[sig-policy] New proposal - prop-157-v001: Temporary IPv4 Transfers
Dear SIG members, A new proposal "prop-157-v001: Temporary IPv4 Transfers" has been sent to the Policy SIG for review. It will be presented at the Open Policy Meeting (OPM) at APNIC 57 on Thursday, 29 February 2024. https://2024.apricot.net/program/program/#/day/9/ We invite you to review and comment on the proposal on the mailing list before the OPM. The comment period on the mailing list before the OPM is an important part of the Policy Development Process (PDP). We encourage you to express your views on the proposal: - Do you support or oppose this proposal? - Does this proposal solve a problem you are experiencing? If so, tell the community about your situation. - Do you see any disadvantages in this proposal? - Is there anything in the proposal that is not clear? - What changes could be made to this proposal to make it more effective? Information about this proposal is appended below as well as available at: http://www.apnic.net/policy/proposals/prop-157 Regards, Bertrand, Shaila, and Anupam APNIC Policy SIG Chairs --- prop-157-v001: Temporary IPv4 Transfers Proposer: Jordi Palet Martinez (jordi.pa...@theipv6company.com) 1. Problem statement When in the community we discuss the need for leasing, understood broadly in any of its possible modalities, as one of the mechanisms to facilitate small sets of IPv4 addresses for the transition to IPv6, specially for new actors, there are mixed feelings about accepting the leasing or not. However, we are forgetting that there is already a mechanism, already accepted by the community, that could be slightly modified to be equivalent to a leasing, and yet have many advantages for both parties: temporary transfers. It is about guaranteeing compliance with the policies with a system equivalent to leasing, and that makes it easier to avoid security problems, keeping the control by the RIR/NIR, and the security of the return of the addresses when the leasing period concludes. At the same time, it seeks to cover the need to be flexible without excessive operational burden for the RIR/NIR, so that the leasing period can be simply extended, since it is understood that there may be situations in which the initially agreed period may be insufficient. It is important to emphasize that those who need these transfers, as a “leasing”, tend to be smaller entities or with more moderate initial investments and consequently are financially weaker. Therefore, given that the ultimate goal must be the deployment of IPv6, using IPv6-only and IPv4aaS, the number of IPv4 addresses that may be needed will be truly reduced. Finally, it seeks to prioritize the benefit of the region and therefore it makes sense that it is only applicable to operations carried out within the region. Furthermore, this prevents permanent transfers from losing reciprocity with those regions that require it. The EC could establish specific rates for this type of transfers and/or their extensions. 2. Objective of policy change - APNIC current policies only allow permanent IPv4 address transfers. This proposal specifies a change in the policy to allow temporary transfers. 3. Situation in other regions - As far as we know, only in RIPE NCC temporary transfers are allowed. At the same time, RIPE NCC does not contemplate leasing, but it does not explicitly prohibit it either. In AFRINIC and LACNIC, neither leasing nor temporary transfers are contemplated. However, an equivalent proposal has been submitted in LACNIC. Temporary transfers are not contemplated in ARIN, and leasing is not a valid justification of the need. When leasing addresses, no more addresses can be requested. Additionally, certain blocks cannot be leased. 4. Proposed policy solution --- Actual text: 11.0. IPv4 transfers APNIC will maintain a public log of all number resource (IPv4, IPv6, ASN) transfers, including unused (market) transfer, merger and acquisitions, and historical resource transfer. 11.1. IPv4 transfers within the APNIC region APNIC will process and record IPv4 address transfer requests between current APNIC account holders subject to the following conditions. 11.1.1. Conditions on the space to be transferred The minimum transfer size is a /24. The address block must be: • In the range of addresses administered by APNIC • 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. • Addresses delegated from the 103/8 free pool cannot be transferred for a minimum of five years after the original delegation. 11.1.3. Conditions on recipient of the transfer The recipient will be subject to current APNIC policies.
