sig-policy August 2009

sig-policy@lists.apnic.net

30 participants
38 discussions

Monthly List Reminder
by noreply＠apnic.net 31 Aug '09

31 Aug '09

Dear Subscriber, This is the monthly reminder of subscription information for the sig-policy list, hosted at APNIC. For subscription information including how to un-subscribe go to http://mailman.apnic.net/mailman/listinfo/sig-policy Thank you for participating in this discussion. Kind Regards, List administrator

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Final call for comments on prop-075: Ensuring efficient use of historical AS numbers
by Randy Bush 31 Aug '09

31 Aug '09

Dear colleagues This is the final call for comments on policy proposal prop-075, "Ensuring efficient use of historical AS numbers". This proposal was presented at APNIC 28 and was accepted by consensus. The proposal is now being submitted to the Policy SIG mailing list for an eight-week discussion period. At the end of that period, if consensus appears to have been achieved, the Policy SIG Chair will ask the Executive Council to endorse the proposal for implementation. * Send all comments and questions to: <sig-policy(a)apnic.net> * Deadline for comments: 26 October 2009 Proposal summary ---------------- This is a policy proposal to recover unused historical AS numbers for eventual reassignment to other APNIC account holders. Proposal details including the full text of the proposal, presentations, links to relevant meeting archives and links to mailing list discussions are available at: http://www.apnic.net/policy/proposals/prop-075 Regards Randy, Ching-Heng and Terence

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Final call for comments on prop-074: IANA Policy for allocation of ASN blocks to RIRs
by Randy Bush 31 Aug '09

31 Aug '09

Dear colleagues This is the final call for comments on policy proposal prop-074, "Internet Assigned Numbers Authority (IANA) policy for allocation of ASN Blocks (ASNs) to Regional Internet Registries". This proposal was presented at APNIC 28 and was accepted by consensus. The proposal is now being submitted to the Policy SIG mailing list for an eight-week discussion period. At the end of that period, if consensus appears to have been achieved, the Policy SIG Chair will ask the Executive Council to endorse the proposal for implementation. * Send all comments and questions to: <sig-policy(a)apnic.net> * Deadline for comments: 26 October 2009 Proposal summary ---------------- According to the current Global Policy for Allocation of ASN Blocks to Regional Internet Registries, IANA will cease to make any distinction between 16-bit and 32-bit only ASN blocks by 31 December 2009, when making allocations to RIRs. This proposal is to extend this date by one year, to 31 December 2010. Proposal details including the full text of the proposal, presentations, links to relevant meeting archives and links to mailing list discussions are available at: http://www.apnic.net/policy/proposals/prop-074 Regards Randy, Ching-Heng and Terence

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Final call for comments on prop-073: Simplifying allocation/assignment of IPv6
by Randy Bush 31 Aug '09

31 Aug '09

Dear colleagues This is the final call for comments on policy proposal prop-073, "Simplifying allocation/assignment of IPv6 to APNIC members with existing IPv4 addresses." This proposal was presented at APNIC 28 and was accepted by consensus. An updated version of the proposal that contained the clarifications suggested during APNIC 28 was sent to this mailing list during the Policy SIG on Thursday 27 August. The proposal is now being submitted to the Policy SIG mailing list for an eight-week discussion period. At the end of that period, if consensus appears to have been achieved, the Policy SIG Chair will ask the Executive Council to endorse the proposal for implementation. * Send all comments and questions to: <sig-policy(a)apnic.net> * Deadline for comments: 26 October 2009 Proposal summary ---------------- This is a proposal to simplify the criteria for a member requesting an initial block of IPv6 addresses where the member already has an IPv4 assignment or allocation. Proposal details including the full text of the proposal, presentations, links to relevant meeting archives and links to mailing list discussions are available at: http://www.apnic.net/policy/proposals/prop-073 Regards Randy, Ching-Heng and Terence

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Final call for comments on prop-050: IPv4 address transfers
by Randy Bush 31 Aug '09

