Re: [sig-policy] Revised version: prop-100 National IP Address Plan - Al

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  • Subject: Re: [sig-policy] Revised version: prop-100 National IP Address Plan - Allocation of country-wide IP address blocks
  • From: Mark Tinka <mtinka at globaltransit dot net>
  • Date: Thu, 1 Sep 2011 11:37:44 +0800
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    • 
      > I said yesterday that a revised version of the proposal 
      > was being worked on. Can we keep our discussions to this 
      > version please?
      
      Thanks, Andy.
      
      I'll take a slightly different angle...
      
      > For the implementation of the above policy decisions many
      > discussions were held with service providers and
      > organizations in which they were of the opinion that
      > there should be proper address planning for different
      > organizations within the economy. So taking cue from
      > this, Government of India (Department of
      > Telecommunications) set up a committee for formulation
      > of a National IPv6 address policy.
      
      I do find it interesting that the government are taking an 
      interest in the address planning habits of the service 
      providers.
      
      > In the 2nd meeting of the committee held on 18th July
      > 2011 in New Delhi, members were of the opinion that
      > India as a whole should request for the reservation of a
      > suitably-sized block of IPv6 addresses from APNIC. This
      > block can be allocated to different organizations by
      > keeping in view the long term planning perspective.
      > 
      > So it was decided that this issue should be taken up with
      > APNIC.  As this was a policy related issue, and other
      > economies in the APNIC region may also have similar
      > needs, therefore, the proposal was put up to APNIC for
      > address block reservation at the economy level for
      > subsequent allocation to different organizations within
      > the economies in the APNIC region.
      
      Okay.
      
      >     (a) Contiguous address block allocation is not
      > ensured by APNIC when an organization goes back to APNIC
      > for further allocation (reapplying after more than one
      > year)
      > 
      >     (b) Non provision of address space for future
      > organizations in economies who are not in a position (or
      > not aware) to ask for addresses at present.
      > 
      > APNIC policy does not currently allow address blocks to
      > be allocated at the economy level, so through this
      > proposal, we are seeking a change in the policy for
      > reservation of adequate IPv6 address space economy wise
      > for further allocation to different organizations and
      > stakeholders within the economy.
      
      I still think that this is a need that can be satisfied at 
      the NIR level.
      
      > 3. Situation in other RIRs
      > --------------------------
      > 
      > No other RIRs presently have a program to assess the
      > needs of individual economies in their region and
      > reserve appropriately-sized address blocks. However,
      > economies in other RIRs may have similar needs and a
      > similar program of assessment may be appropriate.
      
      I think that resource needs assessment is a task handled 
      best by the operators at the micro level (which includes 
      address planning), and respective governments at the macro 
      level.
      
      I fear that if APNIC got involved in assessing the needs of 
      every individual economy in the Asia Pacific region, it 
      would be substantially administrative. Would the data 
      gathered be useful? Certainly. But keeping it up-to-date 
      (not the mention the process of gathering and confirming 
      it), I think, should not be the burden of an RIR. That's 
      what operators and special interest groups at the government 
      and private sector level tend to normally do.
      
      > 4. Details
      > ----------
      > 
      > In the current policy framework of APNIC, addresses are
      > allocated to different organizations in different
      > economies when they are able to demonstrate their need
      > for those addresses and they apply for them. However, in
      > this process two requirements, mentioned in summary
      > above, are not taken into consideration. In the era of
      > IPv4, when the addresses were in severe shortage, such a
      > demonstrated need policy was relevant but in the  era of
      > IPv6 it is not.
      
      I'm with Randy when I say that we once thought 32-bits for 
      IPv4 was more than enough. History has always been a good 
      teacher, but I digress...
      
      Given the current minimum allocations for IPv6, and the 
      opportunities for LIR's/NIR's to indicate how much address 
      space they really need for their operations/members, I find 
      the current needs-based policy still suitable for IPv6; more 
      so because it can be used to extend just about the right 
      amount of IPv6 address space to an NIR that it thinks 
      members in its community would sufficiently need for a given 
      time period.
      
