Hi Sunny, all,
As discussed today, the public log change was
not intended, however, it seems to make sense to keep that
text in order to ensure that the public log is for all the
transfers. Doesn't make any sense to “hide” some of them
from the log.
Just in case, the community doesn’t agree with
that, we can make a two consensus calls, one for the
unification of all the transfer policies, and another one to
make the log for all the transfers or only for the ones as
per current section 8.1/8.2.
This way, we don’t need a new version and
unless the community strongly disagree, the log will be
extended to all the transfers, as it should be.
We shall notice that the lack of that
“complete” log, was probably not intended by the authors of
the other transfer policies and having it is part of the
expected transparency of all RIRs operations.
So, it will be good if anyone disagree or find
any reasons this log should not include all the transfers,
to state it ASAP.
Tks!
Regards,
Jordi
@jordipalet
Dear SIG
members,
Here is the Secretariat impact assessment for prop-142-v001.
APNIC understands this proposal is suggesting combining the
individual resource type (IPv4, IPv6, ASN) transfer policies
under a new part (Part 5) of the APNIC's Internet Number
Resource Policies document.
APNIC
also notes that this proposal is NOT intending to amend the
current transfer policies. However, currently APNIC maintains
a public log of intra and inter-RIR IPv4 transfers only made
under Sections 8.1 and 8.2. The proposed policy is suggesting
changing this to maintain a public log of all resource
transfers "APNIC will maintain a public log of all transfers."
Clarification:
Should
APNIC maintain a public log of all resource type (IPv4, IPv6,
ASN) transfers, including historical IP addresses and
scenarios due to merger, acquisition, or takeover?
Recommendation:
In
the spirit of this proposal, for reasons of consistency and no
changes to the current transfer policies, we recommend the
proposal authors and the community to trust the Secretariat to
do the right thing in combining all relevant transfers
policies under a new Part (Part 5 of the Policy document),
without relying on the proposed text in the proposal.
Implementation:
This
proposal would not require any changes to the systems.
If this proposal reaches consensus, implementation can be
completed within 3 months.
Regards,
Sunny and Odagi
Policy Support
On 2/02/2022
1:17 pm, chku wrote:
Dear SIG
members,
The proposal "prop-142: Unify Transfer Policies Text" has
been sent to
the Policy SIG for review.
It will be presented at the Open Policy Meeting (OPM) at
APNIC 53 on
Wednesday, 02 March 2022.
https://conference.apnic.net/53/program/schedule-conference/#/day/10
We invite you to review and comment on the proposal on the
mailing list
before the OPM.
The comment period on the mailing list before the OPM is an
important
part of the Policy Development Process (PDP). 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 appended below as well as
available at:
http://www.apnic.net/policy/proposals/prop-142
Regards,
Bertrand, Shaila, and Ching-Heng
APNIC Policy SIG Chairs
---------------------------------------------------------------
prop-142-v001: Unify Transfer Policies Text
----------------------------------------------------------------
Proposer: Jordi Palet Martínez (jordi.palet@theipv6company.com)
Amrita Choudhury (amritachoudhury@ccaoi.in)
1. Problem statement
--------------------
Presently the transfer policies have been listed separately
for different type of number resources.
Sections 8.0 to 8.4 of the policy manual contains the text
for IPv4 transfers (including Historical
Resources), section 11.0 is equivalent for IPv6 transfers
(only M&A). and section 13.0 to 13.3, provide
equivalent text for ASN transfers.
As a result, there is duplication of text in different parts
of the manual, which clearly make the
reading and interpretation more complex.
2. Objective of policy change
-----------------------------
The objective of this proposed change is to ensure there is
a single coordinated section for all kind
of transfers, reduce the duplication of pieces of text and
make it easier for people to access the
relevant information.
While this change can be done by the secretariat as an
editorial change, but seems that they prefer
to ensure that the community confirms their acceptance.
The proposal IS NOT intended to change the existing
transfers policies, so only minor re-wording/re-phrasing
is being done in order to shorten the text, avoid
duplicities and making it easier to read and interpret.
3. Situation in other regions
-----------------------------
Different RIRs have unified the text, but the policy manual
in others is separate documents for each policy
so that’s not feasible.
4. Proposed policy solution
---------------------------
Replace actual Policy sections with:
Part 5: Resource Transfers
APNIC recognizes that there are situations where resources
(IPv4, IPv6, ASN) may need to be transferred.
APNIC does not recognize any transfer outside this policy
and require organizations holding such transfers
to return them to the appropriate IR.
The Resource Transfer policies ensure that all transfers are
accurately reflected in the APNIC Whois Database.
