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[sig-policy] prop-050-v002: IPv4 address transfers



Dear SIG members

Version two of the proposal 'IPv4 address transfers' has been sent to
the Policy SIG for review. It will be presented during the Policy SIG
sessions at APNIC 25 in Taipei, Taiwan, 25-29 February 2008.

The proposal's history can be found at:

          http://www.apnic.net/policy/proposals/prop-050-v002.html

We invite you to review and comment on the proposal on the mailing list
before the meeting.

The comment period on the mailing list before an APNIC meeting is an
important part of the policy development process. We encourage you to:

      - Ask the proposer questions if anything in the proposal is
        unclear
      - Point out advantages and disadvantages you see in the proposal
      - State whether you support or oppose the proposal

Mailing list discussions will be taken into account when the proposal
is discussed at the upcoming APNIC meeting. So please make sure you have
your say.

APNIC Policy SIG Chairs
Toshiyuki Hosaka
Randy Bush
Jian Zhang

________________________________________________________________________

prop-050-v002: IPv4 address transfers
________________________________________________________________________



Author:    Geoff Huston
            gih@apnic.net

Version:   2

Date:      22 January 2008



1.  Introduction
----------------

This is a proposal to remove APNIC policy restrictions on the transfer
of registration of IPv4 address allocations and IPv4 portable address
assignments between current APNIC account holders. This proposal is a
refinement of the historical resource transfer policy and applies to
IPv4 resources held by current APNIC account holders.


2.  Summary of current problem
------------------------------

Current APNIC policies relating to the registration of transfer of
address holdings limit the eligibility of registration of transfers to
those relating to mergers and acquisitions of entities that are
administering an operational network.

It is currently anticipated that the IPv4 unallocated address pool
will be exhausted in a timeframe of between 2009 and 2011. There is a
very considerable level of investment in IPv4-based services in the
Asia Pacific region, and a transition to IPv6-based service delivery
is likely to take longer than the remaining period of unallocated
address availability. Accordingly, it is likely that demand for IPv4
addresses will continue beyond the time of unallocated address pool
exhaustion, leading to a period of movement of IPv4 address blocks
between address holders to meet such continuing demand for IPv4
address blocks.

It is the objective of the APNIC IPv4 address registry to accurately
record current address distribution information.

This proposal allows APNIC to recognise the transfer of IPv4 addresses
between current APNIC account holders, and places some constraints on
the parties to the transfer as a precondition for the registration of
the IPv4 address transfer to be undertaken by APNIC.


3.   Situation in other RIRs
----------------------------

It is the understanding of the proposer that no comparable IPv4
resource transfer policy between account holders has been adopted in
any other RIR.

A proposal for address transfers similar to this proposal has been
submitted to the RIPE community as a Policy Proposal:

     2007-08: Enabling Methods for Reallocation of IPv4 Resources
     http://www.ripe.net/ripe/policies/proposals/2007-08.html


4.   Details of the proposal
----------------------------

APNIC will process IPv4 address transfer requests following the
adoption of this proposed policy, subject to the following conditions:

Conditions on the IPv4 address block:

     - Only IPv4 address blocks equal to, or larger than, a /24 prefix
       may be transferred.

     - The address block must be in the range of addresses administered
       by APNIC, either as part of a /8 address block assigned by the
       IANA to APNIC, or as part of a historically-assigned address
       block now administered by APNIC.

     - The address block must be 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. This includes address blocks
       previously considered to be "historical".


Conditions on source of the transfer:

     - The source entity must be a current APNIC account holder.

     - The source entity must be the currently registered holder of the
       IPv4 address resources, and not be involved in any dispute as to
       the status of those resources.

     - The source entity will be ineligible to receive any further IPv4
       address allocations or assignments from APNIC for a period of 24
       months after the transfer.

     - In making any future IPv4 address resource requests to APNIC,
       for as long as IPv4 address resources are available from APNIC,
       following the expiration of this 24 month ineligibility
       period, the source will be required to document the reasons for
       the IPv4 address resource allocation.


Conditions on recipient of the transfer:

     - The recipient entity must be a current APNIC account holder.

     - The recipient entity of the transferred resources will be
       subject to current APNIC policies. In particular, in any
       subsequent APNIC IPv4 address allocation request, the recipient
       will be required to account for all IPv4 address space held,
       including all transferred resources.

     - APNIC fees payable by the recipient will be assessed on the
       basis of all resources held.


The address transfer process:

     After APNIC is notified of the transfer by both the source and the
     recipient of the transfer:

     1. APNIC will update the registration records relating to the
        transferred addresses.

     2. APNIC will adjust the source's address holdings as of the date
        of transfer.

        In terms of membership and/or service fee calculations this
        shall be processed in the same manner as a return of address
        holdings to APNIC as of that date.

     3. APNIC will adjust the recipient's address holdings to include
        the transferred addresses as of the date of the transfer.

        In terms of membership and/or service fee calculations this
        shall be processed in the same manner as an allocation or
        assignment of address holdings to the recipient as of that date.

        In order to preserve aggregation capabilities the transfer
        recipient may notify APNIC that the transferred address may be
        returned to the unallocated APNIC address pool, and a different
        address of the same size may be registered to the recipient of
        the transfer. This option would be available to the recipient of
        the transferred address, at the discretion of the recipient.

     4. The following transfer details will be published by APNIC in a
        public log of resource transfers:

        - Source
        - Recipient
        - Address resources
        - Date of transfer


Transfer fees:

     APNIC may charge the recipient a service fee on the transfer
     transaction. The transfer service fee may vary according to the
     total size of the address block being transferred.

     The transfer fee schedule shall be set initially by the APNIC
     Executive Council upon adoption of this policy.  The transfer fee
     schedule will be included as part of any future review of APNIC
     fees and charges.


5.   Advantages and disadvantages of the proposal
-------------------------------------------------

Advantages:

This proposal would:

     - Ensure that the APNIC registry continues to reflect the current
       actual status of IPv4 resource holdings by APNIC account holders.

     - Mitigate the risks to the integrity of the network and its
       routing and addressing infrastructure associated with the
       unregistered transfers of IPv4 addresses. This proposal, by
       acknowledging the existence of address transfers and registering
       the outcomes would ensure that the APNIC address registry
       continues to maintain accurate data about resources and resource
       holders. The proposal also ensures that those parties who
       currently rely on the accuracy of this registration information
       can continue to rely on the currency and accuracy of this
       information in good faith.

     - Provide a stronger incentive for unused IPv4 address space to
       return to active use, helping to satisfy residual demand for IPv4
       address space across the IPv6 transition.


Disadvantages:

     - Concerns have been raised about a market-based system emerging
       as the only means to obtain IPv4 address space in future, and
       the potential for certain forms of market failures, including
       the possibility of hoarding, speculation and price manipulation.

       A number of factors mitigate these risks. As the transition to
       IPv6 gathers pace, a market-based value of IPv4 addresses would
       fall in line with the decreasing value proposition of IPv4-based
       services in an increasing IPv6 network. An additional constraint
       would apply if this policy were to be adopted while IPv4
       addresses are still available from APNIC, as APNIC's established
       IPv4 address allocation process would continue to provide an
       alternative source of supply of IPv4 addresses to the industry.


6.   Effect on APNIC members
----------------------------

APNIC members will have the ability to register the transfer of IPv4
address resources between APNIC account holders.


7.   Effect on NIRs
-------------------

This policy does not encompass IPv4 address holdings administered by
NIRs, nor the transfer of resources where the source or recipient are
NIR-serviced entities.

(end of document)