[sig-policy] Re: New proposal: prop-158-v001: IPv6 auto-allocation for each IPv4 request

[Satoru Tsurumaki]

Dear Colleagues,

I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team..

I would like to share key feedback in our community for prop-158,based
on a meeting we organised on 31th Jan to discuss these proposals.
This feedback is sent on my behalf, but please note that it is a
summary of the discussions among the 12 Japanese community members (5
on-site, 7 remote) who attended the meeting.

Many oppose opinions were expressed about this proposal.


(comment details)
 - As pointed out in the Secretariat's impact assessment, it is still
possible to obtain a /32 IPv6 address with one click after obtaining
an IPv4 address now. On the other hand, the proposed policy
automatically delegate IPv6 addresses and requires that they advertise
it within two years, which may seem unfair to members who are
delegated the address under the this policy.

 - Unfortunately, there are a certain number of applicants who do not
need IPv6 addresses today.

 - Members who are delegated IPv4 addresses of /23 or less will also
be delegated IPv6 addresses of /32, whether they want them or not, and
finaly their annual membership fee will increase. Under Japanese law,
this is extremely likely to violate the Antimonopoly Law as tying
sales.


Regards,

2024年1月15日(月) 8:39 Bertrand Cherrier via SIG-policy
:
>
> Dear SIG members,
>
> A new proposal "prop-158-v001: IPv6 auto-allocation for each IPv4 request"
> 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-158
>
> Regards,
> Bertrand, Shaila, and Anupam
> APNIC Policy SIG Chairs
>
> --
>
> prop-158-v001: IPv6 auto-allocation for each IPv4 request
>
> ---
>
> Proposers: David Aditya Yoga Pratama (da...@idnic.net)
>   M. Andri Setiawan (an...@idnic.net)
>
>
> 1. Problem statement
> -
>
> Based on this
> https://www.apnic.net/manage-ip/ipv4-exhaustion/#how-much-apnic-has,
> APNIC still has around 2,539,776 available IPv4 addresses and may
> claimed another 2,479,360 reserved IPv4 addresses.
>
> APNIC member still can get /24 of IPv4 addresses based on the current
> APNIC policy.
>
> Most of the new IPv4 requestors are not allocated or requesting IPv6
> even though they are eligible to do so.
>
> The rates of IPv4 allocation is faster than IPv6 allocation and it may
> keep slow the deployment of IPv6.
>
> APNIC associate member can get IPv6 without additional cost
> (proposal-155), so APNIC member should be able to do the same when they
> request IPv4 address.
>
> 2. Objective of policy change
> --
>
> Allocate IPv6 addresses to each IPv4 addresses requests to speed up the
> IPv6 adoption and deployment rates.
>
> 3. Situation in other regions
> 
>
> AFRINIC - No such policy
> ARIN - No such policy and it has no available address space to be offered
> RIPE NCC - No such policy and it has no available address space to be
> offered
> LACNIC - IPv6 allocation request is used as “requirements” for any IPv4
> request as mentioned in their policy point 2.3.3.1 - 2.3.3.4 and 2.3.4.
> “The applicant must already have at least one IPv6 block assigned by
> LACNIC or, if not, must simultaneously request an initial IPv6 block in
> accordance with the corresponding applicable policy. (If an applicant
> has already been assigned an IPv6 block, they shall submit to LACNIC a
> brief document describing their progress in the implementation of IPv6.)”
>
> 4. Proposed policy solution
> 
> Add this to Section "6.1. Minimum and maximum IPv4 delegations" of the
> APNIC Policy document.
>
> For all new and initial IPv4 delegation requests, APNIC and NIR will
> automatically delegates IPv6 address, matching the IPv6 policy in
> Section 8.2.1 (i.e allocation or assignment).
>
> Automatically delegated IPv6 address should be put into deployment
> within two years from the date of the delegation, same as Point 3 in
> Section 8.2.2.
>
> For any 

[sig-policy] Re: New proposal: prop-158-v001: IPv6 auto-allocation for each IPv4 request

[Owen DeLong via SIG-policy]

This proposal is yet another gift from the bad idea fairy… Wait… It’s actually 
a regift from someone else who got it from the bad idea fairy on its last 
go-around.

While I’m all for reuse and recycling, this one needs to go to the landfill.

It was a bad idea the first several times it was proposed and nothing has 
changed to make it a good idea now.

