Orbit

Hello Dean,

Thank you for your comments.

1. *There is no clearly defined problem accepted by the community*

The author provides no proof that there is a current problem, instead choosing to speculate that there may seem to be a problem.

I would need to see solid proof that the suggested situation was infant happening before I would support any policy proposing so solve such a problem.

We observed that some LIRs are obtaining IPv4 address block from last /8 block, and then transfer into another account. http://www.sfc.wide.ad.jp/~true/tmp/transfers_from_last_8_blk.png

I'd like to ask Policy-sig members that this kind of transfers should be allowed, or restricted? We believe that kind of activities are against the spirit of the final /8 policy.

2. *The proposal gives no firm policy details.* Instead offering two

options. If it is not clear which option would provide a clear solution to a demonstrated problem then this policy needs much more discussion before being considered at the policy sig.

I'm sorry about no firm policy details in the proposal. Our intention is to raise awareness of the think kind of activities at this moment. I'll update to include single solution.

Regards, Shin

3). I need to be convinced that The Huston-Bush law of "It's all gone, get over it!" doesn't apply here. Do we really care about the last little dregs? Let people gather them. It's crumbs anyway.

I am happy to discuss this issue, but as I have highlighted before, bringing up new issues at the 11th hour as drafted policy is not in my opinion the way to gain community consensus.

So. Convince me that there is a problem (with proof), choose a single solution to fix it and convince me that these dregs are worth fighting over. Then you'll have my support.

Dean

On Thursday, January 31, 2013, Andy Linton wrote:

...

Dear SIG Members

The proposal "prop-106-v001: Restricting excessive IPv4 address transfers under the final /8 block' has been sent to the Policy SIG for review.

It will be discussed at the Policy SIG at APNIC 35 in Singapore, Thursday 28 February 2013.

We invite you to review and comment on the proposal on the mailing list before the meeting.

The comment period on the mailing list before an APNIC meeting is an important part of the policy development process. We encourage you to express your views on the proposal:

      - Do you support or oppose this proposal?
      - Does this proposal solve a problem you are experiencing? If
        so, tell the community about your situation.
      - 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?

Information about this proposal is available from:

        https://www.apnic.net/policy/proposals/prop-106

Andy, Skeeve, Masato

---

prop-106-v001: Restricting excessive IPv4 address transfers under the final /8 block

---

Authors: Shin SHIRAHATA shin@clara.ad.jp javascript:; Tomohiro Fujisaki fujisaki@syce.net javascript:;

1. Introduction

---

This policy proposes to restricting IPv4 address transfers which were allocated/assigned from the final /8 block.

Based on our observations of the APNIC transfer history records, some LIRs seems to collect IPv4 address blocks under the final /8 range by using multiple accounts, and transfer these blocks to a single account. We believe this kind of behaviors are against the spirit of the final /8 policy.

2. Summary

---

The current APNIC IPv4 address transfer policy allows to obtain a maximum of /22 distribution(s) per each APNIC account holder.

We propose add a restriction to IPv4 address transfer policy to restricting excessive IPv4 address transfers under the final /8 block.

3. Situation in other RIRs

---

No similar policy at other RIRs.

4. Details

---

There are options to handle this problem.

Option 1: Restrict IPv4 address transfers under the final /8 address block for two years.

- Prohibits transfers of the address block for two years after
  receiving the distribution under the final /8 address block.

Option 2: Set a deposit for transfers under the final /8 range.

- Pay ten years of APNIC's annual fees for transfered address
  block in advance when receiving the final /8 address range
  by address transfer or account name change.

  If an APNIC account holder transfers the final /8 range, the
  rights associated with the advanced payment of the annual fees
  will get dissolved, and the transfer recipient must pay the
  annual fees just the same as regular APNIC account holders.

5. Pros/Cons

---

Advantages:

- Restricting the last /8 address range to concentrate on a
  particular account holder

- Matches with the spirit of the final /8 policy

Disadvantages:

- The changes may increase an incentive of underground transfers.

6. Effect on APNIC

---

Transfers from the final /8 address range will be restricted in principle

7. Effect on NIRs

---

NIRs need to adopt this policy.

•          sig-policy:  APNIC SIG on resource management policy
  

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sig-policy mailing list sig-policy@lists.apnic.net javascript:; http://mailman.apnic.net/mailman/listinfo/sig-policy

-- Regards,

Dean

On Jan 31, 2013, at 20:16 , Terry Manderson terry@terrym.net wrote:

Speaking only as an individual and for myself.

For what it is worth, I do not support this proposal.

I think the introduction alone highlights the crux of my concern.

If an LIR is applying for resources, and getting them, and using them to satisfy the goals of internet service provision - I see no problem here. The fact that they **might** [1] be getting IPv4 resources by using a new APNIC account and then transferring them to another existing account is near irrelevant. The recipient must still satisfy the usage provisions of the transfer policy (https://www.apnic.net/policy/transfer-policy#recipient-conditions) and thus in my mind this says that IPv4 addresses are being validly used. To the extent of APNIC's stewardship of the resource pool and ensuring that IPv4 address are being distributed to where they are needed and provided uniqueness of the number space is maintained by ensuring that the address holder is known, the RIR mandate remains satisfied and the 'spirit' of the last /8 policy remains unmolested.

