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

  • To: Philip Smith <pfs at cisco dot com>
  • Subject: Re: [sig-policy] prop-050: IPv4 address transfers
  • From: Geoff Huston <gih at apnic dot net>
  • Date: Fri, 27 Jul 2007 03:23:38 +1000
  • Cc: sig-policy at apnic dot net
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    • Philip,
      Working on the principle that what is written in the proposal would be
      adopted if the policy was to be adopted and what is not written in the
      proposal would not change if the policy was not to be adopted, then the
      direct answer to your question is that this proposal does not propose inter-RIR transfers, as it refers only to registration of IPv4 address transfers between APNIC current account holders.
      I am unsure of the mechanics of a policy proposal that addresses aspects of inter-RIR IPv4 address transfers, but one guess is that this might take the form of a coordinated policy across the RIRs. I am more confident in asserting that this particular policy proposal is not such a proposal, as it refers quite specifically to IPv4 addresses and current APNIC account holders.
      Philip Smith wrote:
      Hi Geoff,
      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
      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)?
      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:
      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
      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.
           - 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)
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