Re: [sig-policy] prop-123-v001: Modify 103/8 IPv4 transfer policy

[George Kuo]

Hi Skeeve and all,

Ahead of the upcoming policy SIG, I'd like to share more info about how 
APNIC secretariat evaluates M & A requests. As part of our due diligence 
check, we have the procedure to verify the

authenticity of the M & A request documentations received. Circumstances
where it's obvious to APNIC that the transaction is fraudulent or
fabricated, to the best of our knowledge, APNIC will reject the transfer
request and terminate membership as per the Membership agreement.

M & A can take many forms and it's difficult for APNIC to be the sole
arbitrator to judge the motivations behind and decide if it is in good
or bad faith.

thanks

George

On 1/2/18 2:42 am, Skeeve Stevens wrote:

Agreed.  I do agree that there needs to be some protections to avoid
abuse of the last /8 resources, but, there seems to be a policy failure
elsewhere in APNIC in relation to the evaluation of M which is
allowing abusive transactions to occur.


...Skeeve

*Skeeve Stevens - Founder & The Architect* - eintellego Networks
(Cambodia) Pte Ltd.
Email: ske...@eintellegonetworks.asia
 ; Web: eintellegonetworks.asia


Cell +61 (0)414 753 383 ; Skype: skeeve

Facebook: eintellegonetworks  ;
Twitter: eintellego 

LinkedIn: /in/skeeve
 ; Expert360: Profile
 ; Keybase: https://keybase.io/skeeve


Elastic Fabrics - Elastic Engineers - Elastic ISPs - Elastic Enterprises


On Mon, Jan 29, 2018 at 4:52 PM, Rajesh Panwala
> wrote:

I partially support the policy. For genuine M cases , there should
not be any restriction on transfer of resources. M activities are
part and parcel of routine business and no one knows when will it
take place.

regards,

Rajesh Panwala
For Smartlink Solutions Pvt. Ltd.
+91-9227886001

On Fri, Jan 26, 2018 at 8:57 AM, Bertrand Cherrier
> wrote:

Dear SIG members,

The proposal "prop-123-v001: Modify 103/8 IPv4 transfer policy" has
been sent to the Policy SIG for review.

It will be presented at the Open Policy Meeting at APNIC 45 in
Kathmandu, Nepal on Tuesday, 27 February 2018.

We invite you to review and comment on the proposal on the
mailing list
before the meeting.

The comment period on the mailing list before an APNIC meeting is an
important part of the policy development process. 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 available at:

   http://www.apnic.net/policy/proposals/prop-123


Regards

Sumon, Bertrand, Ching-Heng
APNIC Policy SIG Chairs

https://www.apnic.net/wp-content/uploads/2018/01/prop-123-v001.txt


---

prop-123-v001: Modify 103/8 IPv4 transfer policy

---

Proposer:Alex Yang
 yang...@126.com 


1. Problem statement
---

Policy Proposal prop-116-v006: Prohibit to transfer IPv4 addresses in
the final /8 block reached consensus at the APNIC 44 AMM on 14 Sep
2017. Since that APNIC has stopped all the IPv4 transfers from 103/8
block if the delegation date is less than 5 years.

However, some of the 103/8 ranges were delegated before 14 Sep 2017.
Those resources should not be subjected to 5 years restriction. The
community was not aware of the restriction when they received those
resources, some of the resources have been transferred or planning to
transfer. If APNIC is not allow those transfers to be registered,
there will be underground transfers. This will cause incorrect APNIC
Whois data.


2. Objective of policy change
---

To keep the APNIC Whois data correct.


3. Situation in other regions
---

No such situation in 

Re: [sig-policy] [Sig-policy] prop-118: No need policy in APNIC region, to be dis cussed at APNIC 44 Policy SIG

[George Kuo]

Hi Aftab,

Thanks for your patience. I now have more information for you.

Total number of IPv4 market transfers that did not get completed in the 
last 12 months is 97.


Below is the breakdown of reasons:
Fraud:   4
Recipient could not demonstrate needs:   1
Recipient did not accept transfer:   6
Requests corrected as M transfer: 23
No response from member:30
Member requested to cancel transfer:33

As far as administration of these requests is concerned, it's just part 
of hostmasters routines required by the APNIC policy.