Owen


> On Jan 29, 2024, at 16:24, Sunny Chendi  wrote:
> 
> Dear SIG members,
> 
> The Secretariat's impact assessment for this proposal is provided below as 
> well as published at:
> http://www.apnic.net/policy/proposals/prop-158
> 
> APNIC notes that this proposal suggests automatically delegating IPv6 address 
> resource to new and initial IPv4 requests to accelerate IPv6 implementation.
> 
> APNIC also notes that this proposal is applicable to both APNIC and NIR 
> account holders.
> 
> Questions/Comments:
> - The current APNIC Membership form allows account holders to request 
> multiple IP resources (IPv4, IPv6, and ASN) while applying for APNIC 
> membership. Account holders can also simply get an IPv6 delegation by 
> one-click process in MyAPNIC.
> 
> - The proposal suggests “Automatically delegated IPv6 address should be put 
> into deployment within two years from the date of the delegation”. Is the 
> intention that the outcome of not complying with this policy is the 
> revocation of just the IPv6 resources, also the IPv4 resources applied for at 
> the same time, or an alternative option?
> 
> - If the account holder requests a /23 IPv4 and is also automatically 
> delegated a /32 IPv6, the fees payable by the account holder will increase as 
> the fee for /32 IPv6 is greater than /23 IPv4.
> 
> Implementation:
> If this proposal reaches consensus, implementation may be completed within 
> three months.
> 
> Regards,
> Sunny
> APNIC Secretariat
> 
> 
> On 15/01/2024 9:39 am, Bertrand Cherrier via SIG-policy wrote:
>> Dear SIG members,
>> 
>> A new proposal "prop-158-v001: IPv6 auto-allocation for each IPv4 request"
>> 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-158
>> 
>> Regards,
>> Bertrand, Shaila, and Anupam
>> APNIC Policy SIG Chairs
>> 
>> --
>> 
>> prop-158-v001: IPv6 auto-allocation for each IPv4 request
>> 
>> ---
>> 
>> Proposers: David Aditya Yoga Pratama (da...@idnic.net)
>>  M. Andri Setiawan (an...@idnic.net)
>> 
>> 
>> 1. Problem statement
>> -
>> 
>> Based on this 
>> https://www.apnic.net/manage-ip/ipv4-exhaustion/#how-much-apnic-has, APNIC 
>> still has around 2,539,776 available IPv4 addresses and may claimed another 
>> 2,479,360 reserved IPv4 addresses.
>> 
>> APNIC member still can get /24 of IPv4 addresses based on the current APNIC 
>> policy.
>> 
>> Most of the new IPv4 requestors are not allocated or requesting IPv6 even 
>> though they are eligible to do so.
>> 
>> The rates of IPv4 allocation is faster than IPv6 allocation and it may keep 
>> slow the deployment of IPv6.
>> 
>> APNIC associate member can get IPv6 without additional cost (proposal-155), 
>> so APNIC member should be able to do the same when they request IPv4 address.
>> 
>> 2. Objective of policy change
>> --
>> 
>> Allocate IPv6 addresses to each IPv4 addresses requests to speed up the IPv6 
>> adoption and deployment rates.
>> 
>> 3. Situation in other regions
>> 
>> 
>> AFRINIC - No such policy
>> ARIN - No such policy and it has no available address space to be offered
>> RIPE NCC - No such policy and it has no available address space to be offered
>> LACNIC - IPv6 allocation request is used as “requirements” for any IPv4 
>> request as mentioned in their policy point 2.3.3.1 - 2.3.3.4 and 2.3.4. “The 
>> applicant must already have at least one IPv6 block assigned by LACNIC or, 
>> if not, must simultaneously request an initial IPv6 block in accordance with 
>> the corresponding 

[sig-policy] Re: New proposal: prop-158-v001: IPv6 auto-allocation for each IPv4 request

[Sunny Chendi]

Dear SIG members,

The Secretariat's impact assessment for this proposal is provided below 
as well as published at:

http://www.apnic.net/policy/proposals/prop-158

APNIC notes that this proposal suggests automatically delegating IPv6 
address resource to new and initial IPv4 requests to accelerate IPv6 
implementation.


APNIC also notes that this proposal is applicable to both APNIC and NIR 
account holders.


Questions/Comments:
- The current APNIC Membership form allows account holders to request 
multiple IP resources (IPv4, IPv6, and ASN) while applying for APNIC 
membership. Account holders can also simply get an IPv6 delegation by 
one-click process in MyAPNIC.


- The proposal suggests “Automatically delegated IPv6 address should be 
put into deployment within two years from the date of the delegation”. 
Is the intention that the outcome of not complying with this policy is 
the revocation of just the IPv6 resources, also the IPv4 resources 
applied for at the same time, or an alternative option?


- If the account holder requests a /23 IPv4 and is also automatically 
delegated a /32 IPv6, the fees payable by the account holder will 
increase as the fee for /32 IPv6 is greater than /23 IPv4.


Implementation:
If this proposal reaches consensus, implementation may be completed 
within three months.


Regards,
Sunny
APNIC Secretariat


On 15/01/2024 9:39 am, Bertrand Cherrier via SIG-policy wrote:

Dear SIG members,

A new proposal "prop-158-v001: IPv6 auto-allocation for each IPv4 
request"

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-158

Regards,
Bertrand, Shaila, and Anupam
APNIC Policy SIG Chairs

--

prop-158-v001: IPv6 auto-allocation for each IPv4 request

---

Proposers: David Aditya Yoga Pratama (da...@idnic.net)
 M. Andri Setiawan (an...@idnic.net)


1. Problem statement
-

Based on this 
https://www.apnic.net/manage-ip/ipv4-exhaustion/#how-much-apnic-has, 
APNIC still has around 2,539,776 available IPv4 addresses and may 
claimed another 2,479,360 reserved IPv4 addresses.


APNIC member still can get /24 of IPv4 addresses based on the current 
APNIC policy.


Most of the new IPv4 requestors are not allocated or requesting IPv6 
even though they are eligible to do so.


