Re: [sig-policy]Proposal prop-014-v001.txt - Lowering minimumallocation
Many thanks for the feedback and support on behalf of the ISPs in
Vietnam.
I will try to incorporate a summary of the comments below into my
presentation at the forthcoming APNIC meeting.
I hope to see you there.
Best wishes,
Anne
--
> Dear APNIC, NIRs and all,
>
> Through SIG and NIR mailing list, VNNIC already stated our community's
> viewpoint on the lowering minimum allocation size. As this proposal now
> officially be posted for the wide comments, we would like to say again our
> comments which is reflect demands and desires of Internet operation entities
> in Viet Nam:
>
> * We support this proposal of APNIC Secretariat.
> Up to now, there are 13 ISPs in Vietnam. Of these, only 6 strong ones had
> portable address allocation from APNIC. The remains use un-portable address
> space from 6 ISPs above. Most of these dependent ISPs now have been
> quatified to be initially allocated. They will request for portable
> allocation some day. However, along with this, they must renumber their
> network. It clearly is a disadvantage that present policy acts on them.
> According to the direction of Vietnamese Government on Telecommunications
> development, up to 2005, there would be 40 licensed ISPs. So lowering the
> size and losen the criteria of minimum allocation is desires of Internet
> Community in Viet Nam.
>
> * If we only losen the criteria but not reduce the minimum allocation
> size, we will waste addresses. According to APNIC's figure, more than half
> (51%) of all APNIC members have held a single allocation for longer than one
> year. We would like to emphasize that it is under present policy. Once we
> losen the criteria of obtaining initial allocation, the amount of similar
> entities will be significantly larger.
>
> * At last, we have a small suggestions: The proposal should tighten the
> criteria of portable assignment to get rid of unhonest PI. It should be "
> Portable assignment is only for end-user. ISPs are forced to apply for
> portable allocation".
>
> Best regards,
>
> Thu Thuy.
>
>
> ----- Original Message -----
> From: "Anne Lord" <anne at apnic dot net>
> To: <sig-policy at apnic dot net>
> Sent: Monday, January 19, 2004 9:41 AM
> Subject: [sig-policy]Proposal prop-014-v001.txt - Lowering minimum
> allocation size and criteria
>
>
>
> Dear colleagues,
>
> Attached below is a proposal for the upcoming APNIC Open Policy
> Meeting in KL, Malaysia. It is being circulated one month before
> the meeting to give time for feedback.
>
> The proposal can also be found at:
>
> http://www.apnic.net/docs/policy/proposals/prop-014-v001.html
>
> Your comments on this proposal are greatly appreciated and should
> be sent to this mailing list.
>
> Best wishes,
>
> Anne
>
> _____________________________________________________________________
>
> A proposal to lower the IPv4 minimum allocation size and initial
> allocation criteria in the Asia Pacific region [prop-014-v001.txt]
> _____________________________________________________________________
>
>
> Proposed by: APNIC Secretariat
> Version: draft 1.0
> Date: January 2004
>
>
> 1 Summary and motivation
> ------------------------
>
> For more than 10 years, the RIR system has applied initial allocation
> criteria and a minimum size for IPv4 address allocations to Local
> Internet Registries (LIRs). This is done to limit address space
> fragmentation and encourage aggregation and it ensures that only ISPs
> with sufficiently large address needs are able to receive portable
> address space.
>
> The size of the minimum allocation in the APNIC region has changed
> previously in response to concerns and the consensus of the community.
> In late 2000, the APNIC community approved a proposal to lower the
> minimum allocation from /19 to /20.
>
> In December 2001, the APNIC community approved new criteria for
> initial allocations. Those criteria are consistent with the /20
> minimum allocation and include (among others) a requirement to have
> used a /22 from an upstream provider and a plan to use a /21 within
> a year.
>
> Nevertheless, members of the APNIC community have expressed concern
> that the barrier to entry remains too high, preventing many smaller
> ISPs from obtaining portable address space.
>
> This document proposes lowering the minimum allocation size and
> initial allocation criteria, in the interests of fairness and equity
> of access to addresses.
>
> Further, many in the community have argued that the goal of
> aggregation has reduced in importance in recent years, due to
> developments in router technology and routing protocol. It is argued
> that it is now possible to sustain reasonable growth in the
> Internet's routing tables without performance or stability problems.