31 Aug '09

Dear colleagues This is the final call for comments on policy proposal prop-050, "IPv4 address transfers". This proposal was presented at APNIC 28 and was accepted by consensus. The proposal is now being submitted to the Policy SIG mailing list for an eight-week discussion period. At the end of that period, if consensus appears to have been achieved, the Policy SIG Chair will ask the Executive Council to endorse the proposal for implementation. * Send all comments and questions to: <sig-policy(a)apnic.net> * Deadline for comments: 26 October 2009 Proposal summary ---------------- This is 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. Proposal details including the full text of the proposal, presentations, links to relevant meeting archives and links to mailing list discussions are available at: http://www.apnic.net/policy/proposals/prop-050 Regards Randy, Ching-Heng and Terence

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Report on APNIC 28 policy proposals
by Sam Dickinson 28 Aug '09

28 Aug '09

Dear SIG members Below is a summary report of the status of policy proposals following discussion at APNIC 28. The following proposals reached consensus: prop-050: IPv4 address transfers prop-073: Simplifying allocation/assignment of IPv6 to APNIC members with existing IPv4 addresses prop-074: Internet Assigned Numbers Authority (IANA) Policy for Allocation of ASN Blocks (ASNs) to Regional Internet Registries prop-075: Ensuring efficient use of historical AS numbers The following proposal was returned to mailing list for further discussion: prop-076: Requiring aggregation for IPv6 subsequent allocations The following proposals were returned to their authors for further consideration: prop-077: Proposal to supplement transfer policy of historical IPv4 addresses prop-078: Reserving /10 IPv4 address space to facilitate IPv6 deployment Next steps ---------- 1. Proposals that reached consensus will be returned to the Policy SIG mailing list for an eight-week comment period. 2. If no substantial objections are received during the final comment period, the proposals are deemed to have reached consensus at each stage of the policy development process. At this point, the SIG Chairs forward the proposals to the APNIC Executive Council (EC) for endorsement. 3. If the APNIC EC endorses the proposals, the APNIC Secretariat begins work on implementation of the proposals. Implementation usually takes a minimum of three months, but may take more depending on the implementation complexity. For more information on the proposals, please see: http://www.apnic.net/policy/proposals For more information on the APNIC policy development process, see: http://www.apnic.net/community/policy/process Regards -- _____________________________________________________________________ Samantha Dickinson email: sam(a)apnic.net Policy Development Manager, APNIC sip: sam(a)voip.apnic.net http://www.apnic.net phone: +61 7 3858 3100

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updated: prop-073
by Randy Bush 27 Aug '09

