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Dear SIG members
The proposal "prop-104-v001: Clarifying demonstrated needs requirement in IPv4 transfer policy' has been sent to the Policy SIG for review.
It will be discussed at the Policy SIG at APNIC 34 in Phnom Penh, Cambodia, Thursday, 30 August 2012.
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-104
Andy, Skeeve, Masato
----------------------------------------------------------------------
prop-104-v001: Clarifying demonstrated needs requirement in IPv4 transfer policy
----------------------------------------------------------------------
Authors: Shin SHIRAHATA shin@clara.ad.jp
Norisuke HIRAI Akira NAKAGAWA
1. Introduction ----------------
This proposal defines the period to be approved of IPv4 transfers for recipients under demonstrated needs, in addition to current IPv4 address policy for allocation/assignment from APNIC.
2. Summary of the current problem ----------------------------------
The current APNIC transfer policy has a requirement for demonstrate a need for transferred IPv4 addresses. The period of demonstrated needs under the current operational practice is 12 months based on the definition in Section 3.2, "Criteria for subsequent LIR delegations" in the "Policies for IPv4 address space management in the Asia Pacific region",
"Based on these factors, APNIC and NIRs will delegate address space to meet the LIR's estimated needs for a period up to one year up to the maximum allowed delegation under Section 3."
and this period was defined before the exhaustion.
On the other hand, ARIN allows transfers based on demonstrated needs up to 24 months. This leads to difference in conditions of the transfer between LIRs in the APNIC region and the ARIN region.
Furthermore, 12 months is also too short for transfers within the APNIC region considering many xSPs plan their service and their addressing requirements beyond one year.
3. Situation in other RIRs ---------------------------
ARIN has a requirement for the period to be approved of IPv4 transfers for recipients under demonstrated needs, up to 24 months. LACNIC has a policy that defines to evaluate for 12 months needs. RIPE NCC has 3 months requirement at this time, and the policy proposal that extend to 24 months, is under discussion.
AfriNIC:
AfriNIC currently does not have an IPv4 address transfers policy.
ARIN:
ARIN policy has a clear period for justification for IPv4 address transfers, and the period is 24 months.
"Such transferred number resources may only be received under RSA by organizations that are within the ARIN region and can demonstrate the need for such resources in the amount which they can justify under current ARIN policies showing how the addresses will be utilized within 24 months."
See Section 8.3, "Transfers to Specified Recipients" in the "ARIN Number Resource Policy Manual":
https://www.arin.net/policy/nrpm.html#eight3
This change was proposed by "DRAFT POLICY ARIN-2012-1: CLARIFYING REQUIREMENTS FOR IPV4 TRANSFERS".
https://www.arin.net/policy/proposals/2012_1.html
LACNIC:
LACNIC policy defines to evaluate for 12 months needs for the recipient of the IPv4 address transfer. However, the transfer will only be activate once LACNIC's address pool runs out. (expect for the reserved space)
See Section 2.3.2.13, "Submission of Assignment Information" and Section 2.3.2.18.2, "Transfer of IPv4 Blocks within the LACNIC Region" in the LACNIC Policy Manual (v1.9):
http://lacnic.net/en/politicas/manual3.html
RIPE:
In the RIPE region, the period of needs approved for IPv4 address transfers will be based on the definition of the current allocation policy, which is 3 months.
Currently, there is no policy which defines the period of needs based justification, specifically for IPv4 transfers, separate from allocation criteria. See Section 5.0, "Policies and Guidelines for Allocations" in the RIPE-553, "IPv4 Address Allocation and Assignment Policies for the RIPE NCC Service Region:"
http://www.ripe.net/ripe/docs/ripe-553/
However, there is a policy proposal under discussions which proposes to extend the period of the demonstrated needs in case of IPv4 transfers, up to 24 months. See 2012-03, "Intra-RIR Transfer Policy Proposal".
http://www.ripe.net/ripe/policies/proposals/2012-03
4. Details -----------
This proposal clarifies the requirement on a period approved for the transferred resource to recipients of IPv4 transfers based on the demonstrated needs, and defines its period as "24 months".
