Re: [sig-policy] prop-050: IPv4 address transfers

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  • Subject: Re: [sig-policy] prop-050: IPv4 address transfers
  • From: Philip Smith <pfs at cisco dot com>
  • Date: Thu, 26 Jul 2007 18:01:45 +1000
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    • 
      I support this policy proposal in principle, given that it will be
      pretty inevitable that LIRs will start "transferring" IPv4 address space
      between each other as IPv4 becomes a marketable "asset" in the next few
      years.
      
      I've one question though.
      
      How will transfers inter-RIR be handled? The policy proposal doesn't
      address it that I can see, but I can imagine that this situation could
      well come about too. Would this need to be another proposal (and if so
      it might be worth mentioning that inter-RIR transfers are not part of
      this policy proposal)?
      
      philip
      --
      
      Toshiyuki Hosaka said the following on 26/7/07 15:23:
      > Dear SIG members
      > 
      > The proposal "IPv4 address transfers" has been sent to the Policy SIG
      > for review. It will be presented at the Policy SIG at APNIC 24 in
      > New Delhi, India, 29 August - 7 September 2007.
      > 
      > I invite you all to review the proposal below and send comments to the
      > mailing list before APNIC 24.
      > 
      > The proposal's history can be found at:
      > 
      >           http://www.apnic.net/policy/proposals/prop-050-v001.html
      > 
      > Regards,
      > Toshi
      > ---
      > Toshiyuki Hosaka
      > Policy SIG Chair
      > 
      > 
      > ________________________________________________________________________
      > 
      > prop-050-v001: IPv4 address transfers
      > ________________________________________________________________________
      > 
      > 
      > 
      > Author:    Geoff Huston
      >             gih at apnic dot net
      > 
      > Version:   1
      > 
      > Date:      26 July 2007
      > 
      > 
      > 
      > 1.  Introduction
      > ----------------
      > 
      > This is a proposal to remove APNIC policy restrictions on the transfer
      > of registration of IPv4 address allocations and IPv4 portable address
      > assignments between current APNIC account holders. This proposal is a
      > refinement of the historical resource transfer policy and applies to
      > IPv4 resources held by current APNIC account holders.
      > 
      > 
      > 2.  Summary of current problem
      > ------------------------------
      > 
      > Current APNIC policies relating to the registration of transfer of
      > address holdings limit the eligibility of registration of transfers to
      > those relating to mergers and acquisitions of entities that are
      > administering an operational network.
      > 
      > It is currently anticipated that the IPv4 unallocated address pool
      > will be exhausted in a timeframe of between 2009 and 2011. There is a
      > very considerable level of investment in IPv4-based services in the
      > Asia Pacific region, and a transition to IPv6-based service delivery
      > is likely to take longer than the remaining period of unallocated
      > address availability. Accordingly, it is likely that demand for IPv4
      > addresses will continue beyond the time of unallocated address pool
      > exhaustion, leading to a period of movement of IPv4 address blocks
      > between address holders to meet such continuing demand for IPv4
      > address blocks.
      > 
      > It is the objective of the APNIC IPv4 address registry to accurately
      > record current address distribution information.
      > 
      > This proposal advocates that APNIC recognise the transfer of IPv4
      > addresses between current APNIC account holders, and places some
      > constraints on the parties to the transfer as a precondition for the
      > registration of the IPv4 address transfer to be undertaken by APNIC.
      > 
      > 
      > 3.   Situation in other RIRs
      > ----------------------------
      > 
      > It is the understanding of the proposer that no comparable IPv4
      > resource transfer policy between account holders has been adopted in
      > any other RIR.
      > 
      > 
      > 4.   Details of the proposal
      > ----------------------------
      > 
      > APNIC will process IPv4 address transfer requests following the
      > adoption of this proposed policy, subject to the following conditions:
      > 
      > Conditions on the IPv4 address block:
      > 
      >      - Only IPv4 address blocks equal to, or larger than, a /24 prefix
      >        may be transferred.
      > 
      >      - The address block must be in the range of addresses administered
      >        by APNIC, either as part of a /8 address block assigned by the
      >        IANA to APNIC, or as part of a historically-assigned address
      >        block now administered by APNIC.
      > 
      >      - The address block must be allocated or assigned to a current
      >        APNIC account holder.
      > 
      >      - The address block will be subject to all current APNIC policies
      >        from the time of transfer. This includes address blocks
      >        previously considered to be "historical".
      > 
      > 
      > Conditions on source of the transfer:
      > 
      >      - The source entity must be a current APNIC account holder.
      > 
      >      - The source entity must be the currently registered holder of the
      >        IPv4 address resources, and not be involved in any dispute as to
      >        the status of those resources.
      > 
      >      - The source entity will be ineligible to receive any further IPv4
      >        address allocations or assignments from APNIC for a period of 24
