[apnic-talk] Address Policy SIG paper

  • To: apnic-talk at lists dot apnic dot net
  • Subject: [apnic-talk] Address Policy SIG paper
  • From: Anne Lord <anne at apnic dot net>
  • Date: Tue, 26 Sep 2000 16:05:50 +1000 (EST)
  • Sender: owner-apnic-talk@lists.apnic.net
      Attached below is a draft paper on "The future of ISP confederations
      - a proposal to permanently suspend the formation of new ISP 
      This paper is being circulated in preparation for the upcoming
      Address Policy SIG at the APNIC meeting. This paper will shortly be 
      available on the APNIC meeting web site, along with all other meeting
      documents at:
      Comments and discussion on this list are very welcome.
      Manager, Member Services
      Problem definition
      The future of ISP confederations - a proposal to permanently suspend 
      the formation of new ISP confederations
      This proposal in this paper is twofold. First, that new procedures are 
      applied to the management framework for existing ISP confederations; and 
      second, that no new ISP confederations be created (in other words, this 
      paper proposes that the suspension of new confederations memberships should 
      be extended indefinitely for ISP confederations).
      1. Background
      The ISP confederation structure arose in response to the globalisation of 
      ISP networks through mergers and acquisitions - where an ISP network may 
      span many countries. The resulting very large ISPs demonstrated a need to 
      maintain independent network address allocation pools, and they were 
      allowed to do this through the adoption of confederation memberships (which 
      were originally designed to serve National NICs, now known as NIRs). ISP 
      confederations have operated along the same administrative lines as NIR 
      confederations, even though the specific characteristics of the NIR and ISP 
      confederations are actually very different.
      Multiple independent allocations within a single APNIC membership are not 
      ordinarily permitted due to significant additional administrative 
      complexity which they impose. Normal APNIC members are therefore required 
      to manage their allocated address space as a single pool, and only request 
      more addresses when 80% of their allocation has been consumed. If 
      independent allocations are required, the organisation is now advised to 
      take out multiple memberships, which clearly delineates the separate 
      2. Motivation
      In practice, the current ISP confederation framework does not consistently 
      apply APNIC policies across the APNIC membership, resulting in a lack of 
      accountability by the ISP confederations. Moreover there are also different 
      implementations of the model across the ISP confederation membership which 
      significantly increase the complexity of management.
      In December 1998 the APNIC Executive Council supported the decision to 
      suspend the formation of any new confederations. Almost two years has 
      elapsed from the time of that decision and APNIC is now seeking feedback 
      from the community on a specific proposal to resolve this issue.
      Note: At the time of the EC decision, the term 'confederation' applied both 
      to the National Internet Registries (organisations that serve the ISP 
      community within a particular country), and to ISP Confederations (whose 
      'membership' is defined by the structure of the ISP itself). This document 
      is concerned only with the case of the ISP confederations.
      3. Current status (including other RIRs)
      The following summary analysis compares the procedural framework applied to 
      ordinary LIR APNIC members and members of ISP confederations and highlights 
      the significant differences.
      Other RIRs (RIPE NCC and ARIN) have no confederation category within their 
      membership structures, so their policies are not detailed here.
      3.1 ISP Address Request Form
      Each direct LIR APNIC member must complete an 'ISP Address Request' form 
      (APNIC-065) in detail when requesting an address allocation. This is 
      evaluated carefully by the APNIC hostmasters.
      Under the current model for ISP confederations, the head office of the 
      confederation is intended to assume the role of the registry, similar to 
      that of APNIC. However there is no formal requirement for the confederation 
      members to complete APNIC-065 when requesting address space, and moreover 
      infrastructure descriptions are not required on the current APNIC 
      Confederation request form. As a result infrastructure requirements go 
      largely undocumented throughout the entire allocation process.
      3.2 Assignment and Allocation Windows
      APNIC applies an 'assignment window' mechanism and second-opinion process 
      to LIR members, in order to objectively measure the understanding and 
      application of assignment policies and procedures by the member. For new 
      members the assignment window starts at zero (and therefore applies to all 
      customer assignments), and it is increased progressively as experience is 
      APNIC is also currently developing a corresponding "allocation window" 
      mechanism by which NIR allocations to NIR members may also be subject to 
      second-opinion approval by APNIC. This has been agreed by all NIR members, 
      and is being progressively introduced.
      The ISP confederation model today does not involve a second-opinion process 
      of any kind, which allows no objective measure or verification of policy 
      adherance by the confederation. In any case this process by its nature 
      assumes that the requestor is independent from the registry, and that the 
      registry is neutral and impartial. Neither is the case for ISP confederations.
      3.3 Establishing new memberships
      ISP confederations are currently able to establish new memberships as they 
      please, and with each membership the ability to create an additional 
      independently managed address pool.
      New memberships of the ISP confederations should be established under the 
      same criteria as those applied to APNIC LIR members.
      3.4 Initial allocations to members
      Initial allocations to new members should be consistent with policies 
      decided by the APNIC community. APNIC applies the 'slow start' policy 
      whereby new members receive the minimum practical allocation. Currently 
      this is a /20.
      4. Discussion
      APNIC is currently discussing the above policy issues with ISP 
      confederation members, with a view to implementing changes. However, there 
      are currently five ISP confederations, each with different topological 
      considerations, which make the consistent and equitable application of 
      policies and procedures a complex management task.
      While the ISP confederation model allows each ISP confederation to obtain 
      independent address allocations for each member, this can also be easily 
      achieved by establishing separate memberships with APNIC.
      5. Recommendations
      APNIC recommends that the ISP confederation membership category be 
      suspended, but that the existing ISP confederations be given the choice to 
      either convert to multiple memberships or to remain as they are.
      If they choose to remain as ISP confederations, they will be asked to work 
      with APNIC to modify their procedures to implement the assignment and 
      allocation window systems with the objective of ensuring a more consistent 
      and fair application of APNIC policies. This will be done on a case by case 
      basis, but with an eventual aim to bring all confederations into line with 
      a consistent policy framework.
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