In case of Inter-RIR transfer, when there is a RIR which defines a period longer than 24 months in the future, the longer period adopted by the other RIR will be adopted.
This proposal does not intend to change the requirement for an address allocation or assignment.
5. Pros/Cons -------------
Advantages:
- Extended period will allow the larger block size to match a longer term needs of the requester. It will help to reduce an IPv4 address block fragmentation caused by transfer.
- APNIC member can apply for IPv4 address transfer as a receiver on the same condition of demonstrate a need in other RIR in case of Inter-RIR transfer. At this time, ARIN is the only RIR that adopts Inter-RIR policy in place other than APNIC. Thus, it places APNIC policy in line with ARIN on the transfer conditions.
- It will allow the block size to more closely match the block size available for transfer from source
- It will reduce the risk of underground IPv4 address transfers, which do not get registered in APNIC database. There is a possibility that the recipients could not obtain justification for enough IPv4 address by the current period of demonstrated needs.
Disadvantages:
- None
There may be people who feel 24 months does not lead to efficient utilization compared to 12 months.
However, the objective of needs based justification is not to "cut the size of address space to be transfered"; it is to ensure that the transfered space will be utilized in realities. 24 months is a realistic period to estimate required address space for xSPs.
6. Effect on APNIC Members ---------------------------
It will requires a recipients within the APNIC region must demonstrate the need for up to a 24 months use of IPv4 address block.
If there is a RIR which defines a period longer than 24 months, the recipients may use the longer period to demonstrate its demand for an Inter-RIR transfer from that RIR.
7. Effect on NIRs ------------------
It is the NIR's choice as to whether to adopt this policy.
Good Afternoon,
A lot of this policy looks to compare the current APNIC situation with that in other RIRs, I do not believe a difference in itself is a reason to change policy. Just because it is done differently elsewhere, while interesting, should not be a necessary and sufficient condition for policy change within this region.
Therefore the justification for this policy really boils down to:
Furthermore, 12 months is also too short for transfers within the APNIC region considering many xSPs plan their service and their addressing requirements beyond one year.
As with prop-99. I'd like to ask Sanjaya, is there a way to accomodate this situation under the current policies. For example, If a user were able to justify their needs for a two year period, would the hostmasters support a transfer under the current policies.
We can then see if there appears to be a problem.
Kind Regards, Dean
- Summary of the current problem
The current APNIC transfer policy has a requirement for demonstrate a need for transferred IPv4 addresses. The period of demonstrated needs under the current operational practice is 12 months based on the definition in Section 3.2, "Criteria for subsequent LIR delegations" in the "Policies for IPv4 address space management in the Asia Pacific region",
"Based on these factors, APNIC and NIRs will delegate address space to meet the LIR's estimated needs for a period up to one year up to the maximum allowed delegation under Section 3."
and this period was defined before the exhaustion.
On the other hand, ARIN allows transfers based on demonstrated needs up to 24 months. This leads to difference in conditions of the transfer between LIRs in the APNIC region and the ARIN region.
Furthermore, 12 months is also too short for transfers within the APNIC region considering many xSPs plan their service and their addressing requirements beyond one year.
- Situation in other RIRs
ARIN has a requirement for the period to be approved of IPv4 transfers for recipients under demonstrated needs, up to 24 months. LACNIC has a policy that defines to evaluate for 12 months needs. RIPE NCC has 3 months requirement at this time, and the policy proposal that extend to 24 months, is under discussion.
AfriNIC:
AfriNIC currently does not have an IPv4 address transfers policy.
ARIN:
ARIN policy has a clear period for justification for IPv4 address transfers, and the period is 24 months.
"Such transferred number resources may only be received under RSA by organizations that are within the ARIN region and can demonstrate the need for such resources in the amount which they can justify under current ARIN policies showing how the addresses will be utilized within 24 months."
