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

[Philip Smith <pfs@cisco.com>]

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
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@apnic.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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