[sig-policy] InternetNZ position on prop-105-v001: Distribution of retur
InternetNZ position on
prop-105-v001: Distribution of returned IPv4 address blocks
(Modification of prop-088)
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Authors: Dean Pemberton dean at internetnz dot net dot nz
1. Executive Summary
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Prop-105 highlight the fact that under current APNIC policy, any
future IPv4 address resources made available via IANA (or any other
mechanism) would be subject to allocation purely based on the
guidelines within the ‘last /8’ policy (prop-088). Prop-105 suggests
that, based on the demonstrated need for IPv4 addresses (citing that
70% of the respondents to a recent survey expressed a need to receive
additional IPv4 address space), any additional APNIC allocations
should be handled outside prop-088 guidelines.
The central issue prop-105 has with the prop-088 guidelines is that
once an APNIC member has applied to recieve a blocst /8 (currently a
/22), they are not eligible for any additional address space.
Prop-105 seeks to amend prop-088 to allow members to receive a single
block from 103/8 (the last /8) in additional to a single block from
any space which APNIC might receive subsequently.
In assessing whether InternetNZ will support, oppose, or adopt a
position of neutrality on a particular policy proposal, three
questions are considered.
1. Does this policy seek to address a well defined, well accepted problem?
2. Will the solutions outlined within the proposal effectively
mitigate the stated problem?
3. Does the policy proposal fit with InternetNZ policy principles?
After consideration of the questions above, InternetNZ:
1. believes that even though there is a demonstrated demand for IPv4
addresses, it does not accept that a situation exists whereby changes
are required to prop-088 for APNIC to cater for additional IPv4
resources from IANA.
2. does not believe that allowing APNIC members to receive additional
allocations from small blocks received from IANA will make a material
difference to the demand for IPv4 addressing.
3. believes that the proposal has the potential to send the wrong
message with regard to the importance of IPv6 adoption as opposed to
continued IPv4 deployment.
4. This policy proposal does not fit within several of InternetNZ
policy principles, namely those of: Working with the architecture of
the Internet and focusing on technical activity.
As such InternetNZ opposes the adoption of APNIC prop-105 as presented
in version 001.
2. Does this policy seek to address a well-defined, well-accepted problem?
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Prop-105 states:
“While rapid implementation of IPv6 is in progress throughout the
APNIC region, demands for IPv4 address still continue. According to
our survey conducted to the APNIC community, over 70% of the
respondents expressed the needs to receive IPv4 address space, if a
separate distribution policy is defined from the final /8 policy.
In May 2012, the global policy “Global Policy for Post Exhaustion:
IPv4 Allocation Mechanisms by the IANA” was ratified by ICANN board,
and it will be implemented soon. Based on this policy, IPv4 address
space returned to IANA will be distributed to RIRs, and its size is
not expected to be so large but substantial enough to be able to
consider an additional minimum allocation for APNIC members.”
The APNIC secretariat states that they have so far pre-approved 43
requests, for a total space of 1,717,504 IP addresses (this equates to
roughly just over half a /12 worth of address space). The study cited
in prop-105, coupled with the stats from the APNIC secretariat clearly
demonstrates a demand for IPv4 resources, what is unclear however, is
if a situation will ever exist under which this policy will become
relevant. It can be effectively argued that it is uncertain if IANA
will ever allocate a meaningful amount of additional IPv4 address
space to APNIC for LIR allocation. In the absence of that occurring,
this problem this policy seeks to solve would not exist.
As such, InternetNZ accepts that there is a demonstrated demand for
IPv4 addresses, but does not accept that a situation exists whereby
changes are required to prop-088 for APNIC to cater for additional
IPv4 resources from IANA.
3. Will the solutions outlined within the proposal effectively
mitigate the stated problem?
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Prop-105 presents the following as a solution to the the perceived problem:
“Modify prop-088 to distribute non-103 IPv4 address blocks to APNIC
account holders who meet the IPv4 distribution criteria define in
APNIC policies.
If APNIC account holder, who was allocated an /22 from final /8 pool,
needs an additional IPv4 address block, they are eligible to receive
another distribution of IPv4 block.
The same policy as the final /8 policy will be applied in terms of the
criteria and the size of the distribution given the requestor has
utilized a total of /22 block from 103/8.”
This is assumed to mean that APNIC members are free to obtain a /22
from 103/8 as well as an additional /22 from any subsequent block of
IPv4 addresses that APNIC might obtain from IANA (or other
mechanisms). While at a high level this might appear to be a solution
to the stated problem, it does not accurately present itself as a
standalone policy, nor does it reference the parts of prop-88 which
would need to change, nor any suggested replacement text.
Prop-105 also neglects to define conditions such as the minimum size
of additional allocation under which this policy would be enacted.
The ICANN policy referred to by the author states:
“The purpose of the proposal is to enable ICANN, as the IANA Functions
Operator, to allocate IPv4 blocks returned by the RIRs. ICANN would
place IPv4 blocks returned by the RIRs in a Recovered IPv4 Pool. This
Pool would be declared active when one RIR has less than half its last
/8 left, approximately 8m IPv4 addresses. The IANA Functions Operator
would then allocate an "IPv4 allocation unit" (minimum size /24) to
each RIR, if the Pool size so permits. If the space available in the
Pool is too limited, allocation would be deferred in 6 month intervals
until space is available.”