      > IPv6 addresses are in abundance and their planning and
      > distribution is also at a very nascent stage. The main
      > objective of this proposal is to ensure that all
      > economies (and the different present and future
      > organizations in those economies) can ensure they will
      > get a suitable share of the IPv6 address space, in one
      > or more large contiguous blocks, whether they need it
      > now or at a later date. This will also help different
      > organizations in different economies to plan their
      > networks in a more effective manner as they will have a
      > reasonably fair idea of the IPv6 address space
      > allocation in future.
      
      It is not always guaranteed that APNIC or an NIR will always 
      allocate from a contiguous block. Fragmentation will always 
      be likely as take-up increases, although, I'm sure, better 
      algorithms at the NIR or RIR level would be welcome.
      
      > (A) Analysis and Projection of Requirements
      > 
      > Each economy in the APNIC region is different in terms of
      > population, population growth rate, GDP growth rate,
      > mobile, internet and broadband penetration growth rate,
      > social requirements etc. There could be many other
      > factors, which could be taken into consideration. These
      > factors would help to make an aggregate estimate of the
      > present and future IPv6 address requirements of all
      > organizations and stakeholders in each economy.  The
      > analysis of each economy in the APNIC region could be
      > conducted in one of the following ways -
      > 
      > 1. By APNIC, since it has more experience across
      > different economies and different RIRs.
      
      I still think that trying to get APNIC to do this work is 
      simply outside of scope. Yes, APNIC - as to other RIR's - do 
      go around conducting IPv6 awareness and training, but it 
      would be wise not to confuse this programme with that of 
      country-level address requirement projections.
      
      > 2. Alternatively, a representative body in each economy,
      > which could be the government of that economy or a
      > prominent industry association or any other recognised
      > body, may be approached by APNIC for estimating the
      > needs of that economy. However, in this case APNIC may
      > need to\ conduct awareness programmes for their
      > education and sufficient time is also required for
      > making such estimation.
      
      Sounds a lot like an NIR to me.
      
      > 3. Any other suitable mechanism deemed fit by APNIC for
      > doing such estimation.
      
      Given how fragile the data would be, not to mention how 
      "open to interpretation" it might end up becoming, it is 
      very easy for APNIC to miss the mark, and either over-do or 
      under-do.
      
      When LIR's or NIR's go to request address space from APNIC, 
      there is little or no ambiguity in the amount of address 
      space that is needed. I think this is a quality that would 
      be much harder to implement when considerations at the 
      country level have to be made by APNIC.
      
      I would say that NIR's working with APNIC on this would be 
      far more appropriate, if not accurate.
      
      >    Through these analysis and projection estimates,
      > economy wise IPv6 address requirement (based on the
      > requirements of different organizations and
      > stakeholders) will emerge. This process will definitely
      > take some time.
      
      I cannot speak for APNIC, but I'm not sure it's time they 
      have (as this kind of data is never static or easy to come 
      by when one considers true verification requirements). Of 
      course, I could certainly be wrong.
      
      > (B) Reservation of the IPv6 address space for different
      > economies (for their organizations and stakeholders) by
      > APNIC
      > 
      > Based on the above projections and estimates, APNIC may
      > keep one or more suitably sized blocks reserved for
      > different economies for ultimate use of organizations
      > and stakeholders of those economies. APNIC may also keep
      > some large blocks unreserved, i.e. not reserved for any
      > economy in the beginning, for any sudden unforeseen
      > requirements in future.
      > 
      > The allocation of addresses from these reserved blocks to
      > organizations and stakeholders in different economies
      > may be done directly by APNIC or through an NIR
      > (wherever existing) as it is doing at present.
      > Ultimately these addresses will be allocated to
      > individual organizations / stakeholders and not to the
      > economy.  As an example, in case of India, after some
      > discussions with service providers, internet
      > associations and other stakeholders, an estimate of
      > current and future requirements of a /16 block,
      > initially, has been suggested. However, the firm
      > requirement has to be deliberated based upon a detailed
      > study as suggested above.
      > 
      > Detailed operational issues for implementing this policy,
      > if approved, will have to be deliberated upon
      > separately.
      