See Section 8.3, "Transfers to Specified Recipients" in the "ARIN Number Resource Policy Manual":
https://www.arin.net/policy/nrpm.html#eight3This change was proposed by "DRAFT POLICY ARIN-2012-1: CLARIFYING REQUIREMENTS FOR IPV4 TRANSFERS".
https://www.arin.net/policy/proposals/2012_1.htmlLACNIC:
LACNIC policy defines to evaluate for 12 months needs for the recipient of the IPv4 address transfer. However, the transfer will only be activate once LACNIC's address pool runs out. (expect for the reserved space)
See Section 2.3.2.13, "Submission of Assignment Information" and Section 2.3.2.18.2, "Transfer of IPv4 Blocks within the LACNIC Region" in the LACNIC Policy Manual (v1.9):
http://lacnic.net/en/politicas/manual3.htmlRIPE:
In the RIPE region, the period of needs approved for IPv4 address transfers will be based on the definition of the current allocation policy, which is 3 months.
Currently, there is no policy which defines the period of needs based justification, specifically for IPv4 transfers, separate from allocation criteria. See Section 5.0, "Policies and Guidelines for Allocations" in the RIPE-553, "IPv4 Address Allocation and Assignment Policies for the RIPE NCC Service Region:"
http://www.ripe.net/ripe/docs/ripe-553/However, there is a policy proposal under discussions which proposes to extend the period of the demonstrated needs in case of IPv4 transfers, up to 24 months. See 2012-03, "Intra-RIR Transfer Policy Proposal".
http://www.ripe.net/ripe/policies/proposals/2012-03
- Details
This proposal clarifies the requirement on a period approved for the transferred resource to recipients of IPv4 transfers based on the demonstrated needs, and defines its period as "24 months".
In case of Inter-RIR transfer, when there is a RIR which defines a period longer than 24 months in the future, the longer period adopted by the other RIR will be adopted.
This proposal does not intend to change the requirement for an address allocation or assignment.
- Pros/Cons
Advantages:
- Extended period will allow the larger block size to match a longer term needs of the requester. It will help to reduce an IPv4 address block fragmentation caused by transfer. - APNIC member can apply for IPv4 address transfer as a receiver on the same condition of demonstrate a need in other RIR in case of Inter-RIR transfer. At this time, ARIN is the only RIR that adopts Inter-RIR policy in place other than APNIC. Thus, it places APNIC policy in line with ARIN on the transfer conditions. - It will allow the block size to more closely match the block size available for transfer from source - It will reduce the risk of underground IPv4 address transfers, which do not get registered in APNIC database. There is a possibility that the recipients could not obtain justification for enough IPv4 address by the current period of demonstrated needs.Disadvantages:
- None There may be people who feel 24 months does not lead to efficient utilization compared to 12 months. However, the objective of needs based justification is not to "cut the size of address space to be transfered"; it is to ensure that the transfered space will be utilized in realities. 24 months is a realistic period to estimate required address space for xSPs.
- Effect on APNIC Members
It will requires a recipients within the APNIC region must demonstrate the need for up to a 24 months use of IPv4 address block.
If there is a RIR which defines a period longer than 24 months, the recipients may use the longer period to demonstrate its demand for an Inter-RIR transfer from that RIR.
- Effect on NIRs
It is the NIR's choice as to whether 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
Dean makes a good point here which may well hold in other cases.
Proposing policy changes really shouldn't be our first choice for problem resolution. I see no reason why people shouldn't come to this list with a problem statement such as the one Dean suggests:
For example, If a user were able to justify their needs for a two year period, would the hostmasters support a transfer under the current policies.
and asking the Secretariat for an opinion. This would allow others with similar problems/questions to take part in discussions.
As Policy SIG Chair I'd be happy to help with such requests and I suspect the Co-Chairs would as well.
Is we can't find a satisfactory solution this way then we can move to more formal methods.
andy
On Tue, Jul 31, 2012 at 3:05 PM, Dean Pemberton dean@deanpemberton.com wrote:
Good Afternoon,
A lot of this policy looks to compare the current APNIC situation with that in other RIRs, I do not believe a difference in itself is a reason to change policy. Just because it is done differently elsewhere, while interesting, should not be a necessary and sufficient condition for policy change within this region.
