Dear SIG members

A new version the proposal "prop-104: Clarifying demonstrated needs
requirement in IPv4 transfer policy" has been sent to the Policy SIG for
review.

Changes from previous version are:

     - Introduction was simplified to avoid misunderstanding.
     - Following text removed from "4.  Details" due to difficulties in
       implementation.

       "In case of Inter-RIR transfer, when there is a RIR which defines
        a period longer than 24 months in the future, the longer period
        adopted by the other RIR will be adopted."



Information about this version and earlier versions is available from:

           http://www.apnic.net/policy/proposals/prop-104

You are encouraged 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?

Regards,

Andy, Skeeve, and Masato


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prop-104-v002: Clarifying demonstrated needs requirement in IPv4
                 transfer policy

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


Authors: Shin SHIRAHATA
           <shin@clara.ad.jp>

           Norisuke HIRAI
           Akira NAKAGAWA


1.  Introduction
----------------

This proposal defines the period to be approved of IPv4 transfers for
recipients under demonstrated needs.


2.  Summary of the current problem
----------------------------------

The current APNIC transfer policy has a requirement for demonstrate a
need for transferred IPv4 addresses. The period of demonstrated needs
under the current operational practice is 12 months based on the
definition in Section 3.2, "Criteria for subsequent LIR delegations" in
the "Policies for IPv4 address space management in the Asia Pacific
region",

"Based on these factors, APNIC and NIRs will delegate address space to
meet the LIR's estimated needs for a period up to one year up to the
maximum allowed delegation under Section 3."

and this period was defined before the exhaustion.

On the other hand, ARIN allows transfers based on demonstrated needs up
to 24 months. This leads to difference in conditions of the transfer
between LIRs in the APNIC region and the ARIN region.

Furthermore, 12 months is also too short for transfers within the APNIC
region considering many xSPs plan their service and their addressing
requirements beyond one year.


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

ARIN has a requirement for the period to be approved of IPv4 transfers
for recipients under demonstrated needs, up to 24 months. LACNIC has a
policy that defines to evaluate for 12 months needs. RIPE NCC has 3
months requirement at this time, and the policy proposal that extend to
24 months, is under discussion.

AfriNIC:

AfriNIC currently does not have an IPv4 address transfers policy.


ARIN:

ARIN policy has a clear period for justification for IPv4 address
transfers, and the period is 24 months.

"Such transferred number resources may only be received under RSA by
organizations that are within the ARIN region and can demonstrate the
need for such resources in the amount which they can justify under
current ARIN policies showing how the addresses will be utilized within
24 months."

See Section 8.3, "Transfers to Specified Recipients" in the "ARIN Number
Resource Policy Manual":

      https://www.arin.net/policy/nrpm.html#eight3

This change was proposed by "DRAFT POLICY ARIN-2012-1: CLARIFYING
REQUIREMENTS FOR IPV4 TRANSFERS".

      https://www.arin.net/policy/proposals/2012_1.html


LACNIC:

LACNIC policy defines to evaluate for 12 months needs for the recipient
of the IPv4 address transfer. However, the transfer will only be
activate once LACNIC's address pool runs out. (expect for the reserved
space)

See Section 2.3.2.13, "Submission of Assignment Information" and Section
2.3.2.18.2, "Transfer of IPv4 Blocks within the LACNIC Region" in the
LACNIC Policy Manual (v1.9):

      http://lacnic.net/en/politicas/manual3.html


RIPE:

In the RIPE region, the period of needs approved for IPv4 address
transfers will be based on the definition of the current allocation
policy, which is 3 months.

Currently, there is no policy which defines the period of needs based
justification, specifically for IPv4 transfers, separate from allocation
criteria. See Section 5.0, "Policies and Guidelines for Allocations" in
the RIPE-553, "IPv4 Address Allocation and Assignment Policies for the
RIPE NCC Service Region:"

      http://www.ripe.net/ripe/docs/ripe-553/

However, there is a policy proposal under discussions which proposes to
extend the period of the demonstrated needs in case of IPv4 transfers,
up to 24 months. See 2012-03, "Intra-RIR Transfer Policy Proposal".

      http://www.ripe.net/ripe/policies/proposals/2012-03


4.  Details
-----------

This proposal clarifies the requirement on a period approved for the
transferred resource to recipients of IPv4 transfers based on the
demonstrated needs, and defines its period as "24 months".

This proposal does not intend to change the requirement for an address
allocation or assignment from APNIC.


5.  Pros/Cons
-------------

Advantages:

      - Extended period will allow the larger block size to match a
        longer term needs of the requester. It will help to reduce an
        IPv4 address block fragmentation caused by transfer.

      - APNIC member can apply for IPv4 address transfer as a receiver on
        the same condition of demonstrate a need in other RIR in case of
        Inter-RIR transfer. At this time, ARIN is the only RIR that
        adopts Inter-RIR policy in place other than APNIC. Thus, it
        places APNIC policy in line with ARIN on the transfer conditions.

      - It will allow the block size to more closely match the block size
        available for transfer from source.

      - It will reduce the risk of underground IPv4 address transfers,
        which do not get registered in APNIC database. There is a
        possibility that the recipients could not obtain justification
        for enough IPv4 address by the current period of demonstrated
        needs.

Disadvantages:

      - None

        There may be people who feel 24 months does not lead to efficient
        utilization compared to 12 months.

        However, the objective of needs based justification is not to
        "cut the size of address space to be transfered"; it is to ensure
        that the transfered space will be utilized in realities. 24
        months is a realistic period to estimate required address space
        for xSPs.


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

It will requires a recipients within the APNIC region must demonstrate
the need for up to a 24 months use of IPv4 address block.


7.  Effect on NIRs
------------------

It is the NIR's choice as to whether to adopt this policy.