[sig-policy] Re: APNIC EC Endorses Proposal from APNIC 56
Thanks Chris, appreciate your replies. I won't give it comment line-by-line though it gives me far more insight. Take what the SIG feels has value from what I've sent, disregard the rest! Many thanks, Luke On 14/12/2023 10:13 am, Christopher Hawker wrote: Hi Luke, See comments in-line. I am not adequately versed in the nuances of what makes the EC's last-minute decision something permissible, yet don't feel like what's taken place this week re: prop-155 demonstrates a properly functional process. prop-155 reached consensus and was endorsed, so the 'work is done' there if not then amended by APNIC EC as they have done I wouldn't consider their decision on fees as a last-minute decision, as it's within their powers. The determination of fees charged is beyond the scope of the Policy SIG, which was acknowledged by Aftab and Simon in the policy proposal that they had submitted. As members of the Policy SIG, we can only make recommendations as to how the EC should decide, it's on them to make the final decision regarding fees. which triggers a need/case for the endorsement to become somewhat null and void, and for discussions to recommence (ie. at least partially restart the process), in the hope a similar change is not again done at the 11th hour by the EC alone. This seems quite a failure of the policy development process. I agree that the decision to charge the fees they have with the exception of the discount renders this policy (in my view) redundant. In my view the policy doesn't need to come back to the list for further discussion as it sought consensus twice (at the OPM and then the AMM) which demonstrated support from the community, the EC need to make a decision regarding a permanent reduction in fees for IPv6 PI space. 1. Speaking of policy, in this case how does the EC's "The EC has also decided to waive..." fit in? I see no ground for it in Step 5[1]. Can this be done pre-/post-endorsement? It feels like going behind the backs of SIG-Policy members despite the intentions likely being positive within APNIC's EC. Fees for services provided and resources assigned/allocated is outside the scope of the Policy SIG, and in turn, not included as part of the PDP. 2. If there is technically no valid route to the amendment they've applied after the fact (in the way it's been done), how can that be handled except/in-addition-to returning it to the list for further discussions? They did not amend the policy. Again, fees are beyond the scope of the Policy SIG and PDP. Are there other cases where the EC has made a change like this at such a stage? To my knowledge, no. To that end, is there a trend? Again, no. Should there not be safety nets which means approved-prop=approved-prop? The policy was not amended, and endorsed as-is in line with what is in-scope of the Policy SIG and PDP. It seems very strange that a presumably-well-defined process can become unstuck in this way, as it undermines a lot of the time and effort invested by SIG members and the community more broadly. Again, the in-scope content of the policy was endorsed as written. While yes, the decision to only issue an initial fee-waiver for the first 12 months does make this policy redundant, it is within the scope of the policy process. 4. By-law reforms have been completed thanks to major community efforts - the instigator was told it would be impossible but alas no. Karl deserves to never have to pay for another drink again, due to his significant involvement in advocating to get this across the line :) One of the key provisions is to ensure that APNIC is a well-protected entity. Fee waiving does not seem to align with a NIC's goals. Why was it done here? To encourage IPv6? Who in particular agreed together within the EC/APNIC to make the 11th hour change, and based on what? I am of the view that the fee waiver is in-line with APNIC's Vision, Mission and Objectives (https://www.apnic.net/about-apnic/organization/vision-mission-objectives/) in attempting to promote the active development and usage of IPv6 Address Space. This wasn't an 11th-hour change, rather it was made at the correct time of implementing a policy. 5. Do we have enough of a divide between the SIG/s and the EC, as implied by Aftab I don't see this in Aftab's response. to invite further direct discussions to this end, attempting to get the EC on the same page more generally? I do believe that some form of fee needs to be charged as APNIC do incur costs with providing services. Perhaps a solution would be to consult with the community regarding new fee implementation prior to making a decision? Shorter version: Should this example lead to procedural/policy changes to prevent a recurrence? Potentially this would require a rework of the PDP, in order for the EC to hold a discussion with the author so they can ensure they understand it as written. 6. With the APNIC EC members sworn into
[sig-policy] Re: APNIC EC Endorses Proposal from APNIC 56