It is clear from this wording that ICANN envisages small addresses
being handed back to RIRs (evident by the use of a minimum /24 size
reference). If for example APNIC were to receive a /20 from IANA
(equivalent to 4 /22s) it would be hard to see how a change to the
existing prop-088 policy would be justified. If on the other hand
APNIC were to receive an additional /8 from IANA, then there may be a
case to justify allowing members an additional allocation from this
block.
While all these are technical possibilities, InternetNZ in defining
its position must take into account the probability of each event
occurring. While it is impossible to predict the future, InternetNZ
feels that it is far more likely that a number of small (<= /20)
blocks, if any, will be made available from IANA rather than any
significantly large blocks (<= /16).
It should also be noted that it was the intent of prop-088 that an
APNIC member’s allocation from the last /8 be used to facilitate
adoption of and transition to IPv6. It was not intended to be used
for day to day operational purposes.
As such, InternetNZ does not believe that allowing APNIC members to
receive additional allocations from small blocks received from IANA
will make a material difference to the demand for IPv4 addressing.
InternetNZ also believes that it has the potential to send the wrong
message with regard to the importance of IPv6 adoption as opposed to
continued IPv4 deployment.
4. Does the policy proposal fit within InternetNZ policy principles?
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A set of eight policy principles[1] underpin the work of InternetNZ
and help ensure that our approach to Internet-related public and
technical policy is transparent and predictable. Internally, the
principles guide the development of policy positions and statements.
Externally, they explain the basis of InternetNZ’s views to our
stakeholders and to the general public. Any proposal that InternetNZ
takes a position on is evaluated against these principles. Five of the
eight principles apply with respect to prop-105. They are the
following:
** Principle No. 2 Internet markets should be competitive. **
Allowing existing APNIC members to receive additional allocations from
subsequent IANA allocations will reduce the ability of new entrants to
receive initial allocations under the existing prop-088 framework.
While this is a possibility, the amount of address space envisaged to
be allocated by IANA is expected to be so small as for this effect to
be considered minor.
As such InternetNZ believes that this policy will have a negligible
impact on the competition within the Internet market.
** Principle No. 3. Internet governance should be determined by open,
multi-stakeholder processes. **
APNIC has an open, multi-stakeholder policy development process. This
proposal does nothing to alter that.
** Principle No. 4. Laws and policies should work with the
architecture of the Internet, not against it. **
InternetNZ believes that the future of Internet deployment is with
IPv6. Anything which artificially prolongs the life of IPv4 at the
expense of wide scale IPv6 adoption is seen to be acting against the
architecture of the Internet. The intent of prop-088 was that an
APNIC member’s allocation from the last /8 was to be used to
facilitate adoption of and transition to IPv6.
As such InternetNZ believes that this proposal acts against the
architecture of the Internet, by prolonging members reliance on IPv4
resources.
** Principle No. 6 The Internet should be accessible by and inclusive
of everyone. **
InternetNZ accepts that in order to ensure that the Internet is
accessible to and inclusive of everyone that APNIC members require
access to IPv4 resources while they transition to using IPv6. It is
our position however that this access is already catered for under the
existing prop-088 mechanism.
If a situation exists under which a member requires additional IPv4
resources, then this can be accomplished through existing APNIC
address transfer mechanisms and the growing IPv4 marketplace.
As such, InternetNZ does not believe that the adoption of this
proposal is required to ensure the accessibility of the Internet.
** Principle No. 7. Technology changes quickly, so laws and policies
should focus on activity. **
InternetNZ accepts that there is a current demand for IPv4 addresses,
it believes however that the appropriate mechanism for the fulfilment
of this demand is:
1. Allocation of a final /22 from the last /8 as per prop-088 guidelines.
2. Timely adoption of IPv6 delivered services
3. Any additional IPv4 resources sourced through existing transfer
policies and recorded accurately in the APNIC database.
5. Summary
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After consideration the questions above, InternetNZ:
1. believes that even though there is a demonstrated demand for IPv4
addresses, it does not accept that a situation exists whereby changes
are required to prop-088 for APNIC to cater for additional IPv4
resources from IANA.
2. does not believe that allowing APNIC members to receive additional
allocations from small blocks received from IANA will make a material
difference to the demand for IPv4 addressing.
3. believes that the proposal has the potential to send the wrong
message with regard to the importance of IPv6 adoption as opposed to
continued IPv4 deployment.
4. This policy proposal does not fit within several of InternetNZ
policy principles, namely those of: Working with the architecture of
the Internet and focusing on technical activity.
As such InternetNZ opposes the adoption of APNIC prop-105 as presented
in version 001.
Dean Pemberton
Policy Advisor
InternetNZ
dean at internetnz dot net dot nz
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[1] https://internetnz.net.nz/content/Policy-Principles