[sig-policy] Final Comment Period for prop-116: Prohibit to transfer IPv4 add resses in the final /8 block

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  • Subject: [sig-policy] Final Comment Period for prop-116: Prohibit to transfer IPv4 add resses in the final /8 block
  • From: "chku" <chku@twnic.net.tw>
  • Date: Mon, 18 Sep 2017 15:43:32 +0800 (CST)
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  • Reply-to: chku <chku@twnic.net.tw>

    • Dear colleagues
      
      A revised version "prop-116-v006: Prohibit to transfer IPv4 addresses in
      the final /8 block" reached consensus at the APNIC 44 Policy SIG and
      then later at the APNIC Member Meeting (AMM).
      
      Synopsis:
      ---------
      The proposed policy solution reaching consensus is:
      
      Prohibit transfer IPv4 addresses under final /8 address block (103/8)
      which have not passed five years after its allocation/assignment. If the
      address block allocated to a LIR in five years is not needed any more,
      it must return to APNIC to allocate to another organization using final
      /8 policy. This five years requirement will apply both market and M&A
      transfers.
      
      This proposal will now move to the next step in the APNIC Policy
      Development Process and is being returned to the Policy SIG mailing list
      for the final Comment Period.
        
         - Deadline for comments:  23:59 (UTC +10) Wednesday, 18 October 2017
      
      Proposal details, including the full text of the proposal, history, and
      links to previous versions are available at:
      
          https://www.apnic.net/community/policy/proposals/prop-116/
      
      Regards
      
      Sumon, Bertrand, Ching-Heng
      Policy SIG Chairs
      
      
      -------------------------------------------------------
      
      prop-116-v006: Prohibit to transfer IPv4 addresses in the final /8 block
      
      -------------------------------------------------------
      
      Proposer:       Tomohiro Fujisaki
                      fujisaki@syce.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 five years after its allocation/assignment. If
      the address block allocated to a LIR in five years is not needed any
      more, it must return to APNIC to allocate to another organization
      using final /8 policy. This five years requirement will apply both
      market and M&A transfers.
      
      
      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
      Hello Chairs
      
      I have prepared an email for the mailing list regarding the outcome of 
      prop-116.
      
      I have set the comment period to end at Wednesday, 18 October 2017. So
      please send it by Wednesday of this week. Or you can change the end date
      to whatever you want.
      
      The PDP says the Comment Period should be no less than 4 weeks, but can
      be as long as 8 weeks.
      
      Regards,
      
      Adam and George
      
      --
       
       
      ###DRAFT###
       
       
      Dear colleagues
      
      A revised version "prop-116-v006: Prohibit to transfer IPv4 addresses in
      the final /8 block" reached consensus at the APNIC 44 Policy SIG and
      then later at the APNIC Member Meeting (AMM).
      
      Synopsis:
      ---------
      The proposed policy solution reaching consensus is:
      
      Prohibit transfer IPv4 addresses under final /8 address block (103/8)
      which have not passed five years after its allocation/assignment. If the
      address block allocated to a LIR in five years is not needed any more,
      it must return to APNIC to allocate to another organization using final
      /8 policy. This five years requirement will apply both market and M&A
      transfers.
      
      This proposal will now move to the next step in the APNIC Policy
      Development Process and is being returned to the Policy SIG mailing list
      for the final Comment Period.
        
         - Deadline for comments:  23:59 (UTC +10) Wednesday, 18 October 2017
      
      Proposal details, including the full text of the proposal, history, and
      links to previous versions are available at:
      
          https://www.apnic.net/community/policy/proposals/prop-116/
      
      Regards
      
      Sumon, Bertrand, Ching-Heng
      Policy SIG Chairs
      
      
      -------------------------------------------------------
      
      prop-116-v006: Prohibit to transfer IPv4 addresses in the final /8 block
      
      -------------------------------------------------------
      
      Proposer:       Tomohiro Fujisaki
                      fujisaki@syce.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 five years after its allocation/assignment. If
      the address block allocated to a LIR in five years is not needed any
      more, it must return to APNIC to allocate to another organization
      using final /8 policy. This five years requirement will apply both
      market and M&A transfers.
      
      
      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
      
      
      
      
      
      
      
      
      
      
      
      
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