27 Aug '09

Dear SIG members Below is an updated version of the proposal that includes the elements of the transfer proposal that reached consensus in the APNIC 28 Policy SIG as well as a couple of administrative updates. The following changes have been made: - Section 4.2 in "Details of the proposal" has been replaced with the revised text that reached consensus during the APNIC 28 Policy SIG: 4.2 The size of the IPv6 delegation for members that meet the alternative criteria described in section 4.1 above will be based on the following: - A member that has an IPv4 allocation would be eligible for an IPv6 /32 - A member that has an IPv4 assignment would be eligible for an IPv6 /48 - The title of the proposal has been changed to reflect the change away from automatic allocation/assignment - Section 4.3 in "Details of the proposal" removes the reference to reservations. The proposal's history can be found at: http://www.apnic.net/policy/proposals/prop-073 The proposal will be presented to the APNIC Member Meeting tomorrow for consensus, and then will be followed by a formal eight-week final call for comments on this mailing list. Randy, Ching-Heng, and Terence ________________________________________________________________________ prop-073-v004: Simplifying allocation/assignment of IPv6 to APNIC members with existing IPv4 addresses ________________________________________________________________________ Simplifying allocation/assignment of IPv6 to APNIC members with existing IPv4 addresses Authors: Terry Manderson <terry(a)terrym.net> Andy Linton <asjl(a)lpnz.org> Version: 4 Date: 27 August 2009 1. Introduction ---------------- This is a proposal to simplify the criteria for a member requesting an initial block of IPv6 addresses where the member already has an IPv4 assignment or allocation. Under this proposal, APNIC would reserve the appropriately sized IPv6 block for each APNIC member that has IPv4 addresses but does not yet have IPv6 addresses. It is further proposed that members holding IPv4 addresses be able to request the IPv6 space reserved for them through a simple one-step process. 2. Summary of current problem ------------------------------ It is well understood that the final allocations of IPv4 address space are drawing very close. The community and APNIC Secretariat have done much to promote the adoption of IPv6. However, the authors recognize that the uptake of IPv6 is less than ideal. As a result, the community is looking for ways to promote the adoption of IPv6 so that it can be added to members' network infrastructure. The authors believe that the current APNIC processes recognize that an entity which has satisfied IPv4 criteria has done enough work to be assessed for IPv6 resources. This policy proposal aims to further promote IPv6 adoption by simplifying the process of applying to APNIC for IPv6 address space. 3. Situation in other RIRs --------------------------- RIPE: 2008-02,"Assigning IPv6 PA to Every LIR", a similar, but certainly not the same, proposal, was withdrawn by the author due to lack of support. There had been concern about the impact on member fees and that by issuing IPv6 addresses that hadn't been explicitly requested the proposal could make IPv6 a commodity. http://www.ripe.net/ripe/policies/proposals/2008-02.html ARIN: We understand that there have been discussions on this topic in the ARIN region but we have not identified a formal proposal. There have been no similar proposals in other regions. 4. Details of the proposal --------------------------- It is proposed that: 4.1 Alternative criteria be added to the IPv6 allocation and assignment policies to allow APNIC members that have IPv4 but no IPv6 space to qualify for an appropriately size IPv6 block under the matching IPv6 policy. 4.2 The size of the IPv6 delegation for members that meet the alternative criteria described in section 4.1 above will be based on the following: - A member that has an IPv4 allocation would be eligible for an IPv6 /32 - A member that has an IPv4 assignment would be eligible for an IPv6 /48 4.3 APNIC members can request the IPv6 address block be allocated/assigned to their member account via a simple mechanism in existing APNIC on-line systems. 4.4 The APNIC Secretariat may reserve prefixes for any or all qualifying members to allow for a seamless allocation process. It is a responsibility of the Secretariat to select an appropriate reservation schedule, and as such the reservation of a prefix is not fixed in size, scope, nor time. To increase visibility of this proposal, the authors recommend that the APNIC Secretariat communicate to members and others that the criteria for receiving an initial IPv6 block has been reduced and that the process of obtaining IPv6 address space has been made simpler. We recommend this to show that there is no effective barrier to members obtaining IPv6 addresses. Current IPv6 policies are still available for members who apply for IPv6 addresses without existing IPv4 addresses, or who apply for subsequent IPv6 resources. 5. Advantages and disadvantages of the proposal ------------------------------------------------ 5.1 Advantages This proposal: - Allows APNIC to engage with all IPv4 resource holders alerting them to the need to start work on deploying IPv6 addressing. - Pre-approves IPv6 resource delegations based on existing IPv4 holdings. - Increases member benefit by avoiding duplication and effort in applying to APNIC for IPv6 when they have already demonstrated their network needs for an IPv4 delegation. - Removes another barrier to IPv6 adoption by providing all eligible organisations with an IPv6 assignment or allocation through a simple request. 5.2 Disadvantages This proposal does not deal with the need to encourage holders of "Historic Internet resources" to apply for IPv6 address space. 6. Effect on APNIC members --------------------------- 6.1 Fees No member's fees will increase as a result of this proposal because under the APNIC fee schedule, assessed address fees are the greater of the IPv4 and IPv6 fees. This proposal was careful to ensure that IPv6 delegations would not increase a member's annual fees (based on the recently revised APNIC fee structure) 6.2 Responsibility A member would acquire the responsibility to manage and maintain a IPv6 allocation in the APNIC registry framework. 6.3 Address/Internet number resource consumption There are about 1300 current APNIC members that do not hold an IPv6 allocation. Allocating a /32 to each of these members would result in a maximum of /22 to /21 of IPv6 address space allocated if all 1300 members requested space. The actual allocation would be less than this as some members would receive a /48. 7. Effect on NIRs ------------------ The impact on any NIR would depend if the NIR adopts this proposal for their constituency.

