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Re: [sig-policy] Address Transfer Policy Proposal
Thank you for your response to the request for comments and feedback
on the transfer policy proposal.
- transfer proposal applies to all address holdings as held by
current
members of APNIC
Does that imply that historical holdings by in-region non-members
(glibly assuming such a thing exists) cannot be transferred to
current member? or do you simply mean that a recipient has to be a
member of APNIC? (or subordinate NIR should they adopt?)
I may need some assistance form the Secretariat here is terms of the
correct phrase, but as I understand the current situation there are:
A: addresses held by current financial members of APNIC,
B: addresses held by non-members of APNIC who pay APNIC a non-member
service fee associated with the address holding, and
C: there are "historical" address resources which are listed in the
APNIC databases and the listed holder is not a financial member and
the address is not the subject of an annual maintenance fee
My intent was to say that addresses in categories A and B are
"current" addresses and may be transferred, and category C addresses
are not eligible to be transferred. In the later case the entity
concerned can become a member or reestablish a relationship with APNIC
and pay an annual maintenance fee and then the addresses are eligible
for transfer.
The reason why I felt that this was appropriate is that addresses in
category C may, or may not, have a clear and current record of the
current holder of the address resource and the process of making the
addresses current within APNIC's existing processes uses a set of
procedures that call on the holder to demonstrate their continuing
association with the addresses - it was hoped that this would improve,
to some extent, the integrity of transfer transactions in so far as
the intent was that transfer transactions would be registered when
both parties were "known" to APNIC, and APNIC would avoid becoming a
party to possibly fraudulent transfer transactions.
For NIRs, similar considerations would apply, I assume.
If there are better ways to phrase this in terms of a policy statement
I would appreciate assistance in terms of appropriate terminology.
Perhaps some advice from the Policy folk in the Secretariat?
- NIRs have the choice as to when to adopt this policy for their
members
(i.e. members of NIRs)
That is definitely "when" not "if", yeah??
Given that there is no time constraint stated here then the intent was
to allow an NIR the choice of adopting this policy or not.
I would assume that the NIR communities would be aware that that the
short term industry needs following the exhaustion of the unallocated
IPv4 pools would imply that such a policy has greater benefit in terms
of ensuring continuing accuracy and relevance of the registry system
and in continuing some level of distribution of addresses if such a
policy was adopted earlier rather than later, but I understand that
the NIRs were desirous of having the ability to adopt such a policy
within timing parameters as determined by their national community.
- when a member disposes of address space using this transfer
policy the
member should not be entitled to any further IPv4 allocations or
assigments from APNIC for an extended period (two years?)
or until the final /8 is reached.
My intent with this two year period constraint was to cover a number
of possible eventualities, including APNIC performing subsequent
allocations from returned address space even after after the final /8
has been invoked.
- prior to the exhaustion of APNIC's IPv4 space (i.e. prior to the
use
of the "final /8" allocation measures) recipients of transfers
will be
required to justify their need for address space. After this time
there
is no requirement for any form of evaluation of requirements for
eligibility.
Except APNIC membership ;)
Yes, I had hoped that this was clear in the text you have quoted. The
intent was that this particular constraint of meeting a needs-based
evaluation would have a time limit as determined by the introduction
final /8 , but that other constraints (such as the constraint that the
addressers are in the name of a current member) would still hold.
If you have any other issues that you feel would assist this policy
gaining a suitable degree of general consensus in this community,
please
let us know, either directly to us, or via this mailing list.
I think the crux behind this is about acknowledging the issue that
v4 is running out, and transfers are a simple mechanism to allow
those who no longer require their allocation to redistribute it to
organisations who can use it while maintaining the integrity of the
titles database.
What I'd also like to see is some wording to strongly suggest that
recipients need to be able to provide a v6 deployment plan, and if
appropriate the acquired v4 allocation automatically comes with a v6
allocation directly from APNIC (or NIR) if the recipient
organisation doesn't already have a v6 allocation. A suggestion/
recommendation like that should not be ceased by the final /8.
Thank you for this suggestion.
Do others feel similarly? And, conversely, are there other who are of
the opinion that this is perhaps a imposing too onerous a constraint
on the registration of a transfer transaction?
I'd like to point out that the reason why such a constraint, and why
other similar conditions or constraints were not included into the
original address transfer policy proposal was that it is my personal
view that the registry system has remarkably little enforcement
mechanism when the associated allocation function has concluded. The
way I have phrased this in the past is that if the constraints on
registration of an address transfer in APNIC's registry was too
onerous, then the most likely outcome is that other forms of
registration would appear and that the risk of creating unwanted and
dangerous chaos in address uniqueness would be considerably greater. I
felt that there needed to be a balance between ensuring that the
registry was able to continue to operate in a manner that was
accessible and free of onerous constraints and imposing a number of
somewhat extraneous constraints and conditions that are superfluous to
the basic registry function.
I wrote up some thoughts on this topic at http://www.potaroo.net/ispcol/2008-11/transfers.html
that you may find useful in thinking about the various issues that
may be at play here.
If there is a broad feeling from this community that such additional
constraints and conditions relating to the disclosure to APNIC of some
form of IPv6 deployment plan should accompany a registration transfer
request, then that certainly can be added to the proposal.
regards,
Geoff
Disclaimer: The above reflects only my personal views in the context
of the Policy SIG's activity in considering an address transfer policy
proposal.