The rates of IPv4 allocation is faster than IPv6 allocation and it may 
keep slow the deployment of IPv6.


APNIC associate member can get IPv6 without additional cost 
(proposal-155), so APNIC member should be able to do the same when 
they request IPv4 address.


2. Objective of policy change
--

Allocate IPv6 addresses to each IPv4 addresses requests to speed up 
the IPv6 adoption and deployment rates.


3. Situation in other regions


AFRINIC - No such policy
ARIN - No such policy and it has no available address space to be offered
RIPE NCC - No such policy and it has no available address space to be 
offered
LACNIC - IPv6 allocation request is used as “requirements” for any 
IPv4 request as mentioned in their policy point 2.3.3.1 - 2.3.3.4 and 
2.3.4. “The applicant must already have at least one IPv6 block 
assigned by LACNIC or, if not, must simultaneously request an initial 
IPv6 block in accordance with the corresponding applicable policy. (If 
an applicant has already been assigned an IPv6 block, they shall 
submit to LACNIC a brief document describing their progress in the 
implementation of IPv6.)”


4. Proposed policy solution

Add this to Section "6.1. Minimum and maximum IPv4 delegations" of the 
APNIC Policy document.


For all new and initial IPv4 delegation requests, APNIC and NIR will 
automatically delegates IPv6 address, matching the IPv6 policy in 
Section 8.2.1 (i.e allocation or assignment).


Automatically delegated IPv6 address should be put into deployment 
within two years from the date of the delegation, same as Point 3 in 
Section 8.2.2.


For any subsequent IPv4 

[sig-policy] Re: New proposal: prop-158-v001: IPv6 auto-allocation for each IPv4 request

[Anupam Agrawal]

Echoing what David has said + there exists a NIR - -SIG in the APNIC
ecosystem. Its charter is to share information on operations, policies, and
procedures and close cooperation with APNIC.

Regards
Anupam Agrawal


On Thu, Jan 25, 2024 at 2:21 PM David Conrad  wrote:

> Fernando,
>
> On Jan 24, 2024, at 3:47 PM, Fernando Frediani 
> wrote:
>
> On Wed, 24 Jan 2024, 07:39 David Conrad,  wrote:
>
>> On Jan 24, 2024, at 4:19 AM, Fernando Frediani 
>> wrote:
>> > No government should ever be able to mandate anything related to policy
>> development and how they apply to IP space assignment and use.
>> I’m actually curious: why do you believe you (or the RIRs) are able to
>> tell governments what they can or cannot mandate?
>
> I think you are not following this discussion and trying to speak about
> soemthing different from what is being discussed.
>
>
> I actually am following the discussion and I am trying to follow your
> argumentation in response to Christopher Hawker that you started with:
>
> "One thing that must end in APNIC is the possibilit for NIR to have their
> own set of policies. This just doesn't make sense, even if they don't
> conflict with APNIC's policies."
>
> As Akinori has pointed out, JPNIC develops its own policies within the
> APNIC policy framework which is, in turn, developed within the framework
> defined in RFC 7020 (and its predecessors).  You state above that NIRs
> (e.g., JPNIC) must not be able to do that, even if those policies “don’t
> conflict with APNIC policies.” Your statement suggests a fundamental
> misunderstanding of the relationships between APNIC and the NIRs that I’m
> trying to understand.
>
> No government is able in practice to determinate what should be the
> policies for IP address assignment anywhere.
>
>
> Somewhat orthogonal to the proposal, but I remain curious: why do you
> believe this? My understanding is that a government may, in practice,
> specify pretty much anything they like, including policy for IP addressing,
> for entities within their economy.
>
> I’m unsure what you mean by this.  Simply, NIRs were (and are, as far as I
>> know) intended to provide Internet registration services for entities
>> within their economy. Overarching guidelines for the policies by which
>> those service are provided are defined within the Internet numbers registry
>> system (see RFC 7020) but those guidelines do not carry the force of law:
>> they require the voluntary cooperation of the parties involved to be
>> effective.
>>
> Maybe your conception about NIRs may not be very accurate and the
> difefence between them and the RIRs and the hierarchy that exists.
>
>
> Perhaps, although I suspect I have been doing this a bit longer than you.
> Another possibility could be your mental model for how the Internet numbers
> registration system works, as simple and appealing as you may find it or
> how much you’d like it to be so, doesn’t actually fully correspond to
> reality.
>
> Regards,
> -drc
>
> ___
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[sig-policy] Re: New proposal: prop-158-v001: IPv6 auto-allocation for each IPv4 request

[David Conrad]

Hi,

On Jan 15, 2024, at 12:39 AM, Bertrand Cherrier via SIG-policy 
 wrote:
> 
> Dear SIG members,
> 
> A new proposal "prop-158-v001: IPv6 auto-allocation for each IPv4 request"
> 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?

Oppose.

>   - Does this proposal solve a problem you are experiencing? If so,
> tell the community about your situation.

No.

>   - Do you see any disadvantages in this proposal?

It would result in the allocation of IPv6 address space that would almost 
certainly be unused, increasing (albeit slightly) administrative load for 
managing IPv6 address space both at APNIC and the requester, as well as 
potentially increasing the risk of address hijack.