Therefore the justification for this policy really boils down to:
Furthermore, 12 months is also too short for transfers within the APNIC region considering many xSPs plan their service and their addressing requirements beyond one year.
As with prop-99. I'd like to ask Sanjaya, is there a way to accomodate this situation under the current policies. For example, If a user were able to justify their needs for a two year period, would the hostmasters support a transfer under the current policies.
We can then see if there appears to be a problem.
Kind Regards, Dean
and asking the Secretariat for an opinion. This would allow others
with similar problems/questions to take part in discussions.
Is we can't find a satisfactory solution this way then we can move to
more formal methods.
Regards,
Aftab A. Siddiqui
Is we can't find a satisfactory solution this way then we can move to more formal methods.
And this is what prop-103 is trying to convey as well, right? no more props until and unless there is a life or death operational/management situation with consensus.
"life or death" may be a little extreme. i think andy said it well.
Proposing policy changes really shouldn't be our first choice for problem resolution. I see no reason why people shouldn't come to this list with a problem statement such as the one Dean suggests:
randy
Hi Andy and All,
Proposing policy changes really shouldn't be our first choice for problem resolution. I see no reason why people shouldn't come to this list with a problem statement such as the one Dean suggests:
I agree with your opinion.
Actually, we had the same thought, and we confirmed with APNIC team before the submission.
The response we received was that APNIC secretariat should follow APNIC policy and stick to one year need at this stage. If there is a need to change this, it should be discussed at policy-sig.
This was why we submitted the proposal but we are open to hear if there has been any changes since we last confirmed with APNIC.
Could you follow-up if the change can be done under current policy?
APNIC team
Regards, Shin
Hello SIG Members
Can I just clarify the current situation regarding demonstrated needs in the case of IPv4 transfers.
As I understand it, the demonstrated need for IPv4 resources under the APNIC Transfer policy is evaluated according to the criteria contained in the IPv4 policy Section 3.1 - 3.5.
These are the pre-final /8 policies we are all familiar with. That is, 80% utilisation with a one year window. http://www.apnic.net/policy/add-manage-policy#delegations
While the relationship between the Transfer policy and the criteria in IPv4 policy is not explicit, in my opinion it would require a change in policy to justify APNIC changing this operational practice.
Otherwise, it would be difficult for the Secretariat to refuse an applicaiton for transfer approval that demonstrated a need for the resources over a 15 year timeframe, or a 100 year timeframe.
I think this would be against the intention of prop-096. http://www.apnic.net/policy/proposals/prop-096
I hope that helps.
Adam
-- Adam Gosling Senior Policy Specialist email: adam@apnic.net APNIC sip: adam@voip.apnic.net http://www.apnic.net phone: +61 7 3858 3100 ________________________________________________________________________ * Sent by email to save paper. Print only if necessary.
On 2/08/12 5:06 PM, Shin SHIRAHATA wrote:
Hi Andy and All,
Proposing policy changes really shouldn't be our first choice for problem resolution. I see no reason why people shouldn't come to this list with a problem statement such as the one Dean suggests:
I agree with your opinion.
Actually, we had the same thought, and we confirmed with APNIC team before the submission.
The response we received was that APNIC secretariat should follow APNIC policy and stick to one year need at this stage. If there is a need to change this, it should be discussed at policy-sig.
This was why we submitted the proposal but we are open to hear if there has been any changes since we last confirmed with APNIC.
Could you follow-up if the change can be done under current policy?
APNIC team
Regards, Shin
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 Dean and all,
Transfer is essentially re-delegation process and the IPv4 policy is quite specific in delegation size based on 1 year need:
"Based on these factors, APNIC and NIRs will delegate address space to meet the LIR's estimated needs for a period up to one year up to the maximum allowed delegation under Section 3. If APNIC or the NIR make a delegation based on a period of less than one year, then they must inform the LIR of the length of the period and the reasons for selecting it."
I don't see ways to accommodate prop-104 need without changing the policy. The needs based transfer evaluation introduced by prop-096 must have boundaries. Otherwise, as per Adam's latest post to the list, people may come with a 15 year or 100 year planning window that would be hard to decline.