Hi Luke, See comments in-line. > I am not adequately versed in the nuances of what makes the EC's last-minute > decision something permissible, yet don't feel like what's taken place this > week re: prop-155 demonstrates a properly functional process. > prop-155 reached consensus and was endorsed, so the 'work is done' there if > not then amended by APNIC EC as they have done I wouldn't consider their decision on fees as a last-minute decision, as it's within their powers. The determination of fees charged is beyond the scope of the Policy SIG, which was acknowledged by Aftab and Simon in the policy proposal that they had submitted. As members of the Policy SIG, we can only make recommendations as to how the EC should decide, it's on them to make the final decision regarding fees. > which triggers a need/case for the endorsement to become somewhat null and > void, and for discussions to recommence (ie. at least partially restart the > process), in the hope a similar change is not again done at the 11th hour by > the EC alone. This seems quite a failure of the policy development process. I agree that the decision to charge the fees they have with the exception of the discount renders this policy (in my view) redundant. In my view the policy doesn't need to come back to the list for further discussion as it sought consensus twice (at the OPM and then the AMM) which demonstrated support from the community, the EC need to make a decision regarding a permanent reduction in fees for IPv6 PI space. > 1. Speaking of policy, in this case how does the EC's "The EC has also > decided to waive..." fit in? I see no ground for it in Step 5[1]. Can this be > done pre-/post-endorsement? It feels like going behind the backs of > SIG-Policy members despite the intentions likely being positive within > APNIC's EC. Fees for services provided and resources assigned/allocated is outside the scope of the Policy SIG, and in turn, not included as part of the PDP. > 2. If there is technically no valid route to the amendment they've applied > after the fact (in the way it's been done), how can that be handled > except/in-addition-to returning it to the list for further discussions? They did not amend the policy. Again, fees are beyond the scope of the Policy SIG and PDP. > Are there other cases where the EC has made a change like this at such a > stage? To my knowledge, no. > To that end, is there a trend? Again, no. > Should there not be safety nets which means approved-prop=approved-prop? The policy was not amended, and endorsed as-is in line with what is in-scope of the Policy SIG and PDP. > It seems very strange that a presumably-well-defined process can become > unstuck in this way, as it undermines a lot of the time and effort invested > by SIG members and the community more broadly. Again, the in-scope content of the policy was endorsed as written. While yes, the decision to only issue an initial fee-waiver for the first 12 months does make this policy redundant, it is within the scope of the policy process. > 4. By-law reforms have been completed thanks to major community efforts - the > instigator was told it would be impossible but alas no. Karl deserves to never have to pay for another drink again, due to his significant involvement in advocating to get this across the line :) > One of the key provisions is to ensure that APNIC is a well-protected entity. > Fee waiving does not seem to align with a NIC's goals. Why was it done here? > To encourage IPv6? Who in particular agreed together within the EC/APNIC to > make the 11th hour change, and based on what? I am of the view that the fee waiver is in-line with APNIC's Vision, Mission and Objectives (https://www.apnic.net/about-apnic/organization/vision-mission-objectives/) in attempting to promote the active development and usage of IPv6 Address Space. This wasn't an 11th-hour change, rather it was made at the correct time of implementing a policy. > 5. Do we have enough of a divide between the SIG/s and the EC, as implied by > Aftab I don't see this in Aftab's response. > to invite further direct discussions to this end, attempting to get the EC on > the same page more generally? I do believe that some form of fee needs to be charged as APNIC do incur costs with providing services. Perhaps a solution would be to consult with the community regarding new fee implementation prior to making a decision? > Shorter version: Should this example lead to procedural/policy changes to > prevent a recurrence? Potentially this would require a rework of the PDP, in order for the EC to hold a discussion with the author so they can ensure they understand it as written. > 6. With the APNIC EC members sworn into confidentiality via formal NDA, not > permitted to record conversations[2], and unable to share any EC information > without express permission, it seems there is somewhat of a silo which should > be okay
[sig-policy] Re: APNIC EC Endorses Proposal from APNIC 56