>   - Is there anything in the proposal that is not clear?

See below.

>   - What changes could be made to this proposal to make it more effective?

The basis for the proposal, i.e., that automatic allocation of IPv6 addresses 
when IPv4 addresses are requested will increase IPv6 adoption, appears to 
assume the reason IPv6 deployment is slow is because of friction in the 
allocation processes of IPv6. Providing evidence that this is the case would 
likely help in justifying this proposal.

> Information about this proposal is appended below as well as available at:
> 
> http://www.apnic.net/policy/proposals/prop-158
> 
> Regards,
> Bertrand, Shaila, and Anupam
> APNIC Policy SIG Chairs
> 
> --
> 
> prop-158-v001: IPv6 auto-allocation for each IPv4 request
> 
> ---
> 
> Proposers: David Aditya Yoga Pratama (da...@idnic.net)
>  M. Andri Setiawan (an...@idnic.net)
> 
> 
> 1. Problem statement
> -
> 
> Based on this 
> https://www.apnic.net/manage-ip/ipv4-exhaustion/#how-much-apnic-has, APNIC 
> still has around 2,539,776 available IPv4 addresses and may claimed another 
> 2,479,360 reserved IPv4 addresses.
> 
> APNIC member still can get /24 of IPv4 addresses based on the current APNIC 
> policy.
> 
> Most of the new IPv4 requestors are not allocated or requesting IPv6 even 
> though they are eligible to do so.

It may be instructive to understand why this is the case, e.g., asking 
requesters who decline IPv6 allocations why they are uninterested in those 
allocations.

> The rates of IPv4 allocation is faster than IPv6 allocation and it may keep 
> slow the deployment of IPv6.

- Documenting the rates of IPv4 and IPv6 allocation would be helpful
- The implication that a higher rate of IPv4 allocation is slowing IPv6 
deployment is not justified/documented by the proposal. 

> APNIC associate member can get IPv6 without additional cost (proposal-155), 
> so APNIC member should be able to do the same when they request IPv4 address.
> 
> 2. Objective of policy change
> --
> 
> Allocate IPv6 addresses to each IPv4 addresses requests to speed up the IPv6 
> adoption and deployment rates.

It is unclear that the allocation of IPv6 addresses when they are not requested 
would have a material impact on the IPv6 adoption/deployment rate.  If there is 
no request for IPv6 addresses, it suggests the requester is uninterested in or 
unable to deploy IPv6. Providing an IPv6 allocation automatically would most 
likely result in those addresses simply being ignored. While it is unlikely the 
loss of this address space would have a material impact on the lifetime of 
IPv6, the allocation of address space unlikely to be legitimately used imposes 
administrative costs and may create increased risks related to address 
hijacking.

> 3. Situation in other regions
> 
> 
> AFRINIC - No such policy
> ARIN - No such policy and it has no available address space to be offered
> RIPE NCC - No such policy and it has no available address space to be offered
> LACNIC - IPv6 allocation request is used as “requirements” for any IPv4 
> request as mentioned in their policy point 2.3.3.1 - 2.3.3.4 and 2.3.4. “The 
> applicant must already have at least one IPv6 block assigned by LACNIC or, if 
> not, must simultaneously request an initial IPv6 block in accordance with the 
> corresponding applicable policy. (If an applicant has already been assigned 
> an IPv6 block, they shall submit to LACNIC a brief document describing their 
> progress in the implementation of IPv6.)”
> 
> 4. Proposed policy solution
> 
> Add this to 

[sig-policy] Re: New proposal: prop-158-v001: IPv6 auto-allocation for each IPv4 request

[David Conrad]

Fernando,

On Jan 24, 2024, at 3:47 PM, Fernando Frediani  wrote:
> On Wed, 24 Jan 2024, 07:39 David Conrad,  > wrote:
>> On Jan 24, 2024, at 4:19 AM, Fernando Frediani > > wrote:
>> > No government should ever be able to mandate anything related to policy 
>> > development and how they apply to IP space assignment and use.
>> I’m actually curious: why do you believe you (or the RIRs) are able to tell 
>> governments what they can or cannot mandate?
> 
> 
> I think you are not following this discussion and trying to speak about 
> soemthing different from what is being discussed.

I actually am following the discussion and I am trying to follow your 
argumentation in response to Christopher Hawker that you started with:

"One thing that must end in APNIC is the possibilit for NIR to have their own 
set of policies. This just doesn't make sense, even if they don't conflict with 
APNIC's policies."

As Akinori has pointed out, JPNIC develops its own policies within the APNIC 
policy framework which is, in turn, developed within the framework defined in 
RFC 7020 (and its predecessors).  You state above that NIRs (e.g., JPNIC) must 
not be able to do that, even if those policies “don’t conflict with APNIC 
policies.” Your statement suggests a fundamental misunderstanding of the 
relationships between APNIC and the NIRs that I’m trying to understand.

> No government is able in practice to determinate what should be the policies 
> for IP address assignment anywhere. 

Somewhat orthogonal to the proposal, but I remain curious: why do you believe 
this? My understanding is that a government may, in practice, specify pretty 
much anything they like, including policy for IP addressing, for entities 
within their economy.

