[sig-policy] New version of prop-104: Clarifying demonstrated needs requ

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  • Subject: [sig-policy] New version of prop-104: Clarifying demonstrated needs requirement in IPv4 transfer policy
  • From: Andy Linton <asjl at lpnz dot org>
  • Date: Wed, 29 Aug 2012 14:28:30 +0700
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    • Dear SIG members

      A new version the proposal "prop-104: Clarifying demonstrated needs
      requirement in IPv4 transfer policy" has been sent to the Policy SIG for
      review.

      Changes from previous version are:

           - Introduction was simplified to avoid misunderstanding.
           - Following text removed from "4.  Details" due to difficulties in
             implementation.

             "In case of Inter-RIR transfer, when there is a RIR which defines
              a period longer than 24 months in the future, the longer period
              adopted by the other RIR will be adopted."



      Information about this version and earlier versions is available from:

                 http://www.apnic.net/policy/proposals/prop-104

      You are encouraged you to express your views on the proposal:

                  - Do you support or oppose 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?

      Regards,

      Andy, Skeeve, and Masato


      ----------------------------------------------------------------------

      prop-104-v002: Clarifying demonstrated needs requirement in IPv4
                       transfer policy

      ----------------------------------------------------------------------


      Authors: Shin SHIRAHATA
                 <shin at clara dot ad dot jp>

                 Norisuke HIRAI
                 Akira NAKAGAWA


      1.  Introduction
      ----------------

      This proposal defines the period to be approved of IPv4 transfers for
      recipients under demonstrated needs.


      2.  Summary of the current problem
      ----------------------------------

      The current APNIC transfer policy has a requirement for demonstrate a
      need for transferred IPv4 addresses. The period of demonstrated needs
      under the current operational practice is 12 months based on the
      definition in Section 3.2, "Criteria for subsequent LIR delegations" in
      the "Policies for IPv4 address space management in the Asia Pacific
      region",

      "Based on these factors, APNIC and NIRs will delegate address space to
      meet the LIR's estimated needs for a period up to one year up to the
      maximum allowed delegation under Section 3."

      and this period was defined before the exhaustion.

      On the other hand, ARIN allows transfers based on demonstrated needs up
      to 24 months. This leads to difference in conditions of the transfer
      between LIRs in the APNIC region and the ARIN region.

      Furthermore, 12 months is also too short for transfers within the APNIC
      region considering many xSPs plan their service and their addressing
      requirements beyond one year.


      3.  Situation in other RIRs
      ---------------------------

      ARIN has a requirement for the period to be approved of IPv4 transfers
      for recipients under demonstrated needs, up to 24 months. LACNIC has a
      policy that defines to evaluate for 12 months needs. RIPE NCC has 3
      months requirement at this time, and the policy proposal that extend to
      24 months, is under discussion.

      AfriNIC:

      AfriNIC currently does not have an IPv4 address transfers policy.


      ARIN:

      ARIN policy has a clear period for justification for IPv4 address
      transfers, and the period is 24 months.

      "Such transferred number resources may only be received under RSA by
      organizations that are within the ARIN region and can demonstrate the
      need for such resources in the amount which they can justify under
      current ARIN policies showing how the addresses will be utilized within
      24 months."

      See Section 8.3, "Transfers to Specified Recipients" in the "ARIN Number
      Resource Policy Manual":

            https://www.arin.net/policy/nrpm.html#eight3

      This change was proposed by "DRAFT POLICY ARIN-2012-1: CLARIFYING
      REQUIREMENTS FOR IPV4 TRANSFERS".

            https://www.arin.net/policy/proposals/2012_1.html


      LACNIC:

      LACNIC policy defines to evaluate for 12 months needs for the recipient
      of the IPv4 address transfer. However, the transfer will only be
      activate once LACNIC's address pool runs out. (expect for the reserved
      space)

      See Section 2.3.2.13, "Submission of Assignment Information" and Section
      2.3.2.18.2, "Transfer of IPv4 Blocks within the LACNIC Region" in the
      LACNIC Policy Manual (v1.9):

            http://lacnic.net/en/politicas/manual3.html


      RIPE:

      In the RIPE region, the period of needs approved for IPv4 address
      transfers will be based on the definition of the current allocation
      policy, which is 3 months.

      Currently, there is no policy which defines the period of needs based
      justification, specifically for IPv4 transfers, separate from allocation
      criteria. See Section 5.0, "Policies and Guidelines for Allocations" in
      the RIPE-553, "IPv4 Address Allocation and Assignment Policies for the
      RIPE NCC Service Region:"

            http://www.ripe.net/ripe/docs/ripe-553/

      However, there is a policy proposal under discussions which proposes to
      extend the period of the demonstrated needs in case of IPv4 transfers,
      up to 24 months. See 2012-03, "Intra-RIR Transfer Policy Proposal".

            http://www.ripe.net/ripe/policies/proposals/2012-03


      4.  Details
      -----------

      This proposal clarifies the requirement on a period approved for the
      transferred resource to recipients of IPv4 transfers based on the
      demonstrated needs, and defines its period as "24 months".

      This proposal does not intend to change the requirement for an address
      allocation or assignment from APNIC.


      5.  Pros/Cons
      -------------

      Advantages:

            - Extended period will allow the larger block size to match a
              longer term needs of the requester. It will help to reduce an
              IPv4 address block fragmentation caused by transfer.

            - APNIC member can apply for IPv4 address transfer as a receiver on
              the same condition of demonstrate a need in other RIR in case of
              Inter-RIR transfer. At this time, ARIN is the only RIR that
              adopts Inter-RIR policy in place other than APNIC. Thus, it
              places APNIC policy in line with ARIN on the transfer conditions.

            - It will allow the block size to more closely match the block size
              available for transfer from source.

            - It will reduce the risk of underground IPv4 address transfers,
              which do not get registered in APNIC database. There is a
              possibility that the recipients could not obtain justification
              for enough IPv4 address by the current period of demonstrated
              needs.

      Disadvantages:

            - None

              There may be people who feel 24 months does not lead to efficient
              utilization compared to 12 months.

              However, the objective of needs based justification is not to
              "cut the size of address space to be transfered"; it is to ensure
              that the transfered space will be utilized in realities. 24
              months is a realistic period to estimate required address space
              for xSPs.


      6.  Effect on APNIC Members
      ---------------------------

      It will requires a recipients within the APNIC region must demonstrate
      the need for up to a 24 months use of IPv4 address block.


      7.  Effect on NIRs
      ------------------

      It is the NIR's choice as to whether to adopt this policy.