Re: [sig-policy] [Sig-policy] prop-118: No need policy in APNIC region,

    • To: Satoru Tsurumaki <satoru.tsurumaki at g.softbank dot co dot jp>
    • Subject: Re: [sig-policy] [Sig-policy] prop-118: No need policy in APNIC region, to be dis cussed at APNIC 44 Policy SIG
    • From: David Hilario <d.hilario at laruscloudservice dot net>
    • Date: Fri, 8 Sep 2017 12:43:30 +0300
    • Cc: SIG policy <sig-policy at apnic dot net>
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      • 
        Thank you for reporting back those views.
        
        I will try to clarify where I can.
        
        
        On 8 September 2017 at 09:32, Satoru Tsurumaki
        <satoru.tsurumaki at g.softbank dot co dot jp> wrote:
        > Dear Colleagues,
        >
        >
        > I am Satoru Tsurumaki from Policy Working Group in Japan.
        >
        > I would like to share key feedback in our community for prop-118,
        > based on a meeting we organised on 5th Sep to discuss these proposals.
        >
        >
        > Mixed opinions were expressed on this proposal.
        >
        > Some participants were against the entire proposal. OTOH, there were
        > some who supported the need to remove needs based justification within
        > the APNIC region, while against justifying 50% use of transfer block
        > within 5 years.
        >
        > Below are details of different opinions expressed.
        >
        > Concerns/Opposing comments:
        > * Strong concern expressed over impact on the transfer with ARIN region.
        > If transfer with ARIN will not be allowed by removing needs based
        > criteria, cannot support this proposal.(*)
        >
        > (*) Additional Note:
        > It is acknowledged that RIPE region transfer with ARIN with the same
        > criteria as prop-118. It should resolve this concern if there is an
        > explicit confirmation from ARIN that the same approach will be
        > applicable to APNIC region
        
        The whole idea is indeed to keep the compatibility working with ARIN.
        
        >
        > * IP address should be distributed to those who need it, therefore
        > against removing needs based criteria
        >
        
        Having a justification based evaluation in transfer does unfortunately
        not help the ones who need IP address but have no money.
        Those with money do not transfer unless they have a need for that
        space, it is a costly and lengthy process.
        That is the situation at the moment.
        
        The need base evaluation is an administrative hurdle, it does not
        ensures fair re-distribution of address space.
        This policy is trying to remove that step from the process.
        
        > * Justifying 50% use within 5 years do not seem like meaningful
        > criteria. It is hard for applicants to speculate the needs for 5 years
        > (too long ahead) and it is also hard to evaluate the application. It
        > may not be a meaningful check despite the time and effort it takes for
        > both applicant and registry.
        >
        
        Plans for the coming 5 years, if you today make a transfer based on a
        hard deployment plan for the coming 12 months, you can still justify
        your transfer with that.
        If you happen to find larger amount than your needs for the coming 12
        months, you can justify with plans for up to 5 years.
        It is mainly to remain compatible with ARIN, if they ever drop those
        requirements, then it is not applied anymore.
        
        > * Concern expressed over abuse in the use of address space if both
        > this proposal and prop-119 are adopted
        >
        
        What type of abuse?
        