>> I’m unsure what you mean by this.  Simply, NIRs were (and are, as far as I 
>> know) intended to provide Internet registration services for entities within 
>> their economy. Overarching guidelines for the policies by which those 
>> service are provided are defined within the Internet numbers registry system 
>> (see RFC 7020) but those guidelines do not carry the force of law: they 
>> require the voluntary cooperation of the parties involved to be effective.
> 
> Maybe your conception about NIRs may not be very accurate and the difefence 
> between them and the RIRs and the hierarchy that exists.

Perhaps, although I suspect I have been doing this a bit longer than you. 
Another possibility could be your mental model for how the Internet numbers 
registration system works, as simple and appealing as you may find it or how 
much you’d like it to be so, doesn’t actually fully correspond to reality.

Regards,
-drc

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[sig-policy] Re: New proposal: prop-158-v001: IPv6 auto-allocation for each IPv4 request

[David Farmer via SIG-policy]

I do not believe this policy will achieve its stated objective: to
accelerate IPv6 implementation.

Automatically delegating IPv6 address space to new and initial IPv4
requests, may increase the number of IPv6 delegations. But, the bar to get
an IPv6 delegation is already pretty low, and it is not the limiting factor
for IPv6 implementation in a network. The limiting factor is the actual
work of implementing IPv6 in a network.

I suspect many, if not most, networks requesting IPv4 will accept the IPv6
delegation and simply fail to proceed with its IPv6 implementation in
their network. IPv4 policy has not been and will not be an effective lever
to increase IPv6 implementations.

Thanks.

-- 
===
David Farmer   Email:far...@umn.edu
Networking & Telecommunication Services
Office of Information Technology
University of Minnesota
2218 University Ave SEPhone: 612-626-0815
Minneapolis, MN 55414-3029   Cell: 612-812-9952
===
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[sig-policy] Re: New proposal: prop-158-v001: IPv6 auto-allocation for each IPv4 request

[David Farmer via SIG-policy]

On Wed, Jan 24, 2024 at 9:49 PM Fernando Frediani 
wrote:

>
> On Wed, 24 Jan 2024, 21:50 Christopher Hawker, 
> wrote:
>
>> NIRs may well continue to exist and perform their administrative
>> functions under the umbrella of the RIR facilitating things in certain
>> economies and cultures.
>>
>> NIRs are independent of RIRs and operate via a NIR Member Relationship
>> Agreement. The MRA outlines what NIRs are able to do.
>>
>
> That is a problem on this discussion, a big missundertanding about how
> things are organized in practice.
>

I think you are arguing about semantics;

I believe APNIC gives NIRs significant latitude to create local policies
and procedures appropriate to their local economies, culture, or laws;

Nevertheless, the "APNIC and NIR Member Relationship Agreement" clearly
states, "Recitals; c. ... National Internet Registries provide procedures
and services that take account of local cultural differences, while
operating in a way that remains consistent with regional and global
resource management policies." Further, "2.3 Termination, a. APNIC may
terminate this agreement in any of the following circumstances: 4. The NIR
Member commits a substantial breach of this agreement or any APNIC Address
Management Policy;"

https://www.apnic.net/about-apnic/corporate-documents/documents/membership/nir-membership-agreement/
https://www.apnic.net/community/policy/operational-policies-nirs/

"APNIC and NIR Member Relationship Agreement" is a cooperative agreement or
contract. It, therefore, doesn't override local or international laws, and
the only real enforcement action is the termination of the agreement.
Furthermore, I imagine APNIC would not pursue termination of the agreement
except under the most egregious violation and only after both informal and
formal opportunities to correct the situation.

Can we please get back to the policy discussion at hand?

Thanks.

-- 
===
David Farmer   Email:far...@umn.edu
Networking & Telecommunication Services
Office of Information Technology
University of Minnesota
2218 University Ave SEPhone: 612-626-0815
Minneapolis, MN 55414-3029   Cell: 612-812-9952
===
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[sig-policy] Re: New proposal: prop-158-v001: IPv6 auto-allocation for each IPv4 request

[MAEMURA Akinori]

Dear Mike and Fernando,


Mike:

I have been under the impression that the APNIC NIRs must adhere to APNIC 
policies but could create their own policies if they don’t contradict those of 
APNIC.


Yes.  Please notice the policy proposals in APNIC sig-policy often have the 
section of "applicability in NIR" (sorry no phrase in my crappy memory) and 
there are cases where NIRs have some room for localizing it.  It's due to some 
reasons.  In JPNIC case we have our own registry system and the policies which 
require additional implementation at the registry system often need some 
treatment like allowance for the local implementation.  For the transfer, APNIC 
doesn't force NIRs to allow transfer, but it was under the discretion of NIR to 
allow it or now and that isn't recognized to contradict APNIC policy.


Moreover, from a bit different angle, If an NIR only can implement APNIC policy, 
how local community can propose a policy they want?  It sounds like the local 
people still need to propose it to APNIC sig-policy?  So in case of Japan we 
have a local policy forum where community members can propose something to the 
existing policies and established the mechanism to keep consistency between 
local forum and sig-policy - proposals in local forum, if once got consensus, 
will be brought to sig-policy, a new policy proposals in sig-policy will be 
introduced in the local to measure temperature and being reported back to 
sig-policy and consensus policy in sig-policy will be simply reviewed in the 
local for implementation at JPNIC.