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prop-076: Requiring aggregation for IPv6 subsequent allocations
by Randy Bush 27 Aug '09

27 Aug '09

Dear SIG members, The proposal, 'Requiring aggregation for IPv6 subsequent allocations', has been sent to the Policy SIG for review. It will be presented at the Policy SIG at APNIC 28 in Beijing, China, 25-28 August 2009. 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? Information about this and other policy proposals is available from: http://www.apnic.net/policy/proposals Randy, Jian and Ching-Heng ________________________________________________________________________ prop-076-v001: Requiring aggregation for IPv6 subsequent allocations ________________________________________________________________________ Authors: Tomohiro Fujisaki <fujisaki(a)syce.net> Akira Nakagawa Toshio Tachibana Fuminori Tanizaki Version: 1 Date: 29 July 2009 1. Introduction ---------------- This is a proposal to make it a condition that LIRs aggregate subsequent IPv6 allocations that they receive from APNIC. 2. Summary of the current problem ---------------------------------- The initial IPv6 address allocation criteria requires that LIRs: "Plan to provide IPv6 connectivity to organizations to which it will make assignments, by advertising that connectivity through its single aggregated address allocation."[1] However, there is no similar aggregation requirement in the criteria for subsequent allocations. For consistency, the routing requirement should be applied also in subsequent allocation criteria. 3. Situation in other RIRs --------------------------- LACNIC: The LACNIC community is currently discussing the following proposal to remove the requirement to announce an initial allocation as a single prefix in favour of announcing the prefix with the minimum possible level of disaggregation: 2007-01: Modifications to the IPv6 Prefix Initial Allocation Policy http://www.lacnic.net/documentos/politicas/LAC-2007-01v3-propuesta-en.pdf RIPE: The RIPE community is currently discussing the following proposal to remove routing requirements from IPv6 policy: 2009-06: Removing Routing Requirements from the IPv6 Address Allocation Policy http://www.ripe.net/ripe/policies/proposals/2009-06.html AfriNIC and ARIN initial IPv6 allocation criteria require a plan to aggregate, with no requirement for aggregation for subsequent allocation criteria. Neither RIR is has any proposal to modify these criteria. 4. Details ----------- This is a proposal to add the requirement under the subsequent IPv6 allocation criteria to aggregate subsequent IPv6 allocations as a single prefix. 5. Pros/Cons ------------- 5.1 Advantages: - By describing clearly in the policy as a requirement, it may contribute to limiting routing expansion of the global IPv6 routing table in the future. 5.2 Disadvantages: - This proposal may just be a nonbinding requirement. - APNIC policy may be more strict than other regions if other RIR communities decided to remove aggregation requirement from their policy. 6. Effect on APNIC members --------------------------- APNIC members will be required to aggregate subsequent allocations as a single prefix. 7. Effect on NIRs ------------------ Same as above. 8. References -------------- [1] See section 5.2.1, "IPv6 Address Allocation and Assignment Policy" http://www.apnic.net/ipv6-address-policy#5.2.1

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prop-073-v003: Automatic allocation/assignment of IPv6
by Randy Bush 27 Aug '09

