[sig-policy] prop-068-v001: Inter-RIR transfer policy

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  • Subject: [sig-policy] prop-068-v001: Inter-RIR transfer policy
  • From: Randy Bush <randy at psg dot com>
  • Date: Fri, 16 Jan 2009 12:33:35 +0900
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    • Dear SIG members
      
      The policy proposal 'Inter-RIR transfer policy' has been sent to
      the Policy SIG for review. It will be presented at the Policy SIG
      at APNIC 27 in Manila, Philippines, 23-27 February 2009. The
      proposal's history can be found at:
      
            http://www.apnic.net/policy/proposals/prop-068-v001.html
      
      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 express your views on the proposal:
      
           - Do you support or oppose this proposal?
           - Does this proposal solve a problem you are experiencing? If
             so, tell the community about your situation.
           - Do you see any disadvantages in this proposal?
           - Is there anything in the proposal that is not clear?
           - What changes could be made to this proposal to make it more
             effective?
      
      randy and jian
      
      _______________________________________________________________________
      
      prop-068-v001: Inter-RIR transfer policy
      ________________________________________________________________________
      
      Author:    Geoff Huston
                  gih at apnic dot net
      
      Version:   1
      
      Date:      16 January 2009
      
      1.  Introduction
      ----------------
      
      This is a proposal to allow the recognition and recording of
      address transfers between APNIC and other RIRs and between APNIC
      and NIRs.
      
      2.  Summary of current problem
      ------------------------------
      
      prop-050, "IPv4 address transfers", proposes that APNIC recognise
      the transfer of IPv4 address resources between APNIC
      members. However, it does not address the following situations:
      
           - A transfer between an APNIC member and a member of another
             RIR
           - A transfer between an APNIC member and a member of an
             APNIC-recognised NIR
      
      3.   Situation in other RIRs
      ----------------------------
      
      No similar policy proposals have been adoped in other RIRs.
      
      4.   Details of the proposal
      ----------------------------
      
      APNIC will recognise and register a transfer of IPv4 addresses in
      the following cases:
      
      4.1 Transfer from APNIC member to another RIR or NIR member
      
           The following constraints apply to the disposer of the IPv4
           address disposer (the "source entity"):
      
               - 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.
      
           The following constraints apply to IPv4 address block being
           transferred:
      
               - 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.
      
           APNIC will require the details of the receiving entity of the
           transfer, and will confirm that the receiving entity and the
           IPv4 address block meets the eligibility criteria established
           by the RIR or NIR nominated by the receiving entity prior to
           approval of registration of the transfer.
      
           The transfer process:
      
               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. The following transfer details will be published by
                  APNIC in a public log of resource transfers:
      
                      - Source
                      - Recipient
                      - Recipient RIR or NIR
                      - Address resources
                      - Date of transfer
      
           Transfer fees:
      
           APNIC may charge the source entity 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.
      
      4.2 Transfer from member of another RIR or NIR to APNIC member
      
           The following constraints apply to the recipient of the IPv4
           address disposer (the "recipient entity"):
      
               - 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 following constraints apply to IPv4 address block being
           transferred:
      
               - Only IPv4 address blocks equal to, or larger than, a /24
                 prefix may be transferred.
      
           APNIC will require the details of the source entity of the
           transfer, and will confirm that the source entity and the IPv4
           address block meets the eligibility criteria established by
           the RIR or NIR that holds the address registration prior to
           approval of registration of the transfer.
      
           The transfer process:
      
               1. APNIC will update the registration records relating to
                  the transferred addresses.
      
               2. 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.
      
                  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, and subject to availablility of an alternate
                  address block from APNIC
      
               3. The following transfer details will be published by
                  APNIC in a public log of resource transfers:
      
                      - Source
                      - Source RIR or NIR
                      - Recipient
                      - Address resources
                      - Date of transfer
      
           Transfer fees:
      
           APNIC may charge the recipient entity 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
      -------------------------------------------------
      
      5.1 Advantages
      
           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. In
           particular, it 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 in particular,
                 associated with the unregistered transfers of IPv4
                 addresses.
      