Hope these help you.  I wonder why NIR got such a big spot light, but I am happy 
to explain further.  I think we with local policy forum leaders do the right things.



Thank you,

Akinori


On 2024/01/25 1:00, Mike Burns wrote:


In the past I have had problems with the transfer policies of APNIC NIRs not 
matching APNIC’s own transfer policies.


When those differences prevented a transfer I asked APNIC to intervene by 
imposing the (governing, to my mind) APNIC transfer policies on the 
recalcitrant NIR.


And that was effective but maybe it didn’t settle the issue, which I think 
should be clear to all.


I believe that there is a hierarchy in which the topmost organizations 
delegate some specified roles to subsidiary organizations via some document 
 like a Memorandum of Understanding (MOU).


It would be such a document that spells out whether policies must match, or if 
they mismatch which is controlling.


I have been under the impression that the APNIC NIRs must adhere to APNIC 
policies but could create their own policies if they don’t contradict those of 
APNIC.


I hope somebody can clear it up.

Regards,
Mike

*From:* Fernando Frediani 
*Sent:* Wednesday, January 24, 2024 10:25 AM
*To:* sig-policy 
*Subject:* [sig-policy] Re: New proposal: prop-158-v001: IPv6 auto-allocation 
for each IPv4 request


To resume my initial point there is no point in allowing NIRs to develop and 
have specific policies, complicate and confuse things unecessarily. Policies 
developed by the entire RIR community is more than enough in order to regulate 
how IP addreess assignment is conducted as in all.other RIRs worldwide.


NIRs may well continue to exist and perform their administrative functions 
under the umbrella of the RIR facilitating things in certain economies and 
cultures.


Best regards

Fernando

On Wed, 24 Jan 2024, 11:47 Fernando Frediani,  wrote:

Hi

On Wed, 24 Jan 2024, 07:39 David Conrad,  wrote:

Fernando,

On Jan 24, 2024, at 4:19 AM, Fernando Frediani 
wrote:
> No government should ever be able to mandate anything related to
policy development and how they apply to IP space assignment and use.

I’m actually curious: why do you believe you (or the RIRs) are able to
tell governments what they can or cannot mandate?

I think you are not following this discussion and trying to speak about
soemthing different from what is being discussed. I mentioned several
times the diference between policies and administrative and legal
obligations and you simplify very much the question.

No government is able in practice to determinate what should be the
policies for IP address assignment anywhere. Don't confuse it with mandate
legal obligations within a certain jurisdiction.


> NIRs are never meant to be "mini-RIRs"or something in that line.

I’m unsure what you mean by this.  Simply, NIRs were (and are, as far
as I know) intended to provide Internet registration services for
entities within their economy. Overarching guidelines for the policies
by which those service are provided are defined within the Internet
numbers registry system (see RFC 7020) but those guidelines do not
carry the force of law: they require the voluntary cooperation of the
parties involved to be effective.

Maybe 

[sig-policy] Re: New proposal: prop-158-v001: IPv6 auto-allocation for each IPv4 request

[Christopher Hawker]

Hello Fernando,

To resume my initial point there is no point in allowing NIRs to develop and 
have specific policies, complicate and confuse things unecessarily.
It only complicates and confuses things for people who have no idea or 
understanding what goes on and what they are talking about.

Policies developed by the entire RIR community is more than enough in order to 
regulate how IP addreess assignment is conducted as in all.other RIRs worldwide.
You've quite clearly disregarded what has been mentioned previously. NIRs have 
the ability to form policies for their own economies to allow them to better 
serve the needs of their economies, provided they do not conflict with RIR 
policies.

NIRs may well continue to exist and perform their administrative functions 
under the umbrella of the RIR facilitating things in certain economies and 
cultures.
NIRs are independent of RIRs and operate via a NIR Member Relationship 
Agreement. The MRA outlines what NIRs are able to do. You may wish to read 
https://www.apnic.net/about-apnic/corporate-documents/documents/membership/nir-membership-agreement/
 for a more comprehensive list.


Regards,
Christopher Hawker
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[sig-policy] Re: New proposal: prop-158-v001: IPv6 auto-allocation for each IPv4 request

[Mike Burns]

In the past I have had problems with the transfer policies of APNIC NIRs not 
matching APNIC’s own transfer policies.

When those differences prevented a transfer I asked APNIC to intervene by 
imposing the (governing, to my mind) APNIC transfer policies on the 
recalcitrant NIR.

And that was effective but maybe it didn’t settle the issue, which I think 
should be clear to all.

 

I believe that there is a hierarchy in which the topmost organizations delegate 
some specified roles to subsidiary organizations via some document  like a 
Memorandum of Understanding (MOU).

It would be such a document that spells out whether policies must match, or if 
they mismatch which is controlling.

I have been under the impression that the APNIC NIRs must adhere to APNIC 
policies but could create their own policies if they don’t contradict those of 
APNIC.

 

I hope somebody can clear it up.

