Dear Tomohiro,
Thanks for reviewing your policy proposal prop-116. I have some questions would like to have your clarifications.
4. Proposed policy solution
---------------------------
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.
Questions:
Some of the statements in Advantages/Disadvantages and Impact sessions appear to be outdated by the change to a two-year limit.
Best regards,
Guangliang Pan (Benny)
Registration Services Manager, APNIC
Email: gpan@apnic.net
SIP: gpan@voip.apnic.net
Phone: +61 7 3858 3188
http://www.apnic.net
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From: sig-policy-bounces@lists.apnic.net [mailto:sig-policy-bounces@lists.apnic.net]
On Behalf Of Sumon Ahmed Sabir
Sent: Sunday, 29 January 2017 9:39 PM
To: sig-policy@apnic.net
Subject: [sig-policy] Revised prop-116-v003: Prohibit to transfer IPv4 addresses in the final /8 block
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
-------------