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[sig-policy] prop-068-v001: Inter-RIR transfer policy
Dear SIG members
The policy proposal 'Inter-RIR transfer policy' has been sent to
the Policy SIG for review. It will be presented at the Policy SIG
at APNIC 27 in Manila, Philippines, 23-27 February 2009. The
proposal's history can be found at:
http://www.apnic.net/policy/proposals/prop-068-v001.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 express your views on the proposal:
- Do you support or oppose this proposal?
- Does this proposal solve a problem you are experiencing? If
so, tell the community about your situation.
- Do you see any disadvantages in this proposal?
- Is there anything in the proposal that is not clear?
- What changes could be made to this proposal to make it more
effective?
randy and jian
_______________________________________________________________________
prop-068-v001: Inter-RIR transfer policy
________________________________________________________________________
Author: Geoff Huston
gih@apnic.net
Version: 1
Date: 16 January 2009
1. Introduction
----------------
This is a proposal to allow the recognition and recording of
address transfers between APNIC and other RIRs and between APNIC
and NIRs.
2. Summary of current problem
------------------------------
prop-050, "IPv4 address transfers", proposes that APNIC recognise
the transfer of IPv4 address resources between APNIC
members. However, it does not address the following situations:
- A transfer between an APNIC member and a member of another
RIR
- A transfer between an APNIC member and a member of an
APNIC-recognised NIR
3. Situation in other RIRs
----------------------------
No similar policy proposals have been adoped in other RIRs.
4. Details of the proposal
----------------------------
APNIC will recognise and register a transfer of IPv4 addresses in
the following cases:
4.1 Transfer from APNIC member to another RIR or NIR member
The following constraints apply to the disposer of the IPv4
address disposer (the "source entity"):
- 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.
The following constraints apply to IPv4 address block being
transferred:
- 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.
APNIC will require the details of the receiving entity of the
transfer, and will confirm that the receiving entity and the
IPv4 address block meets the eligibility criteria established
by the RIR or NIR nominated by the receiving entity prior to
approval of registration of the transfer.
The transfer process:
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. The following transfer details will be published by
APNIC in a public log of resource transfers:
- Source
- Recipient
- Recipient RIR or NIR
- Address resources
- Date of transfer
Transfer fees:
APNIC may charge the source entity 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.
4.2 Transfer from member of another RIR or NIR to APNIC member
The following constraints apply to the recipient of the IPv4
address disposer (the "recipient entity"):
- 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 following constraints apply to IPv4 address block being
transferred:
- Only IPv4 address blocks equal to, or larger than, a /24
prefix may be transferred.
APNIC will require the details of the source entity of the
transfer, and will confirm that the source entity and the IPv4
address block meets the eligibility criteria established by
the RIR or NIR that holds the address registration prior to
approval of registration of the transfer.
The transfer process:
1. APNIC will update the registration records relating to
the transferred addresses.
2. 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.
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, and subject to availablility of an alternate
address block from APNIC
3. The following transfer details will be published by
APNIC in a public log of resource transfers:
- Source
- Source RIR or NIR
- Recipient
- Address resources
- Date of transfer
Transfer fees:
APNIC may charge the recipient entity 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
-------------------------------------------------
5.1 Advantages
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. In
particular, it 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 in particular,
associated with the unregistered transfers of IPv4
addresses.
- 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.
5.2 Disadvantages (and responses)
5.2.1 Altering the traditional concepts of IP addresses
This proposal has the potential to alter a number of
traditional preconceptions relating to addresses and
their value, including challenging the concept that
addresses are not in and of themselves assets and
addresses do no in and of themselves have monetary value
outside of the narrow constraints of use in networks for
routing and end point identification. Changing these
common percpetions about addresses and their use opens
up the potential for a number of responses, including:
- The loss of strong aggregation capability in the
address space, with the consequent load being
imposed on the routing system.
- The significant shift away from a universal
need-based address allocation model in the
underlying policy framework.
- The treatment of addresses as property with the
associated legal ramifications in terms of
corporate and contract law.
- The imposition of taxes on addresses and their
movement.
- The potential for unfairness and inequities to be
realized in terms of access to addresses for use
by network service providers.
Response:
A number of factors mitigate the risks above:
- As the transition to IPv6 gathers pace, any
residual value of IPv4 addresses would fall in
line with the decreasing value proposition of
IPv4-based services in an increasing IPv6 network.
- If this policy were to be adopted while IPv4
addresses are still available from APNIC, APNIC's
established IPv4 address allocation process would
continue to provide an alternative source of
supply of IPv4 addresses to the industry.
5.2.2 Proposal diverts attention from address reclamation and
resuse
It has been argued that the proposal diverts attention
from policy development that encourages IP address
reclamation and reuse.
Response:
To date the level of return and reclamation of addresses
has been minimal. Aside from price-based mechanisms it
is unclear that further policy refinement would alter
this situation.
Even if policy development encouraged address
reclamation and reuse, there is the distinct possibility
that the amount reclaimed addresses would be smaller
than the amount needed for APNIC to continue to allocate
addresses on a needs-basis after the unallocated address
pool has been exhausted.
An open and significant issue is how APNIC could fairly
ration limited addresses when faced with a much larger
set of demands. In other words, concentrating on
relamation and reuse policies rather than transfer
policies also contains significant issues that may prove
challenging to resolve as a policy matter.
5.2.3 Potential for APNIC to be cast as a regulator
If APNIC adopted this policy, APNIC may be cast as a
regulator of a secondary market in addresses. Concerns
have been expressed that APNIC has no experience,
expertise nor the authority to enforce regulatory
actions. Such a role may also expose APNIC to additional
litigation.
Response:
This proposal does not advocate such a role for
APNIC. The scope of this policy is explicitly limited to
the conditions that would allow APNIC to recognise and
record a transfer of addresses in its registry.
There is a general belief that adoption of this policy
would act as an incentive for a market in
addresses. However, that does not imply that markets
would act outside existing regulatory structures. Nor
does it mean that market participants would be immune
from existing regulatory measures within their
respective regimes.
The potential for additional liabilities associated with
this policy should be the subject of legal review by an
appropriately qualified party.
6. Effect on APNIC members
----------------------------
APNIC members will have the ability to register the transfer of
IPv4 address resources between APNIC members.
7. Effect on NIRs
-------------------
This policy would allow NIRs to determine their own transfer
policies, and allow the transfer of resources between APNIC members
and the members of an NIR based on meeting the respective
eligibility criteria for the transfer.
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