 

Regards,
Mike

 

 

 

 

From: Fernando Frediani  
Sent: Wednesday, January 24, 2024 10:25 AM
To: sig-policy 
Subject: [sig-policy] Re: New proposal: prop-158-v001: IPv6 auto-allocation for 
each IPv4 request

 

To resume my initial point there is no point in allowing NIRs to develop and 
have specific policies, complicate and confuse things unecessarily. Policies 
developed by the entire RIR community is more than enough in order to regulate 
how IP addreess assignment is conducted as in all.other RIRs worldwide.

 

NIRs may well continue to exist and perform their administrative functions 
under the umbrella of the RIR facilitating things in certain economies and 
cultures.

 

Best regards

Fernando

 

On Wed, 24 Jan 2024, 11:47 Fernando Frediani, mailto:fhfredi...@gmail.com> > wrote:

Hi

On Wed, 24 Jan 2024, 07:39 David Conrad, mailto:d...@virtualized.org> > wrote:

Fernando,

On Jan 24, 2024, at 4:19 AM, Fernando Frediani mailto:fhfredi...@gmail.com> > wrote:
> No government should ever be able to mandate anything related to policy 
> development and how they apply to IP space assignment and use.

I’m actually curious: why do you believe you (or the RIRs) are able to tell 
governments what they can or cannot mandate?

 

I think you are not following this discussion and trying to speak about 
soemthing different from what is being discussed. I mentioned several times the 
diference between policies and administrative and legal obligations and you 
simplify very much the question.

No government is able in practice to determinate what should be the policies 
for IP address assignment anywhere. Don't confuse it with mandate legal 
obligations within a certain jurisdiction.

 


> NIRs are never meant to be "mini-RIRs"or something in that line.

I’m unsure what you mean by this.  Simply, NIRs were (and are, as far as I 
know) intended to provide Internet registration services for entities within 
their economy. Overarching guidelines for the policies by which those service 
are provided are defined within the Internet numbers registry system (see RFC 
7020) but those guidelines do not carry the force of law: they require the 
voluntary cooperation of the parties involved to be effective.

Maybe your conception about NIRs may not be very accurate and the difefence 
between them and the RIRs and the hierarchy that exists.

 

> No resources would arrive to a NIR if not via the RIR

This is factually incorrect as it ignores the reality that addresses were 
allocated (to NIRs and others) prior to the existence of the RIRs. It also 
ignores the existence of the “transfer" market.

 

This is incorrect understanding on how registration works worldwide. Any 
inter-RIR tranfers are made following - guess what - RIR policies and as such 
all transfers goes trough a RIR system even if they end up in a NIR, but 
following RIR policies.

 

It has been already mentioned that anything done before the existance of 
certain RIRs is treated as legacy and from a long time this doesn't exist 
anymore so anything anywhere in the world that is not related to legacy 
resources is always done via the policies of one of the RIRs.

 

Fernando


Regards,
-drc

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[sig-policy] Re: New proposal: prop-158-v001: IPv6 auto-allocation for each IPv4 request

[Fernando Frediani]

To resume my initial point there is no point in allowing NIRs to develop
and have specific policies, complicate and confuse things unecessarily.
Policies developed by the entire RIR community is more than enough in order
to regulate how IP addreess assignment is conducted as in all.other RIRs
worldwide.

NIRs may well continue to exist and perform their administrative functions
under the umbrella of the RIR facilitating things in certain economies and
cultures.

Best regards
Fernando

On Wed, 24 Jan 2024, 11:47 Fernando Frediani,  wrote:

> Hi
>
> On Wed, 24 Jan 2024, 07:39 David Conrad,  wrote:
>
>> Fernando,
>>
>> On Jan 24, 2024, at 4:19 AM, Fernando Frediani 
>> wrote:
>> > No government should ever be able to mandate anything related to policy
>> development and how they apply to IP space assignment and use.
>>
>> I’m actually curious: why do you believe you (or the RIRs) are able to
>> tell governments what they can or cannot mandate?
>>
>
> I think you are not following this discussion and trying to speak about
> soemthing different from what is being discussed. I mentioned several times
> the diference between policies and administrative and legal obligations and
> you simplify very much the question.
> No government is able in practice to determinate what should be the
> policies for IP address assignment anywhere. Don't confuse it with mandate
> legal obligations within a certain jurisdiction.
>
>
>> > NIRs are never meant to be "mini-RIRs"or something in that line.
>>
>> I’m unsure what you mean by this.  Simply, NIRs were (and are, as far as
>> I know) intended to provide Internet registration services for entities
>> within their economy. Overarching guidelines for the policies by which
>> those service are provided are defined within the Internet numbers registry
>> system (see RFC 7020) but those guidelines do not carry the force of law:
>> they require the voluntary cooperation of the parties involved to be
>> effective.
>>
> Maybe your conception about NIRs may not be very accurate and the
> difefence between them and the RIRs and the hierarchy that exists.
>
> > No resources would arrive to a NIR if not via the RIR
>>
>> This is factually incorrect as it ignores the reality that addresses were
>> allocated (to NIRs and others) prior to the existence of the RIRs. It also
>> ignores the existence of the “transfer" market.
>>
>
> This is incorrect understanding on how registration works worldwide. Any
> inter-RIR tranfers are made following - guess what - RIR policies and as
> such all transfers goes trough a RIR system even if they end up in a NIR,
> but following RIR policies.
>
> It has been already mentioned that anything done before the existance of
> certain RIRs is treated as legacy and from a long time this doesn't exist
> anymore so anything anywhere in the world that is not related to legacy
> resources is always done via the policies of one of the RIRs.
>
> Fernando
>
>>
>> Regards,
>> -drc
>>
>>
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[sig-policy] Re: New proposal: prop-158-v001: IPv6 auto-allocation for each IPv4 request