27 Aug '09

Dear SIG members Version 3 of the proposal "Automatic allocation/assignment of IPv6" has been sent to the Policy SIG for review. It will be presented at the Policy SIG at APNIC 28 in Beijing, China, 25-28 August 2009. More about the proposal can be found at: http://www.apnic.net/community/policy/proposals This new version of the proposal reflects feedback from the community received on the Policy SIG mailing list: - Section 4.2 of version 2 has been removed in this third version and the subsequent sections renumbered accordingly. - Section 4.3 from version 2 (now section 4.2) has been amended to reflect the removal of section 4.2 from version 2. - A new section 4.4 has been added to suggest that it is at the APNIC Secretariat's discretion to reserve IPv6 blocks under this proposal. We encourage you to express your views on the proposal: - Do you support or oppose 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, Jian and Ching-Heng ________________________________________________________________________ prop-073-v003: Automatic allocation/assignment of IPv6 ________________________________________________________________________ Authors: Terry Manderson <terry(a)terrym.net> Andy Linton <asjl(a)lpnz.org> Version: 3 Date: 19 August 2009 1. Introduction ---------------- This is a proposal to simplify the criteria for a member requesting an initial block of IPv6 addresses where the member already has an IPv4 assignment or allocation. Under this proposal, APNIC would reserve the appropriately sized IPv6 block for each APNIC member that has IPv4 addresses but does not yet have IPv6 addresses. It is further proposed that members holding IPv4 addresses be able to request the IPv6 space reserved for them through a simple one-step process. 2. Summary of current problem ------------------------------ It is well understood that the final allocations of IPv4 address space are drawing very close. The community and APNIC Secretariat have done much to promote the adoption of IPv6. However, the authors recognize that the uptake of IPv6 is less than ideal. As a result, the community is looking for ways to promote the adoption of IPv6 so that it can be added to members' network infrastructure. The authors believe that the current APNIC processes recognize that an entity which has satisfied IPv4 criteria has done enough work to be assessed for IPv6 resources. This policy proposal aims to further promote IPv6 adoption by simplifying the process of applying to APNIC for IPv6 address space. 3. Situation in other RIRs --------------------------- RIPE: 2008-02,"Assigning IPv6 PA to Every LIR", a similar, but certainly not the same, proposal, was withdrawn by the author due to lack of support. There had been concern about the impact on member fees and that by issuing IPv6 addresses that hadn't been explicitly requested the proposal could make IPv6 a commodity. http://www.ripe.net/ripe/policies/proposals/2008-02.html ARIN: We understand that there have been discussions on this topic in the ARIN region but we have not identified a formal proposal. There have been no similar proposals in other regions. 4. Details of the proposal --------------------------- It is proposed that: 4.1 Alternative criteria be added to the IPv6 allocation and assignment policies to allow APNIC members that have IPv4 but no IPv6 space to qualify for an appropriately size IPv6 block under the matching IPv6 policy. 4.2 The size of the IPv6 delegation for members that meet the alternative criteria described in section 4.1 above will be based on the following: - A member that has an IPv4 allocation would be eligible for an IPv6 /32 - A member that has received an IPv4 assignment under the multihoming policy would be eligible for an IPv6 /48 - A member that has received an IPv4 assignment under the IXP or Critical Infrastructure policies would be eligible for an IPv6 /48 4.3 APNIC members can request the reserved IPv6 address block be allocated/assigned to their member account via a simple mechanism in existing APNIC on-line systems. 4.4 The APNIC Secretariat may reserve prefixes for any or all qualifying members to allow for a seamless allocation process. It is a responsibility of the Secretariat to select an appropriate reservation schedule, and as such the reservation of a prefix is not fixed in size, scope, nor time. To increase visibility of this proposal, the authors recommend that the APNIC Secretariat communicate to members and others that the criteria for receiving IPv6 space has been reduced and that the process of obtaining IPv6 address space has been made simpler. We recommend this to show that there is no effective barrier to members obtaining IPv6 addresses. Current IPv6 policies are still available for members who apply for IPv6 addresses without existing IPv4 addresses, or who apply for subsequent IPv6 resources. 5. Advantages and disadvantages of the proposal ------------------------------------------------ 5.1 Advantages This proposal: - Allows APNIC to engage with all IPv4 resource holders alerting them to the need to start work on deploying IPv6 addressing. - Pre-approves IPv6 resource delegations based on existing IPv4 holdings. - Increases member benefit by avoiding duplication and effort in applying to APNIC for IPv6 when they have already demonstrated their network needs for an IPv4 delegation. - Removes another barrier to IPv6 adoption by providing all eligible organizations with an IPv6 assignment or allocation through a simple request. 5.2 Disadvantages This proposal does not deal with the need to encourage holders of "Historic Internet resources" to apply for IPv6 address space. 6. Effect on APNIC members --------------------------- 6.1 Fees No member's fees will increase as a result of this proposal because under the APNIC fee schedule, assessed address fees are the greater of the IPv4 and IPv6 fees. This proposal was careful to ensure that IPv6 delegations would not increase a member's annual fees (based on the recently revised APNIC fee structure) 6.2 Responsibility A member would acquire the responsibility to manage and maintain a IPv6 allocation in the APNIC registry framework. 6.3 Address/Internet number resource consumption There are about 1300 current APNIC members that do not hold an IPv6 allocation. Allocating a /32 to each of these members would result in a maximum of /22 to /21 of IPv6 address space allocated if all 1300 members requested space. The actual allocation would be less than this as some members would receive a /48. 7. Effect on NIRs ------------------ The impact on any NIR would depend if the NIR adopts this proposal for their constituency.