George


On 18/8/17 6:48 pm, George Kuo wrote:

Hi Aftab,

For 2017, the secretariat has processed 158 market transfers as of 15
August. So, this is roughly about 5 transfer requests a week.
On average, it takes about 4-5 responses from APNIC hostmasters to
complete a transfer request. We have a procedure to respond to a
correspondence within two working days.

We are getting the rest of the answers for you. I'll come back to you as
soon as I have the information.

thanks,

George


On 18/8/17 3:29 pm, Aftab Siddiqui wrote:

Dear APNIC Sec,

Can you share some stats:

- How many transfers request denied in last 12 months?
- How many requests were denied just because of bad documentation?
- How many transfer request you are receiving every week?
- How long does it take to process a transfer request?
- Does it create any administrative burden?

On Wed, 9 Aug 2017 at 16:14 chku <c...@twnic.net.tw
<mailto:c...@twnic.net.tw>> wrote:

Dear SIG members

The proposal "prop-118: No need policy in APNIC region" was
discussed at
APNIC 43 Policy SIG, but did not reach consensus.

It will be presented at the Open Policy Meeting at APNIC 44 which
will
be held in Taichung, Taiwan on Wednesday and Thursday, 14 & 15
September
2017.

Information about the proposal is available from:

http://www.apnic.net/policy/proposals/prop-118

You are encouraged to express your views on the proposal:

 - Do you support or oppose the proposal?
 - 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?

Please find the text of the proposal below.

Kind Regards,

Sumon, Bertrand, Ching-Heng
APNIC Policy SIG Chairs


---

prop-118-v001: No need policy in APNIC region

---

Proposer:   David Hilario
d.hila...@laruscloudservice.net
<mailto:d.hila...@laruscloudservice.net>


1. Problem statement
---

Whenever a transfer of IPv4 is taking place within the APNIC
region, the
recipient needs to demonstrate the "need" for the IPv4 space they
intend
to transfer.

Companies transferring IPv4 space to their pool do this in ordcer to
enable further growth in their network, since the space is not coming
from the free public pool, regular policies that are intended to
protect
the limited pool of IPv4 space can be removed in transfers.


2. Objective of policy change
---

Simplify transfer of IPv4 space between resource holders.
Ease some administration on APNIC staff.


3. Situation in other regions
---

RIPE region has an all around no need policy in IPv4, even for first
allocation, transfers do not require the recipient to demonstrate
their
intended use of the resources .

ARIN, need base for both transfers and resources issued by ARIN.

AFRINIC, need based policy on transfers (not active yet) and resource
request from AFRINIC based on needs.

LACNIC, no transfers, need based request.

Out of all these RIR, only ARIN and RIPE NCC have inter-RIR transfer
policies,  ARIN has made clear in the past that the "no need" policy
from the RIPE region would break inter-RIR transfers from ARIN to
RIPE
region.


4. Proposed policy solution
---

Simply copy the RIPE policy to solve the ARIN transfer
incompatibility:

 - APNIC shall accept all transfers of Internet number resources
to its
   service region, provided that they comply with the policies
relating
   to transfers within its service region.

 - For transfers from RIR regions that require the receiving
region to
   have needs-based policies, recipients must provide a plan to the
   APNIC for the use of at least 50% of the transferred resources
within
   5 years.

source:
https://www.ripe.net/publicatio

Re: [sig-policy] [Sig-policy] prop-118: No need policy in APNIC region, to be dis cussed at APNIC 44 Policy SIG

[George Kuo]

Hi Aftab,

For 2017, the secretariat has processed 158 market transfers as of 15 
August. So, this is roughly about 5 transfer requests a week.
On average, it takes about 4-5 responses from APNIC hostmasters to 
complete a transfer request. We have a procedure to respond to a 
correspondence within two working days.


We are getting the rest of the answers for you. I'll come back to you as 
soon as I have the information.


thanks,

George


On 18/8/17 3:29 pm, Aftab Siddiqui wrote:

Dear APNIC Sec,

Can you share some stats:

- How many transfers request denied in last 12 months?
- How many requests were denied just because of bad documentation?
- How many transfer request you are receiving every week?
- How long does it take to process a transfer request?
- Does it create any administrative burden?

