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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 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.

Good evening.
I do not support this proposal in its current form for the following reasons.
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.
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.
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:;
- 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.
- 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.
- Situation in other RIRs
No similar policy at other RIRs.
- 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.
- 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.
- Effect on APNIC
Transfers from the final /8 address range will be restricted in principle
- Effect on NIRs
NIRs need to adopt this policy.
sig-policy: APNIC SIG on resource management policy
sig-policy mailing list sig-policy@lists.apnic.net javascript:; http://mailman.apnic.net/mailman/listinfo/sig-policy

Hi, I agree with Dean and wants to add there are no such "underground transfers" and so far the so called "IPv4 black market" is struggling on its own. So again mere speculation if not than please it is requested to the author to share some details and enlighten the community.
Just want to add on top. Things which can be addressed morally shouldn't be addressed through policy. I wish to see ZERO '0' IPv4 address space in the APNIC bucket so that we can for the sake of progress start working on IPv6 deployment on large scale.
And ofcourse I also oppose this proposal.
Regards,
Aftab A. Siddiqui
On Thu, Jan 31, 2013 at 2:47 PM, Dean Pemberton dean@deanpemberton.comwrote:
Good evening.
I do not support this proposal in its current form for the following reasons.
- *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.
- *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.
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 Tomohiro Fujisaki fujisaki@syce.net
- 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.
- 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.
- Situation in other RIRs
No similar policy at other RIRs.
- 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.
- 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.
- Effect on APNIC
Transfers from the final /8 address range will be restricted in principle
- Effect on NIRs
NIRs need to adopt this policy.
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
-- Regards,
Dean
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

Hello Dean,
Thank you for your comments.
- *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.
- *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:;
- 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.
- 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.
- Situation in other RIRs
No similar policy at other RIRs.
- 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.
- 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.
- Effect on APNIC
Transfers from the final /8 address range will be restricted in principle
- Effect on NIRs
NIRs need to adopt this policy.
sig-policy: APNIC SIG on resource management policy
sig-policy mailing list sig-policy@lists.apnic.net javascript:; http://mailman.apnic.net/mailman/listinfo/sig-policy
-- Regards,
Dean

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.
[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.
Cheers Terry p.s deploy IPv6 and move on.
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
- 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.
- 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.
- Situation in other RIRs
No similar policy at other RIRs.
- 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.
- 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.
- Effect on APNIC
Transfers from the final /8 address range will be restricted in principle
- Effect on NIRs
NIRs need to adopt this policy.
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

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
- 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.
- 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.
- Situation in other RIRs
No similar policy at other RIRs.
- 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.
- 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.
- Effect on APNIC
Transfers from the final /8 address range will be restricted in principle
- Effect on NIRs
NIRs need to adopt this policy.
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
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

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

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

Would it be an unacceptable outcome if the impact of the last /8 policy were only to increase the difficulty of new /22 blocks, rather than preventing it outright?
(I don't have a dog in this fight, but I wonder whether it is practical to expect an absolute prohibition to be effective.)
On Feb 1, 2013, at 3:57 PM, Owen DeLong owen@delong.com wrote:
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
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

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

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

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

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.
- 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.
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.
-Mike

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.
- 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.
-Mike

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

Hi all,
I'm co-author of the policy prop-106.
We got several messages, and most of them were against to restrict transfers in the policy.
However, at the same time, we felt most people are against this proposal because problems are not big enough, and not necessarily saying the misuse of 103/8 block (final /8 policy) itself is okay.
Even if not in the form of a policy document, it may help to have it documented somewhere because there is nothing APNIC documents which APNIC/NIR hostmasters can refer to and point out when they find a case of misuse.
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.
Yours Sincerely, -- Tomohiro Fujisaki
From: Andy Linton asjl@lpnz.org Subject: [sig-policy] prop-106-v001: Restricting excessive IPv4 address transfers under the final /8 block Date: Thu, 31 Jan 2013 11:24:25 +0600
| 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 | 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 * | _______________________________________________ | sig-policy mailing list | sig-policy@lists.apnic.net | http://mailman.apnic.net/mailman/listinfo/sig-policy |

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 :)

Hi Aftab,
Thank you for your comments, and sorry for not to reply soon.
| That is the only guideline for APNIC Hostmasters for allocating resources.
First point, we have resource allocation guidelines:
http://www.apnic.net/publications/media-library/documents
'Resource guidelines' section bottom of this page.
We think to add text to this douments.
And second point,
| 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 :)
Yes, I think this is one option. However, I personally think even do so, we should clearly state this in the guideline or policy document so as to APNIC/NIR can refer.
Yours Sincerely, -- Tomohiro Fujiaki
From: Aftab Siddiqui aftab.siddiqui@gmail.com Subject: Re: [sig-policy] prop-106-v001: Restricting excessive IPv4 address transfers under the final /8 block Date: Sat, 23 Feb 2013 10:03:55 +0500
| 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 :)
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