Re: [sig-policy] prop-104-v001: Clarifying demonstrated needs requiremen
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
> 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.
> * sig-policy: APNIC SIG on resource management policy *
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--
Regards,
Dean