Actually, if that's what is happening, then it is a direct attempt to circumvent the intent of the last /8 policy. I hadn't thought that particular scenario through, so I appreciate your bringing it to my attention.

I'm not sure I support this policy as written, but I do support policy to close said loophole.

I would propose that any prefix obtained from the last /8 (these are, after all, easily identifiable) simply be excluded from the transfer policy and that all such prefixes be subject to reclamation if the entity which received the prefix ceases operations.

While you may or may not support the intent of the last /8 policy (I personally have very mixed emotions about it), the simple fact is that it did achieve consensus in the community and it should not be repealed by loophole absent community consensus to change the policy.

[1] Trying to prove intent here is an exercise in futility.

All due respect to the authors, but mooting these two 'options' to (what I see as a non-existant) problem drags bottom-up stakeholder governance over to the dark side of enabling bureaucratic enforcement of financial and forfeiture barriers upon business operations.

Ah, yes, the ever present belief that any attempt to regulate business in the common interest is evil.

Cheers Terry p.s deploy IPv6 and move on.

On this, we agree.

Owen

On 31/01/2013, at 3:24 PM, Andy Linton wrote:

...

prop-106-v001: Restricting excessive IPv4 address transfers under the final /8 block

---

Authors: Shin SHIRAHATA shin@clara.ad.jp Tomohiro Fujisaki fujisaki@syce.net

1. Introduction

---

This policy proposes to restricting IPv4 address transfers which were allocated/assigned from the final /8 block.

Based on our observations of the APNIC transfer history records, some LIRs seems to collect IPv4 address blocks under the final /8 range by using multiple accounts, and transfer these blocks to a single account. We believe this kind of behaviors are against the spirit of the final /8 policy.

2. Summary

---

The current APNIC IPv4 address transfer policy allows to obtain a maximum of /22 distribution(s) per each APNIC account holder.

We propose add a restriction to IPv4 address transfer policy to restricting excessive IPv4 address transfers under the final /8 block.

3. Situation in other RIRs

---

No similar policy at other RIRs.

4. Details

---

There are options to handle this problem.

Option 1: Restrict IPv4 address transfers under the final /8 address block for two years.

• Prohibits transfers of the address block for two years after receiving the distribution under the final /8 address block.

Option 2: Set a deposit for transfers under the final /8 range.

• Pay ten years of APNIC's annual fees for transfered address block in advance when receiving the final /8 address range by address transfer or account name change.

  If an APNIC account holder transfers the final /8 range, the rights associated with the advanced payment of the annual fees will get dissolved, and the transfer recipient must pay the annual fees just the same as regular APNIC account holders.

5. Pros/Cons

---

Advantages:

• Restricting the last /8 address range to concentrate on a particular account holder

• Matches with the spirit of the final /8 policy

Disadvantages:

• The changes may increase an incentive of underground transfers.

6. Effect on APNIC

---

Transfers from the final /8 address range will be restricted in principle

7. Effect on NIRs

---

NIRs need to adopt this policy.

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

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

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

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

All of them.

Here's the problem… If you're trying to circumvent the last /8 policy by creating a pseudo-org, obtaining a /22, then transferring that /22 to the original org., then it's easy enough to do the transfer either by having the parent acquire the pseudo-org (M&A) or by having the resources transferred under Section 3.

Owen

On Feb 1, 2013, at 8:15 AM, Leo Vegoda leo.vegoda@icann.org wrote:

Hi Owen,

Owen DeLong wrote:

[...]

...

I would propose that any prefix obtained from the last /8 (these are,

after all, easily identifiable)

...

simply be excluded from the transfer policy and that all such prefixes be

subject to reclamation

...

if the entity which received the prefix ceases operations.

Which part of the transfer policy? Section 3 deals with transfers between APNIC account holders while section 6 deals with corporate M&A activity.

Thanks,

Leo

On Jan 31, 2013, at 9:25 PM, Owen DeLong owen@delong.com wrote:

...

All due respect to the authors, but mooting these two 'options' to (what I see as a non-existant) problem drags bottom-up stakeholder governance over to the dark side of enabling bureaucratic enforcement of financial and forfeiture barriers upon business operations.

Ah, yes, the ever present belief that any attempt to regulate business in the common interest is evil.

Ah, yes, the ever present fantasy that RIRs creating increasingly Byzantine policies will help deal with the fact that IPv4 supply can't meet demand.

Creating new entities to circumvent the /8 policy was a blatantly obvious outcome. Not bothering to do transfers and thereby reducing the usefulness of the APNIC whois database would be the blatantly obvious outcome of prop-106. Not sure that's particularly desirable.