Regards, Sanjaya
On 31/07/2012 1:05 PM, Dean Pemberton wrote:
Good Afternoon,
A lot of this policy looks to compare the current APNIC situation with that in other RIRs, I do not believe a difference in itself is a reason to change policy. Just because it is done differently elsewhere, while interesting, should not be a necessary and sufficient condition for policy change within this region.
Therefore the justification for this policy really boils down to:
Furthermore, 12 months is also too short for transfers within the APNIC region considering many xSPs plan their service and their addressing requirements beyond one year.
As with prop-99. I'd like to ask Sanjaya, is there a way to accomodate this situation under the current policies. For example, If a user were able to justify their needs for a two year period, would the hostmasters support a transfer under the current policies.
We can then see if there appears to be a problem.
Kind Regards, Dean
On Friday, August 3, 2012, Sanjaya wrote:
Hi Dean and all,
Transfer is essentially re-delegation process and the IPv4 policy is
quite specific in delegation size based on 1 year need:
"Based on these factors, APNIC and NIRs will delegate address space to
meet the LIR's estimated needs for a period up to one year up to the
maximum allowed delegation under Section 3. If APNIC or the NIR make a
delegation based on a period of less than one year, then they must
inform the LIR of the length of the period and the reasons for selecting
it."
I don't see ways to accommodate prop-104 need without changing the
policy. The needs based transfer evaluation introduced by prop-096 must
have boundaries. Otherwise, as per Adam's latest post to the list,
people may come with a 15 year or 100 year planning window that would be
hard to decline.
Regards,
Sanjaya
On 31/07/2012 1:05 PM, Dean Pemberton wrote:
> Good Afternoon,
>
> A lot of this policy looks to compare the current APNIC situation with
> that in other RIRs, I do not believe a difference in itself is a
> reason to change policy. Just because it is done differently
> elsewhere, while interesting, should not be a necessary and sufficient
> condition for policy change within this region.
>
> Therefore the justification for this policy really boils down to:
>
>> Furthermore, 12 months is also too short for transfers within the APNIC
>> region considering many xSPs plan their service and their addressing
>> requirements beyond one year.
>
> As with prop-99. I'd like to ask Sanjaya, is there a way to
> accomodate this situation under the current policies.
> For example, If a user were able to justify their needs for a two year
> period, would the hostmasters support a transfer under the current
> policies.
>
> We can then see if there appears to be a problem.
>
> Kind 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
--
Regards,
Dean
Thank you Sanjaya for making that clear.For me this boils down to the following questions.1/ Is the current 12 month window sufficient?2/ If not, what should a new window be? 24 months? 5years?Clearly the proposal authors feel that the answers should be No and 24 months. I don't see the evidence to back this up however.I would be interested in hearing from the authors and other members on why the current period is insufficient and why 24 months would solve the problems.RegardsDean
On Friday, August 3, 2012, Sanjaya wrote:Hi Dean and all,
Transfer is essentially re-delegation process and the IPv4 policy is
quite specific in delegation size based on 1 year need:
"Based on these factors, APNIC and NIRs will delegate address space to
meet the LIR's estimated needs for a period up to one year up to the
maximum allowed delegation under Section 3. If APNIC or the NIR make a
delegation based on a period of less than one year, then they must
inform the LIR of the length of the period and the reasons for selecting
it."
I don't see ways to accommodate prop-104 need without changing the
policy. The needs based transfer evaluation introduced by prop-096 must
have boundaries. Otherwise, as per Adam's latest post to the list,
people may come with a 15 year or 100 year planning window that would be
hard to decline.
Regards,
Sanjaya
On 31/07/2012 1:05 PM, Dean Pemberton wrote:
> Good Afternoon,
>
> A lot of this policy looks to compare the current APNIC situation with
> that in other RIRs, I do not believe a difference in itself is a
> reason to change policy. Just because it is done differently
> elsewhere, while interesting, should not be a necessary and sufficient
> condition for policy change within this region.