      >        months after the transfer.
      > 
      >      - In making any future IPv4 address resource requests to APNIC,
      >        for as long as IPv4 address resources are available from APNIC,
      >        following the expiration of this 24 month ineligibility
      >        period, the source will be required to document the reasons for
      >        the IPv4 address resource allocation.
      > 
      > 
      > Conditions on recipient of the transfer:
      > 
      >      - The recipient entity must be a current APNIC account holder.
      > 
      >      - The recipient entity of the transferred resources will be
      >        subject to current APNIC policies. In particular, in any
      >        subsequent APNIC IPv4 address allocation request, the recipient
      >        will be required to account for all IPv4 address space held,
      >        including all transferred resources.
      > 
      >      - APNIC fees payable by the recipient will be assessed on the
      >        basis of all resources held.
      > 
      > 
      > The address transfer process:
      > 
      >      After APNIC is notified of the transfer by both the source and the
      >      recipient of the transfer:
      > 
      >      1. APNIC will update the registration records relating to the
      >         transferred addresses.
      > 
      >      2. APNIC will adjust the source's address holdings as of the date
      >         of transfer.
      > 
      >         In terms of membership and/or service fee calculations this
      >         shall be processed in the same manner as a return of address
      >         holdings to APNIC as of that date.
      > 
      >      3. APNIC will adjust the recipient's address holdings to include
      >         the transferred addresses as of the date of the transfer.
      > 
      >         In terms of membership and/or service fee calculations this
      >         shall be processed in the same manner as an allocation or
      >         assignment of address holdings to the recipient as of that date.
      > 
      >      4. The following transfer details will be published by APNIC in a
      >         public log of resource transfers:
      > 
      >         - Source
      >         - Recipient
      >         - Address resources
      >         - Date of transfer
      > 
      > 
      > Transfer fees:
      > 
      >      APNIC may charge the recipient a service fee on the transfer
      >      transaction. The transfer service fee may vary according to the
      >      total size of the address block being transferred.
      > 
      >      The transfer fee schedule shall be set initially by the APNIC
      >      Executive Council upon adoption of this policy.  The transfer fee
      >      schedule will be included as part of any future review of APNIC
      >      fees and charges.
      > 
      > 
      > 5.   Advantages and disadvantages of the proposal
      > -------------------------------------------------
      > 
      > Advantages:
      > 
      > This proposal would:
      > 
      >      - Ensure that the APNIC registry continues to reflect the current
      >        actual status of IPv4 resource holdings by APNIC account holders.
      > 
      >      - Mitigate the risks to the integrity of the network and its
      >        routing and addressing infrastructure associated with the
      >        unregistered transfers of IPv4 addresses. This proposal, by
      >        acknowledging the existence of address transfers and registering
      >        the outcomes would ensure that the APNIC address registry
      >        continues to maintain accurate data about resources and resource
      >        holders. The proposal also ensures that those parties who
      >        currently rely on the accuracy of this registration information
      >        can continue to rely on the currency and accuracy of this
      >        information in good faith.
      > 
      >      - Provide a stronger incentive for unused IPv4 address space to
      >        return to active use, helping to satisfy residual demand for IPv4
      >        address space across the IPv6 transition.
      > 
      > 
      > Disadvantages:
      > 
      >      - Concerns have been raised about a market-based system emerging
      >        as the only means to obtain IPv4 address space in future, and
      >        the potential for certain forms of market failures, including
      >        the possibility of hoarding, speculation and price manipulation.
      > 
      >        A number of factors mitigate these risks. As the transition to
      >        IPv6 gathers pace, a market-based value of IPv4 addresses would
      >        fall in line with the decreasing value proposition of IPv4-based
      >        services in an increasing IPv6 network. An additional constraint
      >        would apply if this policy were to be adopted while IPv4
      >        addresses are still available from APNIC, as APNIC's established
      >        IPv4 address allocation process would continue to provide an
      >        alternative source of supply of IPv4 addresses to the industry.
      > 
      > 
      > 6.   Effect on APNIC members
      > ----------------------------
      > 
      > APNIC members will have the ability to register the transfer of IPv4
      > address resources between APNIC account holders.
      > 
      > 
      > 7.   Effect on NIRs
      > -------------------
      > 
      > This policy does not encompass IPv4 address holdings administered by
      > NIRs, nor the transfer of resources where the source or recipient are
      > NIR-serviced entities.
      > 
      > (end of document)
      > *              sig-policy:  APNIC SIG on resource management policy           *
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