Sorry for the delay in posting these messages. I and the other members of the chair group had some problems posting to the sig-policy mailing list. Thanks to the APNIC staff for sorting things out.
---------- Forwarded message ---------- From: Andy Linton<asjl at lpnz dot org> Date: Wed, Nov 7, 2012 at 9:40 PM Subject: End of comment period: prop-104: Clarifying demonstrated needs requirement in IPv4 transfer policy
To: SIG policy <sig-policy at apnic dot net>
The eight-week final comment period for the proposal 'Clarifying
demonstrated needs requirement in IPv4 transfer policy' has ended.
During the comment period there were no significant objections raised to the
proposal. The Chairs therefore deem that consensus has been maintained
on the proposal.
We formally request that the APNIC Executive Council endorse this
proposal.
This proposal defines the period to be approved of IPv4 transfers for
recipients under demonstrated needs.
2. ÂSummary 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. ÂSituation 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":
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):
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:"
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".
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. ÂPros/Cons
-------------
Advantages:
  Â- Extended period will allow the larger block size to match a
   Âlonger term needs of the requester. It will help to reduce an
   ÂIPv4 address block fragmentation caused by transfer.
  Â- APNIC member can apply for IPv4 address transfer as a receiver on
   Âthe same condition of demonstrate a need in other RIR in case of
   ÂInter-RIR transfer. At this time, ARIN is the only RIR that
   Âadopts Inter-RIR policy in place other than APNIC. Thus, it
   Âplaces APNIC policy in line with ARIN on the transfer conditions.
  Â- It will allow the block size to more closely match the block size
   Âavailable for transfer from source.
  Â- It will reduce the risk of underground IPv4 address transfers,
   Âwhich do not get registered in APNIC database. There is a
   Âpossibility that the recipients could not obtain justification
   Âfor enough IPv4 address by the current period of demonstrated
   Âneeds.
Disadvantages:
  Â- None
   ÂThere may be people who feel 24 months does not lead to efficient
   Âutilization compared to 12 months.
   ÂHowever, the objective of needs based justification is not to
   Â"cut the size of address space to be transfered"; it is to ensure
   Âthat the transfered space will be utilized in realities. 24
   Âmonths is a realistic period to estimate required address space
   Âfor xSPs.
6. ÂEffect 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. ÂEffect on NIRs
------------------
It is the NIR's choice as to whether to adopt this policy.