[sig-policy] prop-050-v002: IPv4 address transfers

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  • Subject: [sig-policy] prop-050-v002: IPv4 address transfers
  • From: Toshiyuki Hosaka <hosaka at nic dot ad dot jp>
  • Date: Tue, 22 Jan 2008 15:56:01 +0900
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      Version two of the proposal 'IPv4 address transfers' has been sent to
      the Policy SIG for review. It will be presented during the Policy SIG
      sessions at APNIC 25 in Taipei, Taiwan, 25-29 February 2008.
      The proposal's history can be found at:
      We invite you to review and comment on the proposal on the mailing list
      before the meeting.
      The comment period on the mailing list before an APNIC meeting is an
      important part of the policy development process. We encourage you to:
            - Ask the proposer questions if anything in the proposal is
            - Point out advantages and disadvantages you see in the proposal
            - State whether you support or oppose the proposal
      Mailing list discussions will be taken into account when the proposal
      is discussed at the upcoming APNIC meeting. So please make sure you have
      your say.
      APNIC Policy SIG Chairs
      Toshiyuki Hosaka
      Randy Bush
      Jian Zhang
      prop-050-v002: IPv4 address transfers
      Author:    Geoff Huston
                  gih at apnic dot net
      Version:   2
      Date:      22 January 2008
      1.  Introduction
      This is a proposal to remove APNIC policy restrictions on the transfer
      of registration of IPv4 address allocations and IPv4 portable address
      assignments between current APNIC account holders. This proposal is a
      refinement of the historical resource transfer policy and applies to
      IPv4 resources held by current APNIC account holders.
      2.  Summary of current problem
      Current APNIC policies relating to the registration of transfer of
      address holdings limit the eligibility of registration of transfers to
      those relating to mergers and acquisitions of entities that are
      administering an operational network.
      It is currently anticipated that the IPv4 unallocated address pool
      will be exhausted in a timeframe of between 2009 and 2011. There is a
      very considerable level of investment in IPv4-based services in the
      Asia Pacific region, and a transition to IPv6-based service delivery
      is likely to take longer than the remaining period of unallocated
      address availability. Accordingly, it is likely that demand for IPv4
      addresses will continue beyond the time of unallocated address pool
      exhaustion, leading to a period of movement of IPv4 address blocks
      between address holders to meet such continuing demand for IPv4
      address blocks.
      It is the objective of the APNIC IPv4 address registry to accurately
      record current address distribution information.
      This proposal allows APNIC to recognise the transfer of IPv4 addresses
      between current APNIC account holders, and places some constraints on
      the parties to the transfer as a precondition for the registration of
      the IPv4 address transfer to be undertaken by APNIC.
      3.   Situation in other RIRs
      It is the understanding of the proposer that no comparable IPv4
      resource transfer policy between account holders has been adopted in
      any other RIR.
      A proposal for address transfers similar to this proposal has been
      submitted to the RIPE community as a Policy Proposal:
           2007-08: Enabling Methods for Reallocation of IPv4 Resources
      4.   Details of the proposal
      APNIC will process IPv4 address transfer requests following the
      adoption of this proposed policy, subject to the following conditions:
      Conditions on the IPv4 address block:
           - Only IPv4 address blocks equal to, or larger than, a /24 prefix
             may be transferred.
           - The address block must be in the range of addresses administered
             by APNIC, either as part of a /8 address block assigned by the
             IANA to APNIC, or as part of a historically-assigned address
             block now administered by APNIC.
           - The address block must be allocated or assigned to a current
             APNIC account holder.
           - The address block will be subject to all current APNIC policies
             from the time of transfer. This includes address blocks
             previously considered to be "historical".
      Conditions on source of the transfer:
           - The source entity must be a current APNIC account holder.
           - 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.
           - The source entity will be ineligible to receive any further IPv4
             address allocations or assignments from APNIC for a period of 24
             months after the transfer.
           - In making any future IPv4 address resource requests to APNIC,
             for as long as IPv4 address resources are available from APNIC,
             following the expiration of this 24 month ineligibility
             period, the source will be required to document the reasons for
             the IPv4 address resource allocation.
      Conditions on recipient of the transfer:
           - The recipient entity must be a current APNIC account holder.
           - The recipient entity of the transferred resources will be
             subject to current APNIC policies. In particular, in any
             subsequent APNIC IPv4 address allocation request, the recipient
             will be required to account for all IPv4 address space held,
             including all transferred resources.
           - APNIC fees payable by the recipient will be assessed on the
             basis of all resources held.
      The address transfer process:
           After APNIC is notified of the transfer by both the source and the
           recipient of the transfer:
           1. APNIC will update the registration records relating to the
              transferred addresses.
           2. APNIC will adjust the source's address holdings as of the date
              of transfer.
              In terms of membership and/or service fee calculations this
              shall be processed in the same manner as a return of address
              holdings to APNIC as of that date.
           3. APNIC will adjust the recipient's address holdings to include
              the transferred addresses as of the date of the transfer.
              In terms of membership and/or service fee calculations this
              shall be processed in the same manner as an allocation or
              assignment of address holdings to the recipient as of that date.
              In order to preserve aggregation capabilities the transfer
              recipient may notify APNIC that the transferred address may be
              returned to the unallocated APNIC address pool, and a different
              address of the same size may be registered to the recipient of
              the transfer. This option would be available to the recipient of
              the transferred address, at the discretion of the recipient.
           4. The following transfer details will be published by APNIC in a
              public log of resource transfers:
              - Source
              - Recipient
              - Address resources
              - Date of transfer
      Transfer fees:
           APNIC may charge the recipient a service fee on the transfer
           transaction. The transfer service fee may vary according to the
           total size of the address block being transferred.
           The transfer fee schedule shall be set initially by the APNIC
           Executive Council upon adoption of this policy.  The transfer fee
           schedule will be included as part of any future review of APNIC
           fees and charges.
      5.   Advantages and disadvantages of the proposal
      This proposal would:
           - Ensure that the APNIC registry continues to reflect the current
             actual status of IPv4 resource holdings by APNIC account holders.
           - Mitigate the risks to the integrity of the network and its
             routing and addressing infrastructure associated with the
             unregistered transfers of IPv4 addresses. This proposal, by
             acknowledging the existence of address transfers and registering
             the outcomes would ensure that the APNIC address registry
             continues to maintain accurate data about resources and resource
             holders. The proposal also ensures that those parties who
             currently rely on the accuracy of this registration information
             can continue to rely on the currency and accuracy of this
             information in good faith.
           - Provide a stronger incentive for unused IPv4 address space to
             return to active use, helping to satisfy residual demand for IPv4
             address space across the IPv6 transition.
           - Concerns have been raised about a market-based system emerging
             as the only means to obtain IPv4 address space in future, and
             the potential for certain forms of market failures, including
             the possibility of hoarding, speculation and price manipulation.
             A number of factors mitigate these risks. As the transition to
             IPv6 gathers pace, a market-based value of IPv4 addresses would
             fall in line with the decreasing value proposition of IPv4-based
             services in an increasing IPv6 network. An additional constraint
             would apply if this policy were to be adopted while IPv4
             addresses are still available from APNIC, as APNIC's established
             IPv4 address allocation process would continue to provide an
             alternative source of supply of IPv4 addresses to the industry.
      6.   Effect on APNIC members
      APNIC members will have the ability to register the transfer of IPv4
      address resources between APNIC account holders.
      7.   Effect on NIRs
      This policy does not encompass IPv4 address holdings administered by
      NIRs, nor the transfer of resources where the source or recipient are
      NIR-serviced entities.
      (end of document)