[apnic-talk] Address Policy SIG paper
Attached below is a draft paper on "The future of ISP confederations
- a proposal to permanently suspend the formation of new ISP
confederations".
This paper is being circulated in preparation for the upcoming
Address Policy SIG at the APNIC meeting. This paper will shortly be
available on the APNIC meeting web site, along with all other meeting
documents at:
http://www.apnic.net/meetings
Comments and discussion on this list are very welcome.
Regards,
Anne
Manager, Member Services
APNIC
----
DRAFT
Problem definition
The future of ISP confederations - a proposal to permanently suspend
the formation of new ISP confederations
This proposal in this paper is twofold. First, that new procedures are
applied to the management framework for existing ISP confederations; and
second, that no new ISP confederations be created (in other words, this
paper proposes that the suspension of new confederations memberships should
be extended indefinitely for ISP confederations).
1. Background
The ISP confederation structure arose in response to the globalisation of
ISP networks through mergers and acquisitions - where an ISP network may
span many countries. The resulting very large ISPs demonstrated a need to
maintain independent network address allocation pools, and they were
allowed to do this through the adoption of confederation memberships (which
were originally designed to serve National NICs, now known as NIRs). ISP
confederations have operated along the same administrative lines as NIR
confederations, even though the specific characteristics of the NIR and ISP
confederations are actually very different.
Multiple independent allocations within a single APNIC membership are not
ordinarily permitted due to significant additional administrative
complexity which they impose. Normal APNIC members are therefore required
to manage their allocated address space as a single pool, and only request
more addresses when 80% of their allocation has been consumed. If
independent allocations are required, the organisation is now advised to
take out multiple memberships, which clearly delineates the separate
allocations.
2. Motivation
In practice, the current ISP confederation framework does not consistently
apply APNIC policies across the APNIC membership, resulting in a lack of
accountability by the ISP confederations. Moreover there are also different
implementations of the model across the ISP confederation membership which
significantly increase the complexity of management.
In December 1998 the APNIC Executive Council supported the decision to
suspend the formation of any new confederations. Almost two years has
elapsed from the time of that decision and APNIC is now seeking feedback
from the community on a specific proposal to resolve this issue.
Note: At the time of the EC decision, the term 'confederation' applied both
to the National Internet Registries (organisations that serve the ISP
community within a particular country), and to ISP Confederations (whose
'membership' is defined by the structure of the ISP itself). This document
is concerned only with the case of the ISP confederations.
3. Current status (including other RIRs)
The following summary analysis compares the procedural framework applied to
ordinary LIR APNIC members and members of ISP confederations and highlights
the significant differences.
Other RIRs (RIPE NCC and ARIN) have no confederation category within their
membership structures, so their policies are not detailed here.
3.1 ISP Address Request Form
Each direct LIR APNIC member must complete an 'ISP Address Request' form
(APNIC-065) in detail when requesting an address allocation. This is
evaluated carefully by the APNIC hostmasters.
Under the current model for ISP confederations, the head office of the
confederation is intended to assume the role of the registry, similar to
that of APNIC. However there is no formal requirement for the confederation
members to complete APNIC-065 when requesting address space, and moreover
infrastructure descriptions are not required on the current APNIC
Confederation request form. As a result infrastructure requirements go
largely undocumented throughout the entire allocation process.
3.2 Assignment and Allocation Windows
APNIC applies an 'assignment window' mechanism and second-opinion process
to LIR members, in order to objectively measure the understanding and
application of assignment policies and procedures by the member. For new
members the assignment window starts at zero (and therefore applies to all
customer assignments), and it is increased progressively as experience is
gained.
APNIC is also currently developing a corresponding "allocation window"
mechanism by which NIR allocations to NIR members may also be subject to
second-opinion approval by APNIC. This has been agreed by all NIR members,
and is being progressively introduced.
The ISP confederation model today does not involve a second-opinion process
of any kind, which allows no objective measure or verification of policy
adherance by the confederation. In any case this process by its nature
assumes that the requestor is independent from the registry, and that the
registry is neutral and impartial. Neither is the case for ISP confederations.
3.3 Establishing new memberships
ISP confederations are currently able to establish new memberships as they
please, and with each membership the ability to create an additional
independently managed address pool.
New memberships of the ISP confederations should be established under the
same criteria as those applied to APNIC LIR members.
3.4 Initial allocations to members
Initial allocations to new members should be consistent with policies
decided by the APNIC community. APNIC applies the 'slow start' policy
whereby new members receive the minimum practical allocation. Currently
this is a /20.
4. Discussion
APNIC is currently discussing the above policy issues with ISP
confederation members, with a view to implementing changes. However, there
are currently five ISP confederations, each with different topological
considerations, which make the consistent and equitable application of
policies and procedures a complex management task.
While the ISP confederation model allows each ISP confederation to obtain
independent address allocations for each member, this can also be easily
achieved by establishing separate memberships with APNIC.
5. Recommendations
APNIC recommends that the ISP confederation membership category be
suspended, but that the existing ISP confederations be given the choice to
either convert to multiple memberships or to remain as they are.
If they choose to remain as ISP confederations, they will be asked to work
with APNIC to modify their procedures to implement the assignment and
allocation window systems with the objective of ensuring a more consistent
and fair application of APNIC policies. This will be done on a case by case
basis, but with an eventual aim to bring all confederations into line with
a consistent policy framework.
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