On Wed, 9 Aug 2017 at 16:14 chku > wrote:

Dear SIG members

The proposal "prop-118: No need policy in APNIC region" was discussed at
APNIC 43 Policy SIG, but did not reach consensus.

It will be presented at the Open Policy Meeting at APNIC 44 which will
be held in Taichung, Taiwan on Wednesday and Thursday, 14 & 15 September
2017.

Information about the proposal is available from:

http://www.apnic.net/policy/proposals/prop-118

You are encouraged to express your views on the proposal:

 - Do you support or oppose the proposal?
 - 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?

Please find the text of the proposal below.

Kind Regards,

Sumon, Bertrand, Ching-Heng
APNIC Policy SIG Chairs


---

prop-118-v001: No need policy in APNIC region

---

Proposer:   David Hilario
d.hila...@laruscloudservice.net



1. Problem statement
---

Whenever a transfer of IPv4 is taking place within the APNIC region, the
recipient needs to demonstrate the "need" for the IPv4 space they intend
to transfer.

Companies transferring IPv4 space to their pool do this in ordcer to
enable further growth in their network, since the space is not coming
from the free public pool, regular policies that are intended to protect
the limited pool of IPv4 space can be removed in transfers.


2. Objective of policy change
---

Simplify transfer of IPv4 space between resource holders.
Ease some administration on APNIC staff.


3. Situation in other regions
---

RIPE region has an all around no need policy in IPv4, even for first
allocation, transfers do not require the recipient to demonstrate their
intended use of the resources .

ARIN, need base for both transfers and resources issued by ARIN.

AFRINIC, need based policy on transfers (not active yet) and resource
request from AFRINIC based on needs.

LACNIC, no transfers, need based request.

Out of all these RIR, only ARIN and RIPE NCC have inter-RIR transfer
policies,  ARIN has made clear in the past that the "no need" policy
from the RIPE region would break inter-RIR transfers from ARIN to RIPE
region.


4. Proposed policy solution
---

Simply copy the RIPE policy to solve the ARIN transfer incompatibility:

 - APNIC shall accept all transfers of Internet number resources to its
   service region, provided that they comply with the policies relating
   to transfers within its service region.

 - For transfers from RIR regions that require the receiving region to
   have needs-based policies, recipients must provide a plan to the
   APNIC for the use of at least 50% of the transferred resources within
   5 years.

source:
https://www.ripe.net/publications/docs/ripe-644


5. Advantages / Disadvantages
---

Advantages:

 - Harmonisation with RIPE region.
 - Makes transfer simpler and smoother within APNIC and between APNIC
   and RIPE.
 - maintains a compatibility with ARIN.
 - Removes the uncertainty that a transfer may be rejected based on
   potentially badly documented needs.
 - Lowers the overall administrative burden on APNIC staff.

Disadvantages:

none.


6. Impact on resource holders
---
None


7. References
---




___

Re: [sig-policy] New Policy Proposal prop-116: Prohibit to transfer IPv4 addresses in the final /8 block

[George Kuo]

Hi Mike,


On 7/09/2016 8:09 AM, Mike Jager wrote:

This proposal does not prohibit transfers due to M Transfers of 103/8

block due to M continues to be allowed, based on the M transfer

procedures.


I had always assumed that anyone trying to get more than one allocation of 103/8 
was creating a separate entity, obtaining APNIC membership, receiving the 103/8 
allocation, and then using the M process to transfer it to their original 
entity.

If this is the case, the proposal will be ineffective at stopping this.

Does APNIC have any information on the relative number of transfers within 103/8 
that have happened as part of M?