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prop-050: IPv4 address transfers
by Randy Bush 26 Aug '09

26 Aug '09

Dear SIG members, The proposal, 'IPv4 address transfers', has been sent to the Policy SIG for review. It will be presented at the Policy SIG at APNIC 28 in Beijing, China, 25-28 August 2009. The proposal's history can be found at: http://www.apnic.net/policy/proposals/prop-050 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, Jian, and Ching-Heng ________________________________________________________________________ prop-050-v005: IPv4 address transfers ________________________________________________________________________ Authors: Geoff Huston gih(a)apnic.net Philip Smith pfs(a)cisco.com Version: 5 Date: 24 July 2009 This proposal contains the transfer proposal features that reflect the points of general agreement demonstrated on the APNIC Policy SIG mailing list in the period May - July 2009. 1. Introduction ---------------- This is a proposal to amend APNIC policy restrictions on the transfer of registration of IPv4 address allocations and IPv4 portable address assignments between current APNIC account holders. This proposal does not propose to refine the existing APNIC historical resource transfer policy, as it is intended to apply 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 2011 and 2012. 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. The underlying proposition behind this policy proposal is that the registry of IPv4 addresses operated by APNIC is of general utility and value only while it accurately describes the current state of address distribution. If a class of address movement transactions are excluded from being entered in the registry, then the registry will have decreasing value to the broader community, and the integrity of the network itself is thereby compromised. This proposal's central aim is to ensure the continuing utility and value of the APNIC address registry by allowing the registry to record transactions where IPv4 addresses are transfered between APNIC account holders. It proposes that APNIC will recognise and register a transfer of addresses where the parties to the transfer are 'known' to APNIC and that the address block being transferred is part of APNIC's current (non-historical) address set The proposal does not prescribe how such transfers may occur, nor impose any further constraints on the transfer or on the parties involved other than those described in this proposal. 3. Situation in other RIRs ---------------------------- RIPE has implemented a transfer policy in its region. See section 5.5, "Transfers of Allocations", of: IPv4 Address Allocation and Assignment Policies for the RIPE NCC Service Region http://www.ripe.net/ripe/docs/ripe-449.html#55 On 1 June 2009, ARIN implemented: 2009-1: Transfer Policy https://www.arin.net/policy/proposals/2009_1.html LACNIC is currently discussing a transfer proposal: LAC-2009-04 Transfer of IPv4 Blocks within the LACNIC Region http://www.lacnic.net/documentos/politicas/LAC-2009-04-propuesta-en.pdf AfriNIC currently has no similar policy or proposal under discussion. 4. Details of the proposal ---------------------------- APNIC will process and record IPv4 address transfer requests between current APNIC account holders following the adoption of this proposed policy, subject to the following conditions. APNIC will maintain a public log of all transfers made under this policy. Conditions on the IPv4 address block: - The minimum transfer size is a /24 - The address block must be in the range of addresses 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. 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 12 months after the transfer, or until the exhaustion of APNIC's IPv4 space (i.e. until the commencement of the use of the "final /8" resources), whichever occurs first. - Under exceptional circumstances a member may submit an application for further assignments or allocations earlier than the expiration of this period. The APNIC Secretariat will monitor these exceptional requests carefully and publish comprehensive statistics on a regular basis. Without identifying any member organization, these statistics will record the numbers of requests and the outcome, the economy that the requests come from and clearly identify if any member has made more than one request under this provision. 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 the efficient utilization of all IPv4 address space held, including all transferred resources. - 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. Applicability to NIRs: - NIRs have the choice as to when to adopt this policy for their members (i.e. members of NIRs) Implementation: - This proposal is to take effect as soon as the APNIC Secretariat implement the mechanisms of the policy following the completion of all steps of the Policy Development Process. 