Regards

Mike

Dear SIG members

A new version of the proposal "prop-116: Prohibit to transfer IPv4
addresses in the final /8 block" has been sent to the Policy SIG for
review.

Information about earlier versions is available from:

http://www.apnic.net/policy/proposals/prop-116

You are encouraged to express your views on the proposal:

  - Do you support or oppose the proposal?
  - Is there anything in the proposal that is not clear?
  - What changes could be made to this proposal to make it more effective?

Please find the text of the proposal below.

Kind Regards,

Masato and Sumon






-------------------------------------------------------

prop-116-v003: Prohibit to transfer IPv4 addresses in the final /8 block

-------------------------------------------------------

Proposer:       Tomohiro Fujisaki
                fujisaki@syce.net


1. Problem statement
--------------------

There are a lot of transfers of IPv4 address blocks from 103/8
happening, both within the APNIC region and among RIRs.

Then number of transfer from 103/8 block are about 200, which is
about 12% of the total number of transfers. This looks so high
since APNIC manages about 40/8.

And based on the information provided by APNIC secretariat, number
of transfers from the 103/8 block are increasing year by year.

Updated by APNIC Secretariat on 27 January 2017:

1) M&A transfers containing 103/8 space

+------+-----------+-----------+-
|      |   Total   | Number of |
| Year | Transfers |   /24s    |
+------+-----------+-----------+-
| 2011 |         3 |         12 |
| 2012 |        10 |         46 |
| 2013 |        18 |         66 |
| 2014 |       126 |        498 |
| 2015 |       147 |        573 |
| 2016 |        63 |        239 |
+------+-----------+------------+-

2) Market transfers containing 103/8 space

+------+-----------+-----------+
|      |   Total   | Number of |
| Year | Transfers |   /24s    |
+------+-----------+-----------+
| 2011 |         2 |         2 |
| 2012 |        21 |        68 |
| 2013 |        16 |        61 |
| 2014 |        25 |        95 |
| 2015 |        67 |       266 |
| 2016 |       103 |       394 |
+------+-----------+-----------+

And also, transfers from the 103/8 block include:
  - Take place within 1 year of distribution, or
  - Multiple blocks to a single organization in case of beyond 1 year.

Further, there is a case where a single organization have received 12
blocks transfers from 103 range.

see:  https://www.apnic.net/transfer-resources/transfer-logs

From these figures, it is quite likely that substantial number of 103/8
blocks are being used for transfer purpose.

This conflicts with the concept of distribution of 103/8 block
(prop-062), which is intended to accommodate minimum IPv4 address blocks
for new comers.

°°prop-062: Use of final /8
°°https://www.apnic.net/policy/proposals/prop-062


2. Objective of policy change
-----------------------------

When stated problem is solved, distribution from 103/8 block will be
consistent with its original purpose, for distribution for new entrants
to the industry. Without the policy change, substantial portion of 103/8
blocks will be consumed for transfer purpose.


3. Situation in other regions
-----------------------------

None.


4. Proposed policy solution
---------------------------

Prohibit transfer IPv4 addresses under /8 address block (103/8) which
have not passed two years after its allocation/assignment.
If the address block allocated to a LIR in two years is not needed any
more, it must return to APNIC to allocate to another organization
using final /8 policy.

In the case of transfers due to M&A, merged organization can have
up to /22 IPv4 address in the 103/8 block in principle. If there
are technical reasons such as all address is used in separate networks
and announced from multiple ASes, merged organization can keep them.
Otherwise, the 103/8 IPv4 address more than /22 must return to APNIC
to allocate to another organization using final /8 policy.


5. Advantages / Disadvantages
-----------------------------

Advantages:
  - It makes 103/8 blocks available according to the original purpose,
    as distribution for new entrants (rather than being consumed for
    transfer purpose)

  - IPv4 addresses under final /8 are not transferred to outside APNIC.

  - By prohibiting transfer them, it is possible to keep one /22 for
    each LIRs state, which is fair for all LIRs.

Disadvantages:

None.


6. Impact on resource holders
------------------------------

  - LIRs cannot transfer address blocks under 103/8. No big impact while
    they use it.

  - Organizations which needs to receive transferred IPv4 can continue
    to do so, outside 103/8 blocks (which should be made available for
    new entrants)


7. References
-------------