>
> Please note that the minimum allocation size and the initial
> allocation criteria affect only the first allocation made to an ISP.
> Changing either of these factors would have no impact on the size of
> subsequent allocations.
>
>
> 2 Background and problem
> ------------------------
>
> The APNIC Secretariat receives feedback from members and the wider AP
> community through channels including training events, the helpdesk
> and hostmaster services, and seminars and workshops. Consistently,
> small ISPs express concern at the difficulty of obtaining address
> space from APNIC under current policies.
>
> As noted above, under current policies, to be eligible for an initial
> /20 allocation, an ISP must (among other requirements):
>
> - have used a /22 from their upstream provider or demonstrate an
> immediate need for a /22;
>
> - demonstrate a detailed plan for use of a /21 within a year.
>
> This proposal adopts a quantitative approach to analyse the impact of
> the current policies by comparing the number of APNIC members (ISPs
> which have qualified to receive portable address space) with the
> number of ISPs actually operating in various economies of the region.
>
> The total number of APNIC members broken down by economy (excluding
> NIRs) is shown below. (Note that the totals here also include
> associate members and members who have received portable assignments).
>
> AU 195
> HK 110
> IN 104
> PH 48
> JP 44
> SG 44
> NZ 37
> PK 34
> TH 33
> MY 31
> CN 30
> AP 29
> BD 25
> TW 25
> Other 84
>
> The total number of ISPs operating in an economy can be obtained where
> a licensing or registration regime is in place, or where other survey
> data is available. The following countries were examined.
>
> India (104 APNIC members)
>
> Data for India obtained at http://www.dotindia.com/isp/ispindex.htm
> shows that for 39 A, B, and C licenses issued, 191 ISPs had started
> business as of August 2003[1]. APNIC has 104 members in India. It
> can be concluded that approximately half of the ISPs operating in
> India have not obtained portable address space allocations from
> APNIC.
>
>
> Hong Kong (110 APNIC members)
>
> At http://www.ofta.gov.hk/tele-lic/operator-licensees/opr-isp.html#s4
> it states that in Hong Kong, there were 216 licensed ISPs in August
> 2003 (there are many more ISPs which are not licensed). Of these, 110
> are APNIC members. Again approximately half of the ISPs in Hong Kong
> have not obtained portable address space allocations from APNIC.
>
>
> Australia (195 APNIC members)
>
> In Australia, 964 ISPs are registered with the Telecommunications
> Industry Ombudsman (http://www.tio.com.au/) and 195 of these are
> registered APNIC members.
>
>
> Indonesia (96 APJII members)
>
> According to information supplied by APJII, the NIR for Indonesia,
> there are two types of ISP licence in Indonesia: 'initial' and
> 'secondary' licences. Both are required before an ISP can operate.
> The 'secondary' licence requires portable address space from APNIC.
>
> According to the Department of Post and Telecommunications, 83 ISPs
> hold initial licences only. These ISPs do not have any portable
> address space. A further 96 ISPs are operating with both initial and
> secondary ISP licences. Therefore, just under half of Indonesian
> ISPs have not obtained portable allocations from APNIC.
>
>
> 3 Other RIRs
> ------------
>
> 3.1 RIPE NCC
>
> In the RIPE region, following consensus at RIPE 46, from 1 January
> 2004, the minimum allocation size was lowered from a /20 to a /21.
> Further, it is no longer necessary to demonstrate efficient
> utilisation of a /22 to request an initial allocation.
>
> The motivation for the proposal was that it was difficult or
> impossible for many start-up LIRs to get a PA allocation. As explained
> in the proposal:
>
> "..startup LIRs that do not already hold address space cannot get
> an initial PA allocation (which would be a /20 as of today, or
> bigger), because in many cases, they cannot demonstrate immediate
> need, or prior utilization of sufficient address space."
>
>
> 3.2 ARIN
>
> The ARIN community has made no change to the /20 minimum allocation
> size. However, at ARIN XII, there was consensus on changing the
> multihomed networks policy as follows:
>
> "Multi-homed organizations may justify and obtain a block of
> address space with prefix length extending to /22 directly from
> ARIN. When prefixes are longer than /20, these micro-allocations
> or micro-assignments will be from a reserved block for that
> purpose."
>
> Although there was no change to the minimum allocation size, the
> multihoming policy now allows smaller allocations to be made, to a
> minimum of /22.
