Re: [sig-policy]Proposal prop-014-v001.txt - Lowering minimum allocation

  • To: <sig-policy at apnic dot net>, "Anne Lord" <anne at apnic dot net>
  • Subject: Re: [sig-policy]Proposal prop-014-v001.txt - Lowering minimum allocation size and criteria
  • From: "Thu Thuy" <thuthuy at vnnic dot net dot vn>
  • Date: Wed, 28 Jan 2004 16:54:43 +0700
  • Cc: <sig-nir at lists dot apnic dot net>
  • List-archive: <>
  • List-help: <>
  • List-id: APNIC SIG for National Internet Registries (NIRs) <>
  • List-post: <>
  • List-subscribe: <>,<>
  • List-unsubscribe: <>,<>
  • References: <>
  • Sender:
      Through SIG and NIR mailing list, VNNIC already stated our community's
      viewpoint on the lowering minimum allocation size. As this proposal now
      officially be posted for the wide comments, we would like to say again our
      comments which is reflect demands and desires of Internet operation entities
      in Viet Nam:
          * We support this proposal of APNIC Secretariat.
      Up to now, there are 13 ISPs in Vietnam. Of these, only 6 strong ones had
      portable address allocation from APNIC. The remains use un-portable address
      space from 6 ISPs above. Most of  these dependent ISPs now have been
      quatified to be initially allocated. They will request for portable
      allocation some day. However, along with this, they must renumber their
      network. It clearly is a disadvantage that present policy acts on them.
      According to the direction of Vietnamese Government on Telecommunications
      development, up to 2005, there would be 40 licensed ISPs. So lowering the
      size and losen the criteria of minimum allocation is desires of Internet
      Community in Viet Nam.
          * If we only losen the criteria but not reduce the minimum allocation
      size, we will waste addresses. According to APNIC's figure, more than half
      (51%) of all APNIC members have held a single allocation for longer than one
      year. We would like to emphasize that it is under present policy. Once we
      losen the criteria of obtaining initial allocation, the amount of similar
      entities will be significantly larger.
          * At last, we have a small suggestions: The proposal should tighten the
      criteria of portable assignment to get rid of unhonest PI. It should be "
      Portable assignment is only for end-user. ISPs are forced to apply for
      portable allocation".
      Best regards,
      Thu Thuy.
      ----- Original Message ----- 
      From: "Anne Lord" <anne at apnic dot net>
      To: <sig-policy at apnic dot net>
      Sent: Monday, January 19, 2004 9:41 AM
      Subject: [sig-policy]Proposal prop-014-v001.txt - Lowering minimum
      allocation size and criteria
      Dear colleagues,
      Attached below is a proposal for the upcoming APNIC Open Policy
      Meeting in KL, Malaysia. It is being circulated one month before
      the meeting to give time for feedback.
      The proposal can also be found at:
      Your comments on this proposal are greatly appreciated and should
      be sent to this mailing list.
      Best wishes,
      A proposal to lower the IPv4 minimum allocation size and initial
      allocation criteria in the Asia Pacific region [prop-014-v001.txt]
      Proposed by: APNIC Secretariat
      Version:     draft 1.0
      Date:        January 2004
      1 Summary and motivation
      For more than 10 years, the RIR system has applied initial allocation
      criteria and a minimum size for IPv4 address allocations to Local
      Internet Registries (LIRs). This is done to limit address space
      fragmentation and encourage aggregation and it ensures that only ISPs
      with sufficiently large address needs are able to receive portable
      address space.
      The size of the minimum allocation in the APNIC region has changed
      previously in response to concerns and the consensus of the community.
      In late 2000, the APNIC community approved a proposal to lower the
      minimum allocation from /19 to /20.
      In December 2001, the APNIC community approved new criteria for
      initial allocations. Those criteria are consistent with the /20
      minimum allocation and include (among others) a requirement to have
      used a /22 from an upstream provider and a plan to use a /21 within
      a year.
      Nevertheless, members of the APNIC community have expressed concern
      that the barrier to entry remains too high, preventing many smaller
      ISPs from obtaining portable address space.