               - 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.
      
      5.2 Disadvantages (and responses)
      
           5.2.1 Altering the traditional concepts of IP addresses
      
                 This proposal has the potential to alter a number of
                 traditional preconceptions relating to addresses and
                 their value, including challenging the concept that
                 addresses are not in and of themselves assets and
                 addresses do no in and of themselves have monetary value
                 outside of the narrow constraints of use in networks for
                 routing and end point identification. Changing these
                 common percpetions about addresses and their use opens
                 up the potential for a number of responses, including:
      
                     - The loss of strong aggregation capability in the
                       address space, with the consequent load being
                       imposed on the routing system.
      
                     - The significant shift away from a universal
                       need-based address allocation model in the
                       underlying policy framework.
      
                     - The treatment of addresses as property with the
                       associated legal ramifications in terms of
                       corporate and contract law.
      
                     - The imposition of taxes on addresses and their
                       movement.
      
                     - The potential for unfairness and inequities to be
                       realized in terms of access to addresses for use
                       by network service providers.
      
                 Response:
      
                 A number of factors mitigate the risks above:
      
                     - As the transition to IPv6 gathers pace, any
                       residual value of IPv4 addresses would fall in
                       line with the decreasing value proposition of
                       IPv4-based services in an increasing IPv6 network.
      
                     - If this policy were to be adopted while IPv4
                       addresses are still available from APNIC, APNIC's
                       established IPv4 address allocation process would
                       continue to provide an alternative source of
                       supply of IPv4 addresses to the industry.
      
           5.2.2 Proposal diverts attention from address reclamation and
           	   resuse
      
                 It has been argued that the proposal diverts attention
                 from policy development that encourages IP address
                 reclamation and reuse.
      
                 Response:
      
                 To date the level of return and reclamation of addresses
                 has been minimal. Aside from price-based mechanisms it
                 is unclear that further policy refinement would alter
                 this situation.
      
                 Even if policy development encouraged address
                 reclamation and reuse, there is the distinct possibility
                 that the amount reclaimed addresses would be smaller
                 than the amount needed for APNIC to continue to allocate
                 addresses on a needs-basis after the unallocated address
                 pool has been exhausted.
      
                 An open and significant issue is how APNIC could fairly
                 ration limited addresses when faced with a much larger
                 set of demands. In other words, concentrating on
                 relamation and reuse policies rather than transfer
                 policies also contains significant issues that may prove
                 challenging to resolve as a policy matter.
      
           5.2.3 Potential for APNIC to be cast as a regulator
      
                 If APNIC adopted this policy, APNIC may be cast as a
                 regulator of a secondary market in addresses. Concerns
                 have been expressed that APNIC has no experience,
                 expertise nor the authority to enforce regulatory
                 actions. Such a role may also expose APNIC to additional
                 litigation.
      
                 Response:
      
                 This proposal does not advocate such a role for
                 APNIC. The scope of this policy is explicitly limited to
                 the conditions that would allow APNIC to recognise and
                 record a transfer of addresses in its registry.
      
                 There is a general belief that adoption of this policy
                 would act as an incentive for a market in
                 addresses. However, that does not imply that markets
                 would act outside existing regulatory structures. Nor
                 does it mean that market participants would be immune
                 from existing regulatory measures within their
                 respective regimes.
      
                 The potential for additional liabilities associated with
                 this policy should be the subject of legal review by an
                 appropriately qualified party.
      
      6.   Effect on APNIC members
      ----------------------------
      
      APNIC members will have the ability to register the transfer of
      IPv4 address resources between APNIC members.
      
      
      7.   Effect on NIRs
      -------------------
      
      This policy would allow NIRs to determine their own transfer
      policies, and allow the transfer of resources between APNIC members
      and the members of an NIR based on meeting the respective
      eligibility criteria for the transfer.
      
      -30-