This ensures the integrity of the network and an accurate
description of the current state of address distribution.
APNIC will maintain a public log of all transfers.
In the case of IPv4, addresses delegated from the 103/8 free
pool cannot be transferred for a minimum of five
years after the original delegation. During that time, if
the reason for the original request is no longer
valid, the resources must be returned to APNIC as required
in Section 4.0. Resource License.
11.0. Intra/Inter-RIR Transfers
APNIC will process and record IPv4 and ASN Intra-RIR
(between current APNIC account holders) and Inter-RIR
Transfers (between current APNIC account holders and
organizations in other RIR regions).
In the case of Inter-RIR transfers, APNIC will process and
record transfers only when the counterpart RIR
has a reciprocal policy.
11.1. Conditions on the Resources to be transferred
The resource must be:
• Under the management of the RIR at which the transfer
source holds an account and the authentic
holder of the space should match with the source without any
disputes.
• Delegated to a current RIR account holder.
• If the recipient is an APNIC account holder, will be
subject to all current APNIC policies from the time of
transfer.
• In the case of IPv4 resources, the minimum transfer size
is a /24.
11.1.1. Historical IPv4 Resources
Transfers of Historical IPv4 resources as defined in Section
2.5.2 can optionally follow this policy.
In that case, the transfer will be recognized and registered
by APNIC.
APNIC does not require any technical review or approval of
the resource’s current use to approve the
transfer. In addition, APNIC does not review any agreements
between the parties to a transfer and
does not exert any control over the type of agreement
between the parties.
If the historical Internet resources are not held under a
current APNIC account, the recipient entity
must verify they are the legitimate holder of the Internet
resources.
For more information on transferring historical Internet
resources, please see the transfer page of the APNIC
website.
https://www.apnic.net/transfer
11.2. Conditions on the Source of the transfer
The conditions on the source of the transfer will be defined
by the RIR where the source organization
holds an account. This means:
• For transfers from an APNIC source, the source entity must
be the currently registered holder
of the IPv4 address resources, and not be involved in any
dispute as to the status of those resources.
• Where the source is in another region, the conditions on
the source as defined in the counterpart RIR’s
transfer policy at the time of the transfer will apply.
11.3. Conditions on the Recipient of the transfer
The conditions on the recipient of the transfer will be
defined by the RIR where the recipient organization
holds an account. This means:
• For transfers to an APNIC recipient, the entity will be
subject to current APNIC policies.
o For IPv4 transfers:
- Recipients that do not already hold IPv4 resources must
demonstrate a detailed plan for the use of
the transferred resource within 24 months.
- Recipients that already hold IPv4 resources must:
- Demonstrate a detailed plan for the use of the transferred
resource within 24 months,
- Show past usage rate, and
- Provide evidence of compliance with APNIC policies with
respect to past delegations.
• For ASN transfers the recipient entity must meet the
criteria for the assignment of an ASN
• Where the recipient is in another region, the conditions
on the recipient as defined in the counterpart
RIR’s transfer policy at the time of the transfer will
apply.
12. Mergers & acquisitions
APNIC will process and record the transfer of IPv4, IPv6 and
ASN resources as the result of merger or acquisition.
12.1. Updating registration details
If an organization changes ownership (due to a merger, sale,
or takeover), then the new entity must register any
changes to its network usage and contact personnel with
APNIC. If the effect of the ownership change is that the
name changes, then the organization must provide relevant
legal documentation to APNIC supporting the changes.
12.2. Effect on membership agreement
If an organization changes ownership then the new entity
should update APNIC of the change. APNIC membership is
not transferable from one entity to another; however, if the
effect of the ownership change is that the organization
becomes a subsidiary of another entity, and the
infrastructures of the respective entities remain fully
independent,
then the membership agreement may continue.
12.3. Consequences for delegations
Following a change in ownership, APNIC will review the
status of any delegations that are held by the new entity or
entities, with regard to the practical effect on their
infrastructures.
If the practical effect of ownership change is that the
infrastructures are merged, then APNIC will not continue to
make separate allocations to both. This situation will
invalidate the membership agreement of the organization that
is effectively subsumed.
When assessing the status of delegations, APNIC requires
full disclosure of all address space held by all of the
entities in question. If full disclosure is not made, then
APNIC will consider any delegations to be invalid and
will require that they be returned.
5. Advantages / Disadvantages
-----------------------------
Advantages:
It creates a unified transfer policy section that is concise
(by shortening the text by almost half) and easy to access.
Disadvantages:
None.
6. Impact on resource holders
-----------------------------
None.
7. References
-------------
Nil.
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