      This document proposes lowering the minimum allocation size and
      initial allocation criteria, in the interests of fairness and equity
      of access to addresses.
      Further, many in the community have argued that the goal of
      aggregation has reduced in importance in recent years, due to
      developments in router technology and routing protocol. It is argued
      that it is now possible to sustain reasonable growth in the
      Internet's routing tables without performance or stability problems.
      Please note that the minimum allocation size and the initial
      allocation criteria affect only the first allocation made to an ISP.
      Changing either of these factors would have no impact on the size of
      subsequent allocations.
      2 Background and problem
      The APNIC Secretariat receives feedback from members and the wider AP
      community through channels including training events, the helpdesk
      and hostmaster services, and seminars and workshops.  Consistently,
      small ISPs express concern at the difficulty of obtaining address
      space from APNIC under current policies.
      As noted above, under current policies, to be eligible for an initial
      /20 allocation, an ISP must (among other requirements):
          - have used a /22 from their upstream provider or demonstrate an
            immediate need for a /22;
          - demonstrate a detailed plan for use of a /21 within a year.
      This proposal adopts a quantitative approach to analyse the impact of
      the current policies by comparing the number of APNIC members (ISPs
      which have qualified to receive portable address space) with the
      number of ISPs actually operating in various economies of the region.
      The total number of APNIC members broken down by economy (excluding
      NIRs) is shown below.  (Note that the totals here also include
      associate members and members who have received portable assignments).
      AU 195
      HK 110
      IN 104
      PH 48
      JP 44
      SG 44
      NZ 37
      PK 34
      TH 33
      MY 31
      CN 30
      AP 29
      BD 25
      TW 25
      Other 84
      The total number of ISPs operating in an economy can be obtained where
      a licensing or registration regime is in place, or where other survey
      data is available.  The following countries were examined.
        India (104 APNIC members)
        Data for India obtained at
        shows that for 39 A, B, and C licenses issued, 191 ISPs had started
        business as of August 2003[1]. APNIC has 104 members in India. It
        can be concluded that approximately half of the ISPs operating in
        India have not obtained portable address space allocations from
        Hong Kong (110 APNIC members)
        it states that in Hong Kong, there were 216 licensed ISPs in August
        2003 (there are many more ISPs which are not licensed). Of these, 110
        are APNIC members. Again approximately half of the ISPs in Hong Kong
        have not obtained portable address space allocations from APNIC.
        Australia (195 APNIC members)
        In Australia, 964 ISPs are registered with the Telecommunications
        Industry Ombudsman ( and 195 of these are
        registered APNIC members.
        Indonesia (96 APJII members)
        According to information supplied by APJII, the NIR for Indonesia,
        there are two types of ISP licence in Indonesia: 'initial' and
        'secondary' licences. Both are required before an ISP can operate.
        The 'secondary' licence requires portable address space from APNIC.
        According to the Department of Post and Telecommunications, 83 ISPs
        hold initial licences only. These ISPs do not have any portable
        address space. A further 96 ISPs are operating with both initial and
        secondary ISP licences. Therefore, just under half of Indonesian
        ISPs have not obtained portable allocations from APNIC.
      3 Other RIRs
      3.1 RIPE NCC
      In the RIPE region, following consensus at RIPE 46, from 1 January
      2004, the minimum allocation size was lowered from a /20 to a /21.
      Further, it is no longer necessary to demonstrate efficient
      utilisation of a /22 to request an initial allocation.
      The motivation for the proposal was that it was difficult or
      impossible for many start-up LIRs to get a PA allocation. As explained
      in the proposal:
          "..startup LIRs that do not already hold address space cannot get
          an initial PA allocation (which would be a /20 as of today, or
          bigger), because in many cases, they cannot demonstrate immediate
          need, or prior utilization of sufficient address space."
      3.2 ARIN
      The ARIN community has made no change to the /20 minimum allocation
      size. However, at ARIN XII, there was consensus on changing the
      multihomed networks policy as follows:
          "Multi-homed organizations may justify and obtain a block of
          address space with prefix length extending to /22 directly from
          ARIN. When prefixes are longer than /20, these micro-allocations
          or micro-assignments will be from a reserved block for that
      Although there was no change to the minimum allocation size, the
      multihoming policy now allows smaller allocations to be made, to a
      minimum of /22.