However, the fractal pattern of deck chairs is interesting to look at I suppose.

Regards, -drc

On Feb 1, 2013, at 17:41 , Randy Bush randy@psg.com wrote:

...

...

Ah, yes, the ever present belief that any attempt to regulate business in the common interest is evil.

Ah, yes, the ever present fantasy that RIRs creating increasingly Byzantine policies will help deal with the fact that IPv4 supply can't meet demand.

there is a significant difference between the position that the rirs should be bookkeepers and not regulators, and the statement that there should be no regulation.

and arin is this year's extreme example of why the rirs should not be regulators.

randy

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

---

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

Amusingly, I actually spoke against the last /8 policy for many of the reasons now being discussed. However, the community came to consensus and put the policy on the books.

If there's community consensus to repeal the policy, then I accept there is no need to attempt to enforce it.

If there's no community consensus to repeal the policy, then I feel that we have an obligation to try and make it work.

Owen

On Feb 2, 2013, at 9:43 PM, Mike Jager mike@mikej.net.nz wrote:

...

Disadvantages:

• The changes may increase an incentive of underground transfers.

If my memory serves, one of the important points to come out of all of the transfer policy discussion was that if a "legitimate" transfer is "too hard", the resources will be "transferred" (read: used/leased/borrowed/swapped for a dozen/whatever in the long-term by another entity) anyway, without notification to the RIR(s) concerned.

I kinda feel like we've been down this path before.

The IP black market is often held up as the boogeyman to try and scare us into bad policy decisions.

It remains an undocumented specter.

...

4. Details

---

There are options to handle this problem.

Option 1: Restrict IPv4 address transfers under the final /8 address block for two years.

• Prohibits transfers of the address block for two years after receiving the distribution under the final /8 address block.

Option 2: Set a deposit for transfers under the final /8 range.

• Pay ten years of APNIC's annual fees for transfered address block in advance when receiving the final /8 address range by address transfer or account name change.

  If an APNIC account holder transfers the final /8 range, the rights associated with the advanced payment of the annual fees will get dissolved, and the transfer recipient must pay the annual fees just the same as regular APNIC account holders.

I can't see that either of these options will solve the problem as described, and both of them aggravate the "hidden transfer" problem.

Under the first option, a potential recipient of a transfer has no choice but to use the resources without informing APNIC. Under the second option, there is a strong financial incentive for them to behave in the same way.

It's relatively easy to detect such usage in most cases and APNIC would, IMHO, at that point have a pretty good case for revocation.

Trying to restrict a transfer of resources after the resources have been legitimately allocated to a new member seems like frantically welding the gate shut after the horse has bolted. If there is a problem here, then like others, I'd like to see some data before we jump into solving it.

I could say the same thing about the so-called black market.

Owen

On 4/02/13 8:06 AM, Owen DeLong wrote:

...

The IP black market is often held up as the boogeyman to try and scare us into bad policy decisions.

If there are organisations out there that have decided that forming a new entity, receiving a /22 from APNIC, transferring it to their original entity, and winding up the new entity is the easiest way for them to receive additional IPv4 resource, I'm fairly certain that this proposal isn't going to stop them. They'll just continue to do what they're doing, but without actually informing APNIC of the transfer. No black market involved, as the address space is still ultimately allocated to the people using it, albeit through different memberships/legal entities.

I'm not trying to scare anyone into anything. My concern with the proposal is nothing to do with the black market, it's that it wont actually have the intended effect of preventing organisations getting more than a single /22 under the final /8 policy.

This proposal isn't going to stop forming a new entry and receiving a /22 from APNIC by policy, but it will changes financial incentives.

Under the second option, there is a no financial incentive to transfer from last /8 block. Because obtaining IP address through IPv4 address transfer would much cheaper choice as long as following condition is true:

Deposit amount of APNIC Membership fee (e.g 10yrs) for /22 > cost of transfer /22

Regards, Shin

Regards,

Aftab A. Siddiqui

Hi Tomohiro,

So, we would like to change our proposal to describe the spilt of /8 policy and remarks spirit in the guideline document such as:

- IPv4 address transfer under 103/8 block may not be approved, in
  cases where APNIC/NIRs considers that it does not match with the
  spirit of the final /8 policy.

This would allow APNIC/NIRs referring to the guidelines document, when they find the case of misuse.

I doubt if there is any provision of having a Guideline document instead of policy proposal. Bylaws are there for the same purpose. Or please enlighten me if I'm wrong.

APNIC ByLaws: Part II - Objects

The objects of APNIC are: a: to provide the service of allocating and registering Internet resources for the purpose of enabling communications via open system network protocols and to assist in the development and growth of the Internet in the Asia and Pacific Rim region;

That is the only guideline for APNIC Hostmasters for allocating resources. Secondly, for recently new resource allocation hostmasters says "We don't expect you transfer the resource to another APNIC member account within 12 months. Can you please confirm your understanding?" I think its enough to take this prop back :)