Re: [sig-policy] Revised prop-116-v003: Prohibit to transfer IPv4 addres

    • To: Sumon Ahmed Sabir <sumon at fiberathome dot net>
    • Subject: Re: [sig-policy] Revised prop-116-v003: Prohibit to transfer IPv4 addresses in the final /8 block
    • From: Jay Daley <jay at nzrs dot net dot nz>
    • Date: Mon, 30 Jan 2017 10:43:50 +1300
    • Cc: "sig-policy at apnic dot net" <sig-policy at apnic dot net>
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    • In-reply-to: <CAJMj-ZBoaUWZ2D77qt3uASTL_fJgHTs=+AoQZ=ipLusc-ubDog at mail dot gmail dot com>
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      • 
        In my view there is no point in prohibiting transfer as a proxy to prohibiting ’sales' because people will still carry out those sales and all that will happen is that they will not be registered correctly any more.
        
        I also agree with Mike Henderson, with the current role/strategy for RIRs there is no need for any more changes to IPv4 policy.
        
        regards
        Jay
        
        > On 30/01/2017, at 12:39 AM, Sumon Ahmed Sabir <sumon at fiberathome dot net> wrote:
        > 
        > Dear SIG members
        > 
        > A new version of the proposal "prop-116: Prohibit to transfer IPv4
        > addresses in the final /8 block" has been sent to the Policy SIG for
        > review.
        > 
        > Information about earlier versions is available from:
        > 
        > http://www.apnic.net/policy/proposals/prop-116
        > 
        > You are encouraged to express your views on the proposal:
        > 
        >   - Do you support or oppose the proposal?
        >   - Is there anything in the proposal that is not clear?
        >   - What changes could be made to this proposal to make it more effective?
        > 
        > Please find the text of the proposal below.
        > 
        > Kind Regards,
        > 
        > Masato and Sumon
        > 
        > 
        > 
        > 
        > 
        > 
        > -------------------------------------------------------
        > 
        > prop-116-v003: Prohibit to transfer IPv4 addresses in the final /8 block
        > 
        > -------------------------------------------------------
        > 
        > Proposer:       Tomohiro Fujisaki
        >                 fujisaki at syce dot net
        > 
        > 
        > 1. Problem statement
        > --------------------
        > 
        > There are a lot of transfers of IPv4 address blocks from 103/8
        > happening, both within the APNIC region and among RIRs.
        > 
        > Then number of transfer from 103/8 block are about 200, which is
        > about 12% of the total number of transfers. This looks so high
        > since APNIC manages about 40/8.
        > 
        > And based on the information provided by APNIC secretariat, number
        > of transfers from the 103/8 block are increasing year by year.
        > 
        > Updated by APNIC Secretariat on 27 January 2017:
        > 
        > 1) M&A transfers containing 103/8 space
        > 
        > +------+-----------+-----------+-
        > |      |   Total   | Number of |
        > | Year | Transfers |   /24s    |
        > +------+-----------+-----------+-
        > | 2011 |         3 |         12 |
        > | 2012 |        10 |         46 |
        > | 2013 |        18 |         66 |
        > | 2014 |       126 |        498 |
        > | 2015 |       147 |        573 |
        > | 2016 |        63 |        239 |
        > +------+-----------+------------+-
        > 
        > 2) Market transfers containing 103/8 space
        > 
        > +------+-----------+-----------+
        > |      |   Total   | Number of |
        > | Year | Transfers |   /24s    |
        > +------+-----------+-----------+
        > | 2011 |         2 |         2 |
        > | 2012 |        21 |        68 |
        > | 2013 |        16 |        61 |
        > | 2014 |        25 |        95 |
        > | 2015 |        67 |       266 |
        > | 2016 |       103 |       394 |
        > +------+-----------+-----------+
        > 
        > And also, transfers from the 103/8 block include:
        >   - Take place within 1 year of distribution, or
        >   - Multiple blocks to a single organization in case of beyond 1 year.
        > 
        > Further, there is a case where a single organization have received 12
        > blocks transfers from 103 range.
        > 
        > see:  https://www.apnic.net/transfer-resources/transfer-logs
        > 
        > From these figures, it is quite likely that substantial number of 103/8
        > blocks are being used for transfer purpose.
        > 
        > This conflicts with the concept of distribution of 103/8 block
        > (prop-062), which is intended to accommodate minimum IPv4 address blocks
        > for new comers.
        > 
        > °°prop-062: Use of final /8
        > °°https://www.apnic.net/policy/proposals/prop-062
        > 
        > 
        > 2. Objective of policy change
        > -----------------------------
        > 
        > When stated problem is solved, distribution from 103/8 block will be
        > consistent with its original purpose, for distribution for new entrants
        > to the industry. Without the policy change, substantial portion of 103/8
        > blocks will be consumed for transfer purpose.
        > 
        > 
        > 3. Situation in other regions
        > -----------------------------
        > 
        > None.
        > 
        > 
        > 4. Proposed policy solution
        > ---------------------------
        > 
        > Prohibit transfer IPv4 addresses under /8 address block (103/8) which
        > have not passed two years after its allocation/assignment.
        > If the address block allocated to a LIR in two years is not needed any
        > more, it must return to APNIC to allocate to another organization
        > using final /8 policy.
        > 
        > In the case of transfers due to M&A, merged organization can have
        > up to /22 IPv4 address in the 103/8 block in principle. If there
        > are technical reasons such as all address is used in separate networks
        > and announced from multiple ASes, merged organization can keep them.
        > Otherwise, the 103/8 IPv4 address more than /22 must return to APNIC
        > to allocate to another organization using final /8 policy.
        > 
        > 
        > 5. Advantages / Disadvantages
        > -----------------------------
        > 
        > Advantages:
        >   - It makes 103/8 blocks available according to the original purpose,
        >     as distribution for new entrants (rather than being consumed for
        >     transfer purpose)
        > 
        >   - IPv4 addresses under final /8 are not transferred to outside APNIC.
        > 
        >   - By prohibiting transfer them, it is possible to keep one /22 for
        >     each LIRs state, which is fair for all LIRs.
        > 
        > Disadvantages:
        > 
        > None.
        > 
        > 
        > 6. Impact on resource holders
        > ------------------------------
        > 
        >   - LIRs cannot transfer address blocks under 103/8. No big impact while
        >     they use it.
        > 
        >   - Organizations which needs to receive transferred IPv4 can continue
        >     to do so, outside 103/8 blocks (which should be made available for
        >     new entrants)
        > 
        > 
        > 7. References
        > -------------
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        Jay Daley
        Chief Executive
        NZRS Ltd
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