5. Advantages and disadvantages of the proposal ------------------------------------------------- 5.1 Advantages This proposal: - Ensures that the APNIC registry continues to reflect the current actual status of IPv4 resource holdings by APNIC account holders. - Mitigates the risks to the integrity of the network, and its routing and addressing infrastructure in particular, associated with the unregistered transfers of IPv4 addresses. - Provides 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 reuse 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 reclamation 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. 5.3 Summary of comments on transfer proposals There are a number of views of this that have been noted in the various policy discussions on this topic in the various RIR policy forums. The APNIC policy proposal is broadly similar to a policy proposal under consideration in RIPE, which is referred to here as a "minimal' policy for address transfers. The address transfer proposal currently under consideration in ARIN has a larger set of constraints to be applied to determine if a transfer would be recognised by the registry. A summary of the discussion of the differences in these policy proposals follows. 5.3.1 In favor of a 'minimal' policy - The policy places APNIC in the role of a 'title office' for addresses, and ensures that APNIC, as a registry operator, is neutral in terms of the means used by APNIC members to determine that they wish to proceed with a transfer of addresses. As long as the criteria for a valid transfer are met, by whatever means agreed to by the parties involved, then the registry should allow the transaction to be duly recorded. - APNIC has no practical operational experience in the area of enforcing various constraints on parties as to how and why addresses may be transferred, and does not currently have any recognized authority to do so. Making policy in the absence of a well understood and commonly accepted authority model calls into question the legitimacy and authority of outcome. - Regulation is a well understood and familiar concept in many, if not all, regimes. If there is a general desire to place constraint and regulate the actions of parties who wish to undertake a transfer of addresses, then it may be preferred to do so in the context of a broader framework that involves other bodies and authorities that have a greater level of experience and authority in this area of activity, and leverage from existing regulatory structures and enforcement mechanisms. In this manner the policy proposal does not attempt to create a novel, and potentially superfluous additional regulatory framework. - APNIC has no experience in determining what actions by potential parties to a transfer may need to be constrained in some fashion. Attempting to create policy in anticipation of the need for such constraints is going to be a guessing game that has accompanying flaws, Irrespective of what constraints are initially specified in policy, it will be the case that as the levels of experience in this form of activity increases some iterations over the policy of constraints will be necessary in any case. This approach argues to start from a position that is relatively open and unrestricted, and recommend that APNIC impose additional constraints only when all other forms of constraint are inapplicable and there is a clear need and common desire for such constraints to be enforced by APNIC as distinct from using another party for such a role. 5.3.2 In favour of applying a greater level on constraint in the policy - APNIC has no practical operational experience in address transfers, so we should take incremental steps form the current position rather than a complete relaxation of the entire set of constraints associated with the existing allocation framework. Recipients of a transfer should be qualified by the registry on the basis of demonstrated need in the same fashion as recipient of address allocations today. Address blocks should not be arbitrarily fragmented. Timing constraints should be applied to stop transfers of addresses occurring that are primarily motivated by reasons other than immediate need for use in deployed networks. - Constraints that are generally considered to be onerous and unnecessary can always be removed at a later date, while applying and enforcing additional constraints at a later date will prove to be a far harder task. - There are a number of technical risks associated with address trading. Unconstrained deaggregation will lead to a fracture of the routing system due to unconstrained and large scale expansion of the inter-domain routing table. This is an irreversible state. 