I have included two tables here for your reference. The numbers for 
Market transfers are available as part of the public transfer logs. 
(ftp://ftp.apnic.net/public/transfers/)



1) M transfers containing 103/8 space

+--+---+---+-
|  |   Total   | Number of |
| Year | Transfers |   /24s|
+--+---+---+-
| 2011 | 3 | 12 |
| 2012 |10 | 46 |
| 2013 |18 | 66 |
| 2014 |   126 |498 |
| 2015 |   147 |573 |
| 2016 |45 |177 |
+--+---++-

2) Market transfers containing 103/8 space

+--+---+---+
|  |   Total   | Number of |
| Year | Transfers |   /24s|
+--+---+---+
| 2011 | 2 | 2 |
| 2012 |21 |68 |
| 2013 |16 |61 |
| 2014 |25 |95 |
| 2015 |67 |   266 |
| 2016 |56 |   206 |
+--+---+---+

Thanks,

George K





Cheers
-Mike
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Re: [sig-policy] [New Policy Proposal] prop-114: Modification in the ASN eligibility criteria

[George Kuo]

Hello Dean,

We are not aware of any potential members who may have decided not to 
apply for IPv4 addresses or AS numbers based on how they have 
interpreted the policy wording.


However, we explain the policy criteria to any potential members who do 
contact APNIC, and those who are not multihoming do not qualify for An 
IPv4 or ASN assignment based on the current policy.


Currently, we don't keep a record of these unsuccessful requests, but
we can begin to keep records in the future if this information is
required.

George K

On 4/02/2015 5:13 am, Dean Pemberton wrote:

Could I ask that the APNIC hostmasters to comment on the following:

Have you ever been made aware of a situation where due of the current
wording of the relevant clauses in the policy, a member or potential
member has not made a resource application where they would otherwise
have been able to?

In other words has the current policy in the eyes of the host masters
ever been a barrier to entry?




On Wednesday, 4 February 2015, Masato Yamanishi myama...@gmail.com
mailto:myama...@gmail.com wrote:

Dear SIG members

The proposal prop-114: Modification in the ASN eligibility criteria
has been sent to the Policy SIG for review.

It  will be presented at the Open Policy Meeting at APNIC 39 in Fukuoka,
Japan on Thursday, 5 March 2015.

We invite you to review and comment on the proposal on the mailing list
before the meeting.

The comment period on the mailing list before an APNIC meeting is an
important part of the policy development process. 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 available at:

http://www.apnic.net/policy/proposals/prop-114


Regards,

Masato





---
prop-114-v001: Modification in the ASN eligibility criteria
---

Proposer: Aftab Siddiqui
aftab.siddi...@gmail.com
javascript:_e(%7B%7D,'cvml','aftab.siddi...@gmail.com');

   Skeeve Stevens
ske...@eintellegonetworks.com
javascript:_e(%7B%7D,'cvml','ske...@eintellegonetworks.com');


1. Problem statement


 The current ASN assignment policy dictates two eligibility criteria
 and both should be fulfilled in order to get an ASN. The policy
 seems to imply that both requirements i.e. multi-homing and clearly
 defined single routing policy must be met simultaneously, this has
 created much confusion in interpreting the policy.

 As a result organizations have either provided incorrect
information
 to get the ASN or barred themselves from applying.


2. Objective of policy change
-

 In order to make the policy guidelines simpler we are proposing to
 modify the text describing the eligibility criteria for ASN
 assignment by removing multi-homing requirement for the
organization.


3. Situation in other regions
-

ARIN:
 It is not mandatory but optional to be multi-homed in order get ASN

RIPE:
 Policy to remove multi-homing requirement is currently in
discussion
 and the current phase ends 12 February 2015
 Policy - https://www.ripe.net/ripe/policies/proposals/2014-03

LACNIC:
 only inter-connect is mandatory not multi-homing

AFRINIC:
  It is mandatory to be multi-homed in order to get ASN.


4. Proposed policy solution
---

 An organization is eligible for an ASN assignment if it:
  - Is planning to use it within next 6 months


5. Advantages / Disadvantages
-

Advantages:

 Removing the mandatory multi-homing requirement from the policy
will
 make sure that organizations are not tempted to provide wrong
 information in order to fulfil the criteria of eligibility.

Disadvantages:

 No disadvantage.


6. Impact on resource holders
-

 No impact on existing resource holders.


7. References
-



--
--
Dean Pemberton

Technical Policy Advisor
InternetNZ
+64 21 920 363 (mob)
d...@internetnz.net.nz mailto:d...@internetnz.net.nz

To promote the Internet's benefits and uses, and protect its potential.


*  sig-policy:  APNIC SIG on resource management policy   *