[sig-policy][prop-014-v001] FINAL CALL FOR COMMENTS

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  • Date: Mon, 08 Mar 2004 16:34:55 +1000
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      Final call for comments: [prop-014-v001]
      "Proposal to lower the IPv4 minimum allocation size
      and initial allocation criteria"
      ____________________

      This is the final call for comments on policy proposal [prop-014-v001]
      "Proposal to lower the IPv4 minimum allocation size and initial
      allocation criteria"

      This proposal was presented at APNIC 17 and consensus was
      reached :

      "to reduce the minimum initial allocation size to /21 and
      to lower the criteria for an initial allocation to demonstrate
      an immediate need for a /23 and use of a /22 within one year"

      This proposal is now submitted to the sig-policy mailing list for an
      eight week discussion period. At the end of that period, if consensus
      appears to have been achieved, the Chair of the Policy SIG will
      ask the Executive Council to endorse the proposal for implementation.

      * Send all comments and questions to: <sig-policy at apnic dot net>
      * Deadline for comments: 3 May 2004


      _____________________________________________________________________

      A proposal to lower the IPv4 minimum allocation size and initial
      allocation criteria in the Asia Pacific region
      _____________________________________________________________________


      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


      ______________________________________________________________________

      APNIC Secretariat <secretariat at apnic dot net>
      Asia Pacific Network Information Centre (APNIC) Tel: +61-7-3858-3100
      PO Box 2131 Milton, QLD 4064 Australia Fax: +61-7-3858-3199
      Level 1, 33 Park Road, Milton, QLD http://www.apnic.net
      ______________________________________________________________________