      While I do not entirely support the idea of reservations 
      based on certain metrics that define an economy and its 
      needs, I would be open to an administrative arrangement 
      between APNIC and NIR based on the specific data that NIR 
      can provide to APNIC.
      
      > 5. Pros/Cons
      > ------------
      > 
      > Advantages:
      > 
      > 1. The various IPv6 awareness programmes for different
      > economies, the various studies for estimation of needs
      > of different economies and management of the reserved
      > IPv6 blocks as mentioned above will no doubt increase
      > the job of APNIC in the immediate future, but over a
      > long period of time, this would prove to be very
      > beneficial for IPv6 deployment and also make the job of
      > APNIC easier since APNIC would be very clear on what
      > future allocations it can make.
      
      Yes, the amount of data that will be collected by APNIC 
      would be very useful. But I believe it would be a resource 
      duplication as operators, who are the actual folks on the 
      ground assigning addresses to customers and taking feedback 
      on what customers want for the future, already know this 
      information.
      
      This information comes to APNIC during the (additional) 
      address application process, informally through policy or 
      operational mailing list discussions, and during meetings 
      such as APRICOT, APNIC, e.t.c. So the information is already 
      there - for APNIC to go and look for it again within all 
      economies in the Asia Pacific region, I think, is noble but 
      too administrative.
      
      > 2. The economies and their organizations will also
      > benefit since they will have a fair idea of what they
      > will get in future and they can plan accordingly for the
      > long term for IPv6 deployment.
      
      There is the danger that new entrants in an economy that 
      received an allocation from APNIC are unhappy because a 
      smaller % of the existing ISP's ate up the majority of the 
      chunk that had previously been provided, assuming Prop-100 
      passed.
      
      What I'm saying is that it's difficult to offer any 
      guarantees, especially as the policy becomes operational. 
      It's just as difficult at the regional level as it would be 
      at the national level.
      
      A service provider's ability to detail their needs to APNIC 
      or an NIR is, I think, far more flexible and free of assumed 
      prejudice.
      
      > Disadvantages:
      > 
      > 1. There may be short term workload/financial
      > implications for APNIC for analysis and projection
      > studies, training and awareness etc. These however,
      > should not be a constraint because otherwise also APNIC
      > has to work for IPv6 awareness and its deployment in all
      > economies in APNIC region.
      
      This, in my books, is a really huge disadvantage for the 
      amount of benefit gained; again, considering this data is 
      already available in some way or form.
      
      I think a lot of the other disadvantages have already been 
      highlighted by some of the list members.
      
      > 6. Effect on APNIC
      > ------------------
      > 
      > 1. It would prove to be very beneficial for IPv6
      > deployment and also make the job of APNIC easier since
      > APNIC would be very clear on what future allocations it
      > can make.
      
      Again, I can't speak for APNIC, but I think this would be 
      too much work, especially if APNIC want to implement 
      controls to ensure fair play from both sides.
      
      > 2. Address allocation will be more organized and orderly.
      
      This cannot be guaranteed. IPv4 as taught us that, despite 
      the vastness of IPv6.
      
      > 7. Effect on NIRs
      > -----------------
      > 
      > NIRs can allocate IP addresses to individual members in
      > its geographical area from the reserved blocks as per
      > the actual projections of individual members.
      
      This is what I support - APNIC allocates address space to an 
      NIR that will, then, deal with local members within the 
      constraints of a given economy.
      
      However, I think it is feasible to assume that some members 
      may choose to bypass the NIR and apply for allocations 
      directly from APNIC. I think that's not all bad, provided 
      records are accurate.
      
      Cheers,
      
      Mark.
      

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