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

  • To: APNIC Secretariat <secretariat at apnic dot net>
  • Subject: Re: [sig-policy][prop-014-v001] FINAL CALL FOR COMMENTS
  • From: Jeff Williams <jwkckid1 at ix dot netcom dot com>
  • Date: Mon, 08 Mar 2004 01:05:47 -0800
  • Cc: sig-policy at apnic dot net
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    • 
      Again....
      
      It is not factual that a consensus was reached on this policy
      proposal, namely "prop-014-v001".  So claiming such repeatedly
      in no way makes it so.
      
        So I would again ask kindly that honesty be the stalwart in
      such policy making processes...
      
      APNIC Secretariat wrote:
      
      > ____________________
      >
      > 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
      > ______________________________________________________________________
      >
      > *              sig-policy:  APNIC SIG on resource management policy           *
      > _______________________________________________
      > sig-policy mailing list
      > sig-policy at lists dot apnic dot net
      > http://mailman.apnic.net/mailman/listinfo/sig-policy
      
      Regards,
      
      --
      Jeffrey A. Williams
      Spokesman for INEGroup LLA. - (Over 134k members/stakeholders strong!)
      "Be precise in the use of words and expect precision from others" -
          Pierre Abelard
      
      "If the probability be called P; the injury, L; and the burden, B;
      liability depends upon whether B is less than L multiplied by
      P: i.e., whether B is less than PL."
      United States v. Carroll Towing  (159 F.2d 169 [2d Cir. 1947]
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