Good evening. 

I do not support this proposal in its current form for the following reasons. 

1) *There is no clearly defined problem accepted by the community*
The author provides no proof that there is a current problem, instead choosing to speculate that there may seem to be a problem. 

I would need to see solid proof that the suggested situation was infant happening before I would support any policy proposing so solve such a problem. 

2) *The proposal gives no firm policy details.*  Instead offering two options. If it is not clear which option would provide a clear solution to a demonstrated problem then this policy needs much more discussion before being considered at the policy sig. 

3). I need to be convinced that The Huston-Bush law of "It's all gone, get over it!" doesn't apply here. Do we really care about the last little dregs?  Let people gather them. It's crumbs anyway. 

I am happy to discuss this issue, but as I have highlighted before, bringing up new issues at the 11th hour as drafted policy is not in my opinion the way to gain community consensus. 

So. 
Convince me that there is a problem (with proof), choose a single solution to fix it and convince me that these dregs are worth fighting over. Then you'll have my support. 

Dean

On Thursday, January 31, 2013, Andy Linton wrote:
Dear SIG Members

The proposal "prop-106-v001: Restricting excessive IPv4 address
transfers under the final /8 block' has been sent to the Policy SIG for review.

It will be discussed at the Policy SIG at APNIC 35 in Singapore,
Thursday 28 February 2013.

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 proposal is available from:

            https://www.apnic.net/policy/proposals/prop-106

Andy, Skeeve, Masato





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

prop-106-v001: Restricting excessive IPv4 address transfers under the
               final /8 block

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


Authors:    Shin SHIRAHATA shin@clara.ad.jp
            Tomohiro Fujisaki fujisaki@syce.net



1. Introduction
---------------

This policy proposes to restricting IPv4 address transfers which
were allocated/assigned from the final /8 block.

Based on our observations of the APNIC transfer history records,
some LIRs seems to collect IPv4 address blocks under the final /8
range by using multiple accounts, and transfer these blocks to
a single account. We believe this kind of behaviors are against
the spirit of the final /8 policy.


2. Summary
----------

The current APNIC IPv4 address transfer policy allows to obtain
a maximum of /22 distribution(s) per each APNIC account holder.

We propose add a restriction to IPv4 address transfer policy to
restricting excessive IPv4 address transfers under the final /8
block.


3. Situation in other RIRs
--------------------------

No similar policy at other RIRs.


4. Details
----------

There are options to handle this problem.

Option 1: Restrict IPv4 address transfers under the final /8 address
          block for two years.

    - Prohibits transfers of the address block for two years after
      receiving the distribution under the final /8 address block.


Option 2: Set a deposit for transfers under the final /8 range.

    - Pay ten years of APNIC's annual fees for transfered address
      block in advance when receiving the final /8 address range
      by address transfer or account name change.

      If an APNIC account holder transfers the final /8 range, the
      rights associated with the advanced payment of the annual fees
      will get dissolved, and the transfer recipient must pay the
      annual fees just the same as regular APNIC account holders.


5. Pros/Cons
------------

Advantages:

    - Restricting the last /8 address range to concentrate on a
      particular account holder

    - Matches with the spirit of the final /8 policy


Disadvantages:

    - The changes may increase an incentive of underground transfers.


6. Effect on APNIC
------------------

Transfers from the final /8 address range will be restricted in
principle


7. Effect on NIRs
-----------------

NIRs need to adopt this policy.
*              sig-policy:  APNIC SIG on resource management policy           *
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--
Regards,

Dean