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Re: [sig-policy] Last Call for Comments on prop-050: IPv4 address transfers




On 8/03/2009, at 08:54 , Scott Leibrand wrote:

I believe all of these issues are very serious, so I oppose this latest
revision of prop-050 until they can be addressed.  Normally I refrain
from comment on other RIRs' policies, but I believe this policy, if
adopted as written, has the potential for serious negative effects
outside of the APNIC region.

-Scott

James Spenceley wrote:

For those of you not there to understand how we ended up with this
proposal, in the last 10 minutes the Chair decided that it was better
to have *any* policy rather than a policy with any form group
consideration, so we randomly removed parts of the proposal to the
point where (even the english speakers) were confused as to what the
actual policy was.

So yes we now have a policy that has significant risk to the IANA Free Pool, APNIC revenues and the entire concept of justified allocation of
IP resources.

I think you both misunderstand the ability of our excellent hostmasters at APNIC to apply existing policy to this situation. The document "Policies for IPv4 address space management in the Asia Pacific region" (http://www.apnic.net/policy/add-manage-policy.html) contains the following clauses:

---
5.1.4	Conservation

To maximize the lifetime of the available resource, address space must be distributed according to actual need and for immediate use. Stockpiling address space and maintaining reservations are contrary to this goal. Conservation also implies efficiency. Therefore, all users of address space should adopt techniques such as Variable Length Subnet Masking (VLSM) and appropriate technologies that ensure the address space is not used wastefully.

5.2	Conflict of goals
The goals of conservation and aggregation often conflict with each other. Also, some or all of the goals may occasionally conflict with the interests of individual IRs or end-users. Therefore, IRs evaluating requests for address space must carefully analyse all relevant considerations and try to balance the needs of the requestor with the needs of the Internet community as a whole.

6.11	Documentation
To properly evaluate requests, IRs must carefully examine all relevant documentation relating to the networks in question. This documentation may include:

	• network engineering plans;
	• subnetting plans;
	• descriptions of network topology;
	• descriptions of network routing plans;
	• equipment invoices and purchase orders;
	• other relevant documents.
All documentation should conform to a consistent standard and any estimates and predictions that are documented must be realistic and justifiable.

---

If I were in the role of hostmaster and found myself dealing with a request from an entity that had transferred a block of addresses to someone else and then came to APNIC with two years for more, I would have no hesitation in rejecting the request quoting:

Section 5.1.4 - stockpiling.

Section 5.2 - request does not balance the needs of the requestor vs the needs of the Internet community as a whole.

Section 6 - documentation does not demonstrate predictions that are realistic with the public log of transfers introduced in the new policy as part of the evidence.

Having said all that I think it would be more useful to let this proposal go forward and introduce a new proposal to be discussed at the next meeting which deals with the issues which gained consensus on an individual basis and then strangely failed to be accepted in the final decision.