        >
        > Supportive Comment:
        > * If the role of registry is to be a record keeper in transfers of
        > resources, and both the source and recipient both agree, we can remove
        > needs based criteria
        >
        >
        > Best Regards,
        >
        >
        > Satoru Tsurumaki
        > Policy Working Group
        > Japan Open Policy Forum
        >
        > 2017-08-09 15:13 GMT+09:00 chku <chku at twnic dot net dot tw>:
        >> Dear SIG members
        >>
        >> The proposal "prop-118: No need policy in APNIC region" was discussed at
        >> APNIC 43 Policy SIG, but did not reach consensus.
        >>
        >> It will be presented at the Open Policy Meeting at APNIC 44 which will
        >> be held in Taichung, Taiwan on Wednesday and Thursday, 14 & 15 September
        >> 2017.
        >>
        >> Information about the proposal is available from:
        >>
        >>     http://www.apnic.net/policy/proposals/prop-118
        >>
        >> You are encouraged to express your views on the proposal:
        >>
        >>  - Do you support or oppose the proposal?
        >>  - 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?
        >>
        >> Please find the text of the proposal below.
        >>
        >> Kind Regards,
        >>
        >> Sumon, Bertrand, Ching-Heng
        >> APNIC Policy SIG Chairs
        >>
        >>
        >> -------------------------------------------------------
        >>
        >> prop-118-v001: No need policy in APNIC region
        >>
        >> -------------------------------------------------------
        >>
        >> Proposer:       David Hilario
        >>                 d.hilario at laruscloudservice dot net
        >>
        >>
        >> 1. Problem statement
        >> -------------------------------------------------------
        >>
        >> Whenever a transfer of IPv4 is taking place within the APNIC region, the
        >> recipient needs to demonstrate the "need" for the IPv4 space they intend
        >> to transfer.
        >>
        >> Companies transferring IPv4 space to their pool do this in ordcer to
        >> enable further growth in their network, since the space is not coming
        >> from the free public pool, regular policies that are intended to protect
        >> the limited pool of IPv4 space can be removed in transfers.
        >>
        >>
        >> 2. Objective of policy change
        >> -------------------------------------------------------
        >>
        >> Simplify transfer of IPv4 space between resource holders.
        >> Ease some administration on APNIC staff.
        >>
        >>
        >> 3. Situation in other regions
        >> -------------------------------------------------------
        >>
        >> RIPE region has an all around no need policy in IPv4, even for first
        >> allocation, transfers do not require the recipient to demonstrate their
        >> intended use of the resources .
        >>
        >> ARIN, need base for both transfers and resources issued by ARIN.
        >>
        >> AFRINIC, need based policy on transfers (not active yet) and resource
        >> request from AFRINIC based on needs.
        >>
        >> LACNIC, no transfers, need based request.
        >>
        >> Out of all these RIR, only ARIN and RIPE NCC have inter-RIR transfer
        >> policies,  ARIN has made clear in the past that the "no need" policy
        >> from the RIPE region would break inter-RIR transfers from ARIN to RIPE
        >> region.
        >>
        >>
        >> 4. Proposed policy solution
        >> -------------------------------------------------------
        >>
        >> Simply copy the RIPE policy to solve the ARIN transfer incompatibility:
        >>
        >>  - APNIC shall accept all transfers of Internet number resources to its
        >>    service region, provided that they comply with the policies relating
        >>    to transfers within its service region.
        >>
        >>  - For transfers from RIR regions that require the receiving region to
        >>    have needs-based policies, recipients must provide a plan to the
        >>    APNIC for the use of at least 50% of the transferred resources within
        >>    5 years.
        >>
        >> source:
        >>     https://www.ripe.net/publications/docs/ripe-644
        >>
        >>
        >> 5. Advantages / Disadvantages
        >> -------------------------------------------------------
        >>
        >> Advantages:
        >>
        >>  - Harmonisation with RIPE region.
        >>  - Makes transfer simpler and smoother within APNIC and between APNIC
        >>    and RIPE.
        >>  - maintains a compatibility with ARIN.
        >>  - Removes the uncertainty that a transfer may be rejected based on
        >>    potentially badly documented needs.
        >>  - Lowers the overall administrative burden on APNIC staff.
        >>
        >> Disadvantages:
        >>
        >> none.
        >>
        >>
        >> 6. Impact on resource holders
        >> -------------------------------------------------------
        >> None
        >>
        >>
        >> 7. References
        >> -------------------------------------------------------
        >>
        >>
        >>
        >>
        >> _______________________________________________
        >> Sig-policy-chair mailing list
        >> Sig-policy-chair at apnic dot net
        >> https://mailman.apnic.net/mailman/listinfo/sig-policy-chair
        >>
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