Hi, This all seems quite disappointing, when it should have been quite positive. SIG-Policy was 'that close' it seems, and I'd like to dig into how such a change is possible. Being candid, I am not adequately versed in the nuances of what makes the EC's last-minute decision something permissible, yet don't feel like what's taken place this week re: prop-155 demonstrates a properly functional process. My understanding of what's happened up to here: /prop-155 reached consensus and was endorsed, so the 'work is done' there if not then amended by APNIC EC as they have done - which triggers a need/case for the endorsement to become somewhat null and void, and for discussions to recommence (ie. at least partially restart the process), in the hope a similar change is not again done at the 11th hour by the EC alone. This seems quite a failure of the policy development process./ Some multi-pronged queries/perspectives around this: 1. Speaking of policy, in this case how does the EC's /"The EC has also decided to waive..."/ fit in? I see no ground for it in Step 5[1]. Can this be done pre-/post-endorsement? It feels like going behind the backs of SIG-Policy members despite the intentions likely being positive within APNIC's EC. 2. If there is technically no valid route to the amendment they've applied after the fact (in the way it's been done), how can that be handled except/in-addition-to returning it to the list for further discussions? 3. Are there other cases where the EC has made a change like this at such a stage? To that end, is there a trend? Should there not be safety nets which means approved-prop=approved-prop? It seems very strange that a presumably-well-defined process can become unstuck in this way, as it undermines a lot of the time and effort invested by SIG members and the community more broadly. 4. By-law reforms have been completed thanks to major community efforts - the instigator was told it would be impossible but alas no. One of the key provisions is to ensure that APNIC is a well-protected entity. Fee waiving does not seem to align with a NIC's goals. Why was it done here? To encourage IPv6? Who in particular agreed together within the EC/APNIC to make the 11th hour change, and based on what? 5. Do we have enough of a divide between the SIG/s and the EC, as implied by Aftab, to invite further direct discussions to this end, attempting to get the EC on the same page more generally? Shorter version: Should this example lead to procedural/policy changes to prevent a recurrence? 6. With the APNIC EC members sworn into confidentiality via formal NDA, not permitted to record conversations[2], and unable to share any EC information without express permission, it seems there is somewhat of a silo which /should/ be okay if processes are strongly & clearly defined. Are members of this SIG comfortable with the existing structure, communication and transparency? If not, what would you change and why? 7. Reviewing at high-level the Policy Development Process (APNIC-111-v003), it seems there is insufficient clarity and explanation within, most notably while there appears to be no provision for the last-minute EC-authored changes, there is similarly no specific restriction otherwise either. Does the SIG view this as an opportunity to separately move to strengthen this document, to eliminate any gaps which could be mis-used? Is the SIG comfortable this is a once-off? The EC is obviously comfortable enough with their last-minute amendments per their wording below which implies that prop-155 as-amended will steam ahead. SIG-Policy has said no to that, however at a glance this entire case seems improper and not explicitly OK. However, I lack sufficient knowledge and history in this space to make concrete statements, hence my broad requests for clarity, and long-winded email which attempts to decipher what appears to be the elephant in the room. /"The EC has also decided to waive the fees on IPv6 PI assignments under this policy..."/ /"The Secretariat will begin the implementation process and inform the community as soon as it is completed."/ Which seems to reinforce the need for more oversight/policy in these edge cases, as otherwise it seems the processes for APNIC SIGs may be undermined in cases where the EC deems it appropriate, even where the clearly-defined process has not led to the same determinations. Just like with the by-law reforms, it seems this eventuality has highlighted some potentially glaring issues that should be tightened up to avoid a repeat? At the moment, it seems there are 8 people[3] on the Executive Council, and I'd imagine a change like this requires majority. So hopefully more insights can be shared not just into the questions posed, but also more generally into how the SIGs can expect the EC to interact with them into the future - with a view towards more transparency & accountability, and sharing any
[sig-policy] Re: APNIC EC Endorses Proposal from APNIC 56
I too, agree with Aftab, and strongly urge that the EC reconsiders the fees for IPv6 PI space. The idea to this policy was to increase and incentivise the uptake of IPv6. By charging the same costs as other delegations, it effectively renders this entire policy proposal redundant as there is no benefit for providers to apply for a PI assignment under this policy other than that of a $680.00 one-time discount. Putting aside the financial aspect (as much as possible), we need to support and encourage the uptake of IPv6. This decision does not encourage, promote or incentivise its adoption. Regards, Christopher Hawker ___ SIG-policy - https://mailman.apnic.net/sig-policy@lists.apnic.net/ To unsubscribe send an email to sig-policy-le...@lists.apnic.net
