Re: [sig-policy] New version of prop-116: Prohibit to transfer IPv4 addr

    • To: chku <chku at twnic dot net dot tw>
    • Subject: Re: [sig-policy] New version of prop-116: Prohibit to transfer IPv4 addresses in the final /8 block
    • From: Ernest Tse <ernest.tse at pacswitch dot com>
    • Date: Mon, 11 Sep 2017 08:03:16 +0000 (UTC)
    • Cc: sig-policy at apnic dot net
    • Delivered-to: sig-policy at mailman dot apnic dot net
    • Dkim-signature: v=1; a=rsa-sha1; c=relaxed/relaxed; d=sendgrid.net; h=from:to:cc:reply-to:in-reply-to:references:subject:mime-version:content-type; s=smtpapi; bh=QdwMP8s2OjKeQiBFZNTVFDr4rlw=; b=YBS+IS24wBPNDKrQUD 3pSno1aGjj5lgBjv9vq+5+b5f0EBK4/bISPPFZeAEyN1DVxCE7bvlVBArjXy9dBT CGJgfma6hny3yuLDc1URVT+jmsiWdktatQSs2EeEpdXOr6hppp9Q7S9aQ11PRQhy pdafybc0AAM300vzvt854CQUU=
    • Importance: Normal
    • In-reply-to: <1505098112.29970.chku at twnic dot net dot tw>
    • List-archive: <http://mailman.apnic.net/mailing-lists/sig-policy/>
    • List-help: <mailto:sig-policy-request@lists.apnic.net?subject=help>
    • List-id: APNIC SIG on resource management policy <sig-policy.lists.apnic.net>
    • List-post: <mailto:sig-policy@lists.apnic.net>
    • List-subscribe: <https://mailman.apnic.net/mailman/listinfo/sig-policy>, <mailto:sig-policy-request@lists.apnic.net?subject=subscribe>
    • List-unsubscribe: <https://mailman.apnic.net/mailman/options/sig-policy>, <mailto:sig-policy-request@lists.apnic.net?subject=unsubscribe>
    • References: <1505098112.29970.chku@twnic.net.tw>
      • Dear,


        How I can reject this policy?


        Best Regards,

        Ernest Tse



        On Mon, 11/09/2017 10.48, chku <chku at twnic dot net dot tw> 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.

        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 earlier versions is available from:

        http://www.apnic.net/policy/proposals/prop-116

        The changes are:

        - updated stat data in section 1

        - added ripe region status in section 3

        - added end date in section 4

        4. Proposed policy solution
        ---------------------------

        Prohibit transfer IPv4 addresses under final /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. This two years requirement will apply both
        market and M&A transfers.

        ->(added) This restriction will end when final /8 address block
        (103/8) run out.


        Please find the text of the proposal below.

        Kind Regards,

        Sumon, Bertrand, Ching-Heng
        APNIC Policy SIG Chairs


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

        prop-116-v005: 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 transfers from 103/8 block are 352, which is about
        14% of the total number of transfers as of 10 Septermber 2017.
        This is the highest number of transfers in all APNIC managed /8s.

        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 |
        | 2017 | 45 | 178 |
        +------+-----------+------------+-

        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 |
        | 2017 | 70 | 288 |
        +------+-----------+-----------+

        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
        -----------------------------
        "RIPE Resource Transfer Policies" says:

        2.2 Transfer Restrictions

        Scarce resources, which are understood as those resources that are
        allocated or assigned by the RIPE NCC on a restricted basis (such as
        IPv4 or 16-bit ASNs), cannot be transferred for 24 months from the
        date the resource was received by the resource holder. This
        restriction also applies if the resource was received due to a change
        in the organisation°«s business (such as a merger or acquisition).


        4. Proposed policy solution
        ---------------------------

        Prohibit transfer IPv4 addresses under final /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. This two years requirement will apply both
        market and M&A transfers.

        This restriction will end when final /8 address block (103/8) run out.

        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
        -------------
        RIPE Resource Transfer Policies
        http://www.ripe.net/publications/docs/transfer-policies

        * sig-policy: APNIC SIG on resource management policy *
        _______________________________________________
        sig-policy mailing list
        sig-policy at lists dot apnic dot net
        https://mailman.apnic.net/mailman/listinfo/sig-policy