Dear chairs

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@fiberathome.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@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 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 | +------+-----------+------------+-

1. 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

1. 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.

1. Situation in other regions

None.

1. 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.

1. 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.

1. 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)

1. References

•          sig-policy:  APNIC SIG on resource management policy           *
  

sig-policy mailing list sig-policy@lists.apnic.net https://mailman.apnic.net/mailman/listinfo/sig-policy