>
> The ARIN community also reached consensus on allowing an exception for
> organisations located in the AFRINIC region, which now have a minimum
> allocation of /22.
>
>
> 3.3 LACNIC
>
> The minimum allocation size is a /20.
>
>
> 4 Discussion
> ------------
>
> 4.1 Lowering the minimum allocation size and initial allocation
> criteria
>
> A possible response to concerns about the barrier to entry for small
> ISPs is to lower the minimum allocation size and initial allocation
> criteria. The following discussion considers the effect of lowering
> the minimum allocation size from a /20 to a /21.
>
> Of a total of 734 current open APNIC members, 468 (63%) of those have
> received one allocation only. Further, of those 468 members, 378 have
> had their allocation for longer than one year. In other words, more
> than half (51%) of all APNIC members have held a single allocation for
> longer than one year, without returning to APNIC for additional
> address space.
>
>
> 4.2 Impact on routing tables
>
> Lowering the barrier to entry would have some impact on the size of
> the routing tables. The number of discrete allocations will be
> increased as more entities are able to receive portable prefixes.
> However, it is argued that the impact to the routing table will not be
> significant. The survey of ISP numbers in a number of economies in the
> region (see section 2 above) indicates that the total number of
> additional allocations at the /21 level would number in the hundreds,
> and the incremental impact on the global routing table, currently
> carrying some 130,000 entries, would be negligible.
>
> This conclusion is based upon data analysis of the 3 December 2003
> routing table report[2] which shows that /19 prefixes account for 6%
> of the global routing table, /20 prefixes account for 7%, whereas /24s
> account for almost 55%. Policy changes in recent years (in particular
> the move from a /19 to a /20) have not resulted in significant changes
> to this profile. The largest factor contributing to routing table
> growth remains the advertisement of /24 prefixes, either from legacy
> allocated space or from more specific prefixes of portable space.
>
>
> 4.3 Impact on conservation
>
> Recent research work[3] (which extrapolated allocation practices and
> demand, using an exponential growth model derived from the best of
> 2000-2003 data) concluded that RIRs could continue making IPv4
> allocations on the current basis for the next two decades.
>
> There are many factors that could affect this prediction. Changes in
> RIR allocation policies are one such factor. However, analysis
> suggests that this policy impact is not highly significant. For
> instance, global rates of RIR consumption have been: 4.47 /8s per year
> in 2000; 5.47 /8s per year in 2001; and 3.08 /8s per year in 2002.
> During this preiod the minimum allocation was changed from a /19 to a
> /20 in all regions.
>
> Based on this previous experience of the effect of policy change on
> address consumption, the current proposal is not expected to conflict
> with the RIR goal of conservation.
>
>
> 4.4 Impact on RIR operations
>
> A lower minimum allocation would require some changes to RIR
> hostmaster operations. Specifically, to be able to support contiguous
> allocations, hostmasters would need to reserve address space for a
> longer period. Currently, reservations are held for 12 months,
> extending to 15 months in some cases.
>
>
> 4.5 Impact to NIRs
>
> It is anticipated that the NIRs will conduct their Open Policy
> Meetings with a view to adopting a consistent minimum allocation size
> and allocation criteria.
>
>
> 5 Proposal
> ----------
> It is proposed that the current size of the minimum allocation should
> be lowered from a /20 to a /21. It is also proposed that the
> respective criteria for an initial allocation should be amended such
> that the LIR must:
>
> - have used a /23 from their upstream provider or demonstrate an
> immediate need for a /23; and
>
> - demonstrate a detailed plan for use of a /22 within a year;
>
> All other aspects of the policy would remain unchanged.
>
>
> 6 Implementation
> ----------------
>
> If consensus is reached, it is proposed to implement this policy three
> months after the policy has been approved by the APNIC Executive
> Council (EC).
>
>
> Notes and references
> --------------------
>
> 1 ISPs are not the only type of organisation who become APNIC members
> and receive allocations of portable address space.
>
> 2 The Routing Table report is archived at
> http://www.apnic.net/mailing-lists/bgp-stats/
>
> 3 IPv4 Address Lifetime Expectancy - 2003, Geoff Huston
> http://www.apnic.net/community/presentations/docs/ietf/200307/35
>
>
> --
>
> * sig-policy: APNIC SIG on resource management policy
> *
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