prop-165: Provision of IPv4 Address Space to IPv6-only Networks for Transitional Purpose

This proposal aims to enable organizations eligible for IPv6 Provider Aggregatable (PA) address space to request and receive a limited IPv4 allocation, specifically a /24 block. This is intended to support the deployment of IPv6-only networks that still require minimal IPv4 resources for transitional purposes, such as DNS resolution.

Tomohiro Fujisaki and Hiroki Kawabata

1. APNIC’s Understanding of the Proposed Policy

This Proposed Policy is unclear due to terminology used in the proposal not being consistent with the 2.0 Definitions. APNIC does not use the terms PA (Provider Aggregatable) and PI (Provider Independent) for resource holdings and such terms do not have exact equivalents in APNIC-127.

The Secretariat has interpreted the intent of the Proposed Policy as being to allow resource holders with IPv6 only address allocations to be able to obtain a /24 IPv4 for transition purposes, without requiring any further justification of need as is ordinarily required for IPv4 under section 6.2 of APNIC-127. The Secretariat understands that the Authors believe the burden of proof for these networks might be too high under current policy.

2. Impact of Proposed Policy on Registry and Addressing System

The Secretariat notes that resource holders with IPv6 only address allocations are eligible to receive an IPv4 allocation under existing policy, provided the relevant needs justification is met.

However, the Secretariat is unable to assess the impact of the Proposal on the Registry and Addressing System based on the Proposed Policy wording.

The Secretariat has the following questions in relation to the Proposed Policy for which clarification is requested:

• “Organizations qualifying for IPv6 PA allocations may request an IPv4 /24.”

  • Will this /24 count toward the resource holder’s last /8 holding?
    If so, can they also apply for their second /24 under regular IPv4 policy as the maximum delegation size for IPv4 is currently /23.

• “The IPv4 block must be used only for IPv6-only network support.”

  • How should the Secretariat monitor if their IPv4 is being used to support their IPv6-only network and not being used for some other purpose?

• “The block is non-transferable and cannot be leased.”

  • How should the Secretariat monitor if the address is being leased?

• “Additional usage restrictions apply in accordance with current APNIC policies.”

  • Which specific existing usage restrictions are intended to apply? Most existing usage restrictions are based on the needs justification required under section 6.2 of APNIC-127 which appears to be intended not to apply under the Proposed Policy wording.

3. Impact of Proposed Policy on APNIC Operation/Services

Additional work would be required on APNIC core registry back-end and front-end systems to allow for the delegation of these addresses.

Additional changes to APNIC’s operating procedures will be required to account for exceptions to standing policy, including with respect to reduced demonstrated need (section 6.2 of APNIC-127) and modified transfer restriction period (section 11 of APNIC-127).

4. Legal Impact of Proposed Policy

The Proposed Policy will require a number of amendments to APNIC-127, however the specific implementation of such changes has not been made clear by the Authors. This uncertainty may create a number of enforcement and assessment challenges depending on its implementation, which can be considered further following clarification of the Secretariat’s questions in Part 2 of this Impact Analysis.

5. Implementation

The Secretariat is unable to confirm the extent of the implication impact on APNIC systems and operations at this time until further clarification is provided in response to the questions in Part 2 of this Impact Analysis.