5.3.3 Discussions of the emergence of a market The various comments made on this and the related address transfer policy proposals provides grounds for the observation that there is a general perception that the recognition of address transfers leads to a de facto recognition of the emergence of a market or markets for IPv4 addresses. A related topic of discussion about the merits or otherwise of these proposals has been the consideration of the relative merits and risks of market behaviours when applied to this situation. The comments opposed to the emergence of markets include the following: - Markets in addresses are an inevitable consequence of a transfer policy, and unconstrained markets are prone to a number of risks of distortion. These risks include deceptive trading, margin trading, trading in market derivatives and futures, hoarding, and speculation. The utility of an address as a token for addressing a packet is devalued in a market situation. - Operation of a market will lock out all but the largest of players in the network from access to further addresses, as the value of the address will be set by the bidder with the highest price and the ability to exploit the address to its maximal extent. - The operation of a market in IPv4 addresses will lead to the erosion of the effectiveness of self-imposed policies in IPv6, and may lead to the emergence of a market in IPv6 addresses. - Markets are unfair in terms of the implicit bias of a market in favour of those parties who are in a position to set the market price, and inherently discriminating against those parties who do not have the capacity to pay. In an international context this is counter to the general objective of a generally available, neutral and non-discriminatory communications infrastructure. Comments in favour of the emergence of a market in IPv4 addresses include: - Address exhaustion poses an insoluble problem to the address registries in that for as long as there is a continuing demand for addresses the registries have no means to meet that demand. Markets create a means for addresses to be recycled, and create a means for the various levels of demand and supply of addresses in IPv4 to reach a balance through a market-based pricing mechanism. - At every stage there is always an alternative to bidding for IPv4 addresses in the context of a market transaction: namely the use of IPv6 within the network, and the use of an upstream protocol translation service to provide legacy access to other IPv4 networks. Given that substitutes exist, the potential price of IPv4 addresses in a market is capped by the cost of deployment of IPv6 and IPv4 transitional mechanisms. - This is a temporary measure during the dual stack phase of IPv6 transition. The higher the market price for IPv4 addresses the greater the cost pressure placed on the industry to undertake the IPv6 transition, which in turn limits the lifetime of the market and the speculative potential of any such market. Players will have an incentive to act quickly in terms of releasing address resources into such a market given that withholding for too long will result in no return as the market will naturally terminate once IPv6 transition has reached a critical deployment mass. This address transfer policy proposal is mute on the topic of a market for address transfers, and neither advocates nor specifically opposes the emergence of any such market or markets. The policy constrains itself to enumeration of the set of constraints that would apply for APNIC to recognize and register a transfer of addresses between APNIC members. How those parties arrived at the decision to undertake the transfer, and the related issues concerning property, financial and legal frameworks and the emergence of markets, the need to regulate such markets and identification of the market regulator are specifically not encompassed by this policy proposal, nor does this proposal advocate that such a role be undertaken by APNIC. 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 ------------------- As APNIC account holders, NIRs will have the ability to register transfers of addresses with other APNIC account holders upon adoption of this proposal. The proposal allows for NIRs to have the choice as to when to adopt this policy for their members. Members of NIRs will have the ability to register transfers of addresses when individual NIRs implement this transfer policy.

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sig-policy August 2009