>
> Therefore the justification for this policy really boils down to:
>
>> Furthermore, 12 months is also too short for transfers within the APNIC
>> region considering many xSPs plan their service and their addressing
>> requirements beyond one year.
>
> As with prop-99. I'd like to ask Sanjaya, is there a way to
> accomodate this situation under the current policies.
> For example, If a user were able to justify their needs for a two year
> period, would the hostmasters support a transfer under the current
> policies.
>
> We can then see if there appears to be a problem.
>
> Kind Regards,
> Dean
* sig-policy: APNIC SIG on resource management policy *
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--
Regards,
Dean
* sig-policy: APNIC SIG on resource management policy *
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Dear SIG members
The proposal "prop-104-v001: Clarifying demonstrated needs requirement
in IPv4 transfer policy' has been sent to the Policy SIG for review.
It will be discussed at the Policy SIG at APNIC 34 in Phnom Penh,
Cambodia, Thursday, 30 August 2012.
We invite you to review and comment on the proposal on the mailing list
before the meeting.
I neither support nor appose the proposal at this stage. In order to make a decision, I would like to hear some more information from the author on the following points.
1) Has the situation that this proposal seeks to correct actually been a problem with a real request? I would like to understand if this is already effecting operational networks, or if we are trying to address an academic difference in RIR allocation policies.
2) What was the rationale towards asking for 24 months as the new period. Why is this any better than 18 or 36 months? I would like to ensure that we're not going to need to change this in the short term due to guessing at this stage.
3) What happens if an RIR adopts a much longer time period, eg 5 years. Does this proposal bind us to blindly follow them, or are we still able to determine our own direction here.
Regards,
Dean
On Wed, Aug 29, 2012 at 2:33 PM, Andy Linton asjl@lpnz.org wrote:
Are there any further comments on this proposal before we discuss this at the Policy SIG meeting tomorrow?
andy
On Mon, Jul 30, 2012 at 8:27 AM, Andy Linton asjl@lpnz.org wrote:
Dear SIG members
The proposal "prop-104-v001: Clarifying demonstrated needs requirement in IPv4 transfer policy' has been sent to the Policy SIG for review.
It will be discussed at the Policy SIG at APNIC 34 in Phnom Penh, Cambodia, Thursday, 30 August 2012.
We invite you to review and comment on the proposal on the mailing list before the meeting.
sig-policy: APNIC SIG on resource management policysig-policy mailing list sig-policy@lists.apnic.net http://mailman.apnic.net/mailman/listinfo/sig-policy
- What was the rationale towards asking for 24 months as the new
period. Why is this any better than 18 or 36 months? I would like to ensure that we're not going to need to change this in the short term due to guessing at this stage.
if i understand yesterday's presentation, it is to match (for some unstated reason), arin's justification window.
i find this strange. are we going to adjust to also match some others' windows? are were going to have a global policy on the window? if we need to coordinate all parameters globally, why do we need rirs?
randy
Agreed, thats why I'd like to understand a bit more about what the demonstrated problem is here. Once I can understand that, I'm in a better position to decide what I think about the proposed solution.
On Wed, Aug 29, 2012 at 2:52 PM, Randy Bush randy@psg.com wrote:
if i understand yesterday's presentation, it is to match (for some unstated reason), arin's justification window.
i find this strange. are we going to adjust to also match some others' windows? are were going to have a global policy on the window? if we need to coordinate all parameters globally, why do we need rirs?
randy
I oppose this policy. I do not believe it is to APNIC's benefit to adopt ARIN's flawed policy.
Owen
On Aug 28, 2012, at 19:55 , Dean Pemberton dean@deanpemberton.com wrote:
Agreed, thats why I'd like to understand a bit more about what the demonstrated problem is here. Once I can understand that, I'm in a better position to decide what I think about the proposed solution.
On Wed, Aug 29, 2012 at 2:52 PM, Randy Bush randy@psg.com wrote:
if i understand yesterday's presentation, it is to match (for some unstated reason), arin's justification window.
i find this strange. are we going to adjust to also match some others' windows? are were going to have a global policy on the window? if we need to coordinate all parameters globally, why do we need rirs?
randy
-- 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
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