*_Clarifications in response to comments received from various
members on proposal Prop-100 submitted to APNIC_*
*2.*From the various comments received from APNIC community members,
it appears that there is a need to provide further clarifications to
proposal prop-100, which are summed up as below -
Everyone is aware of the fact that IPv6 is in the initial stages of
deployment and therefore, this is the right time for taking steps
which were missed in the IPv4 era. There are 2 very important
aspects in the Internet address space, which are also some of the
most important address management objectives in APNIC policy and
needs to be considered –
a.*Conservation - *The IPv4 address space was 32-bit only, but due
to bulk allotments to the early users and insufficient planning for
future allocations, the free addresses were exhausted fast.
India, which has a very fast growing ICT user base, mostly among the
mobile users, did not get enough IPv4 addresses. We are having only
34 million IPv4 addresses for a telecom subscriber base of around
850 million in which there are about 360 million data users. India
has recently rolled out 3G services and deployment of LTE services
in future is already on the drawing boards of major operators. Every
ICT user in INDIA, down the line in near future will be using IP
technology in his day to day life. Because of paucity of IPv4
addresses, India has decided to adopt IPv6 in a big way and so we
have already released a National IPv6 Policy in July 2010.
Even though the IPv6 address space is 128 bits, which is considered
almost infinite, the address space has to be conserved with proper
and adequate planning for sufficient time period and considering the
requirements of different economies in APNIC region. Therefore, the
existing need based policy, putting emphasis on immediate needs
only, required to be redefined in the IPv6 era and the policy should
now address long term needs of the organizations and users of
different economies.
*b.**Aggregation – *It is agreed that the advantage of aggregation
of the**address space would largely depend on the organizations
individual routing policy and hence not entirely eliminate the
fragmentation issue but would definitely reduce the issue since
larger aggregated address spaces could be announced .This objective
in APNIC policy can be addressed by allocation of large contiguous
blocks to organizations seeking IPv6 addresses for present and
future needs. Since the current policy is a need-based policy, where
IP addresses are allocated on the basis of immediate need, there are
certain concerns in this approach –**
**
*i.*Even though organizations can fairly predict their IP address
need for the immediate future, they go back to APNIC only when they
actually need it, because they don’t want to pay and block their
money for a resource, which they will need a few years down the
line. They go mostly by commercial considerations which is very
natural for them. This may not have been considered in APNIC Policy
. However, if a big block is allocated to a country on behalf of its
different organizations, the country will take care of further
allocations to the different organizations in a planned manner
considering all facts for sufficient time period. This will not only
meet the technical requirement of aggregation but also meet the
needs of different stakeholders. **
ii.Additionally the aggregated country level address procurement
would also have the cost benefit which can further be passed on to
the organizations and help bring their Capex down.
*3.*The larger internet population of the country like the
Government, Service providers, Organizations based in India and the
billion populations from India would use IP addresses from blocks
given to Indian organizations. There will also be call centres,
BPOs, multinational companies etc. having offices in India using the
IP addresses allocated by other RIRs who will also be benefitted
because now they will also have an option to get contiguous address
blocks for operations in India. Therefore, a large contiguous block
will help to increase routing efficiency to some extent.
*4.*APNIC has already approved the proposal of India for setting up
a “National Internet Registry” within the country. This NIR will
take some time to establish and operate. Further, NIR will also
receive large blocks of addresses from APNIC (maybe in one tranche
or multiple tranches) for further distribution to different
organizations in India. Once the NIR is setup, the address planning
and management can be done by the NIR. Since India is a large
country of nearly 1.2 billion citizens, already having about 850
million telecom users with 360 million data users, and upcoming 3G
and LTE networks.Additionally each of these users would require
multiple IP addresses for the triple play services and applications.
Hence at least a /16 address block will be required.
*5.*Therefore, the proposal prop-100, which has been submitted to
APNIC, on behalf of different organizations in our country, seeks to
address these issues to ensure that whatever addresses are allocated
by APNIC (and subsequently by the upcoming NIR) are from one single
large block and not from different blocks. This will not only ensure
network optimization but also adequate and contiguous address space
availability for different organizations/stakeholders in a planned
manner in future and with cost benefits to the end users.
*6.*With this, it is hoped that most of the general queries
regarding the proposal are clarified.
Sd/-
R M AGARWAL
Deputy Director General (Networks & Technologies),
Department of Telecommunications, Government of India
Room no. 1104, Sanchar Bhawan
20, Ashoka Road, New Delhi – 110001
India
Mob: +91- 9868133440
Off no. +91 11 23372606
------------------------------------------------------------------------
Due to corporate changes to my email address, my original list of
objections did not make it through to the mailing list. Subsequent
postings by other members summed up my objections more broadly, thus I
chose not to re-post them. However, even with these clarifications, I
remain opposed to the proposal.
--
Randy.