses.  This policy will be vital to
integration of implantation of IPv6 into an Asia Pacific region.

Case Study
---------------------------------------------------------------------------- 
Some organizations have requirements for multiple discrete networks that
need individual address allocations. Discrete networks must often have
separate unique globally routable address space and will often grow at
different rates. In order for organizations with multiple discrete networks
to request additional address space under a single maintainer ID, the
organization must use the following criteria:

* The organization should be a single entity, and not a consortium of
smaller independent entities.

* This policy applies only to organizations that have been previously
granted address space by an RIR. This policy does not apply to organizations with only legacy address space. 

* The organization must have multiple (at least two) discrete multi-homed
networks.

* The organization must have compelling criteria for creating discrete
networks. Examples:

o regulatory restrictions for data transmission

o geographic distance and diversity between networks

o autonomous multi-homed discrete networks

* The organization must apply for this policy to be applied to their
account.

Other APNIC IP allocation policies for IPv6/IPv4 would apply to this
proposal.

Proposal
---------------------------------------------------------------------------- 

4.1   When applying for additional address space from an RIR for new
      Networks or additional space for existing networks the
      organization must show greater than 50% utilization for the last
      block granted by the RIR and their allocations as a whole.

4.2   The organization must not issue additional IP address space to a
      discrete network unless all the blocks sub-allocated to that
      network show utilization greater than 80% individually and as a
      whole.

4.3   The organization must not sub-allocate a CIDR block larger than
      the current minimum allocation size of the RIR (currently
      /21-IPv4, /32-IPv6 for APNIC region) to a new network.

4.4   The organization must not sub-allocate an additional CIDR block
      larger than the current minimum allocation size of the RIR
      (currently /21-IPv4, /32-IPv6 for APNIC 's region) to an existing
network, unless previous growth rates for that network indicate that it is 
      likely to utilize a larger CIDR block before the time the
      organization will be requesting an additional block from the RIR.

4.5   When sub-allocating a block larger than the minimum allocation
      size to an existing network the ISPs should use the smallest
      allocation possible out of a larger reserved block. This
      requirement is to reduce the number of routes the ISPs will
      announce from that autonomous system.

4.6   The ISPs must follow guidelines of RFC 2050 (or its replacement)
      and the policy of the granting RIR for allocations that are
      assigned or sub-allocated to downstream networks. This includes
      record keeping of IP address requests and network utilization
      documents for audits by the RIR.

4.7   ISPs with 'multiple membership accounts' should request that     this
      policy apply to them, their existing allocations be merged, and that
      additional allocations will fall under this policy.

4.8   The ISPs must record sub-allocations or assignments down to the
      current RIR bit boundary and record them in an approved RIR public
      database.

4.9   The ISPs must keep detailed records of how it has sub-allocated
      space to each discrete network. This should include the block
      sub-allocated, any reserved blocks, and date of allocation/
      reservation. The discrete network allocation information should
      also be present in a public database.

4.10  An assignment window will be assigned to the ISPs and will need to
      be followed for their entire network. Second opinion requests will
      need to be sent to APNIC for review. This is to include blocks of
      addresses that are assigned to new or existing pools within the ISPs
      network.


Fees
---------------------------------------------------------------------------- 

The IP addresses from all combined resources would be taken into account
when assessing the membership tier for the organization upon the renewal of
their membership.


References
---------------------------------------------------------------------------- 

http://www.arin.net/policy/index.html#four5

http://www.arin.net/policy/proposals/2004_5.html

Policy Proposal 2004-5: Address Space for Multiple Discrete Networks

http://www.arin.net/policy/proposals/2001_6.html

Policy 2001-6: Multiple Discrete Networks - Single Maintainer ID


Uchenna N Ibekwe
MCI Inc.
Phone +1-703-886-2650
uchenna.ibekwe@mci.com

"All I have seen teaches me to trust the Creator for all I have not seen."
Ralph Waldo Emerson

"Confidence comes not from always being right, but from not fearing to be
wrong." --Peter T. McIntyre
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