      The ARIN community also reached consensus on allowing an exception for
      organisations located in the AFRINIC region, which now have a minimum
      allocation of /22.
      3.3 LACNIC
      The minimum allocation size is a /20.
      4 Discussion
      4.1 Lowering the minimum allocation size and initial allocation
      A possible response to concerns about the barrier to entry for small
      ISPs is to lower the minimum allocation size and initial allocation
      criteria. The following discussion considers the effect of lowering
      the minimum allocation size from a /20 to a /21.
      Of a total of 734 current open APNIC members, 468 (63%) of those have
      received one allocation only. Further, of those 468 members, 378 have
      had their allocation for longer than one year. In other words, more
      than half (51%) of all APNIC members have held a single allocation for
      longer than one year, without returning to APNIC for additional
      address space.
      4.2 Impact on routing tables
      Lowering the barrier to entry would have some impact on the size of
      the routing tables. The number of discrete allocations will be
      increased as more entities are able to receive portable prefixes.
      However, it is argued that the impact to the routing table will not be
      significant. The survey of ISP numbers in a number of economies in the
      region (see section 2 above) indicates that the total number of
      additional allocations at the /21 level would number in the hundreds,
      and the incremental impact on the global routing table, currently
      carrying some 130,000 entries, would be negligible.
      This conclusion is based upon data analysis of the 3 December 2003
      routing table report[2] which shows that /19 prefixes account for 6%
      of the global routing table, /20 prefixes account for 7%, whereas /24s
      account for almost 55%. Policy changes in recent years (in particular
      the move from a /19 to a /20) have not resulted in significant changes
      to this profile. The largest factor contributing to routing table
      growth remains the advertisement of /24 prefixes, either from legacy
      allocated space or from more specific prefixes of portable space.
      4.3 Impact on conservation
      Recent research work[3] (which extrapolated allocation practices and
      demand, using an exponential growth model derived from the best of
      2000-2003 data) concluded that RIRs could continue making IPv4
      allocations on the current basis for the next two decades.
      There are many factors that could affect this prediction. Changes in
      RIR allocation policies are one such factor. However, analysis
      suggests that this policy impact is not highly significant. For
      instance, global rates of RIR consumption have been: 4.47 /8s per year
      in 2000; 5.47 /8s per year in 2001; and 3.08 /8s per year in 2002.
      During this preiod the minimum allocation was changed from a /19 to a
      /20 in all regions.
      Based on this previous experience of the effect of policy change on
      address consumption, the current proposal is not expected to conflict
      with the RIR goal of conservation.
      4.4 Impact on RIR operations
      A lower minimum allocation would require some changes to RIR
      hostmaster operations. Specifically, to be able to support contiguous
      allocations, hostmasters would need to reserve address space for a
      longer period. Currently, reservations are held for 12 months,
      extending to 15 months in some cases.
      4.5 Impact to NIRs
      It is anticipated that the NIRs will conduct their Open Policy
      Meetings with a view to adopting a consistent minimum allocation size
      and allocation criteria.
      5 Proposal
      It is proposed that the current size of the minimum allocation should
      be lowered from a /20 to a /21. It is also proposed that the
      respective criteria for an initial allocation should be amended such
      that the LIR must:
          - have used a /23 from their upstream provider or demonstrate an
            immediate need for a /23; and
          - demonstrate a detailed plan for use of a /22 within a year;
      All other aspects of the policy would remain unchanged.
      6 Implementation
      If consensus is reached, it is proposed to implement this policy three
      months after the policy has been approved by the APNIC Executive
      Council (EC).
      Notes and references
      1 ISPs are not the only type of organisation who become APNIC members
        and receive allocations of portable address space.
      2 The Routing Table report is archived at
      3 IPv4 Address Lifetime Expectancy - 2003, Geoff Huston
      *              sig-policy:  APNIC SIG on resource management policy
      sig-policy mailing list
      sig-policy at lists dot apnic dot net