[Fernando Frediani]

Hi

On Wed, 24 Jan 2024, 07:39 David Conrad,  wrote:

> Fernando,
>
> On Jan 24, 2024, at 4:19 AM, Fernando Frediani 
> wrote:
> > No government should ever be able to mandate anything related to policy
> development and how they apply to IP space assignment and use.
>
> I’m actually curious: why do you believe you (or the RIRs) are able to
> tell governments what they can or cannot mandate?
>

I think you are not following this discussion and trying to speak about
soemthing different from what is being discussed. I mentioned several times
the diference between policies and administrative and legal obligations and
you simplify very much the question.
No government is able in practice to determinate what should be the
policies for IP address assignment anywhere. Don't confuse it with mandate
legal obligations within a certain jurisdiction.


> > NIRs are never meant to be "mini-RIRs"or something in that line.
>
> I’m unsure what you mean by this.  Simply, NIRs were (and are, as far as I
> know) intended to provide Internet registration services for entities
> within their economy. Overarching guidelines for the policies by which
> those service are provided are defined within the Internet numbers registry
> system (see RFC 7020) but those guidelines do not carry the force of law:
> they require the voluntary cooperation of the parties involved to be
> effective.
>
Maybe your conception about NIRs may not be very accurate and the difefence
between them and the RIRs and the hierarchy that exists.

> No resources would arrive to a NIR if not via the RIR
>
> This is factually incorrect as it ignores the reality that addresses were
> allocated (to NIRs and others) prior to the existence of the RIRs. It also
> ignores the existence of the “transfer" market.
>

This is incorrect understanding on how registration works worldwide. Any
inter-RIR tranfers are made following - guess what - RIR policies and as
such all transfers goes trough a RIR system even if they end up in a NIR,
but following RIR policies.

It has been already mentioned that anything done before the existance of
certain RIRs is treated as legacy and from a long time this doesn't exist
anymore so anything anywhere in the world that is not related to legacy
resources is always done via the policies of one of the RIRs.

Fernando

>
> Regards,
> -drc
>
>
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[sig-policy] Re: New proposal: prop-158-v001: IPv6 auto-allocation for each IPv4 request

[David Conrad]

Fernando,

On Jan 24, 2024, at 4:19 AM, Fernando Frediani  wrote:
> No government should ever be able to mandate anything related to policy 
> development and how they apply to IP space assignment and use.

I’m actually curious: why do you believe you (or the RIRs) are able to tell 
governments what they can or cannot mandate?

> NIRs are never meant to be "mini-RIRs"or something in that line.

I’m unsure what you mean by this.  Simply, NIRs were (and are, as far as I 
know) intended to provide Internet registration services for entities within 
their economy. Overarching guidelines for the policies by which those service 
are provided are defined within the Internet numbers registry system (see RFC 
7020) but those guidelines do not carry the force of law: they require the 
voluntary cooperation of the parties involved to be effective.

> No resources would arrive to a NIR if not via the RIR

This is factually incorrect as it ignores the reality that addresses were 
allocated (to NIRs and others) prior to the existence of the RIRs. It also 
ignores the existence of the “transfer" market.

Regards,
-drc

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[sig-policy] Re: New proposal: prop-158-v001: IPv6 auto-allocation for each IPv4 request

[Fernando Frediani]

Hello

On 23/01/2024 20:49, Christopher Hawker wrote:


They play a important administrative role in certain places and
economies, but that doesn't mean they should be allowed to develop
policies.

I disagree. As David has identified, NIRs may in some cases may have 
legal mandates set by the governments of their economies relating to 
the management of address space which may not be relevant to other 
economies. In these circumstances it would be appropriate for these 
NIRs to set these policies at an economy level, rather than that of a 
regional level. Further, some NIR policies may be defined as a means 
to better serve their communities whereas they could be detrimental to 
others (not saying that they would).


I think there is some misunderstanding about the difference between 
specific administrative functions and legal obligations in certain 
jurisdictions and policy development process.
No government should ever be able to mandate anything related to policy 
development and how they apply to IP space assignment and use. That is a 
bottom up process that is developed solely by the community in line with 
ICP-2. Any legal need and mandates specific to certain countries are 
administrative stuff and should not be confused with policy development 
with regards how numbering resources are dealt with, the rules under how 
resources are assigned and used.


Allowing this to happen open doors to unnecessary discrepancies,
bureaucracy and sometimes unfairness within the same RIR region
which should not exist.

Again, I disagree. NIRs that fall under APNIC are seen and treated as 
regular APNIC members and any relationship between an LIR and an NIR 
is exactly that - between them. Network operators within NIR service 
regions are welcome to choose whether to obtain resources directly 
from APNIC or their NIR and can move their holdings between the two. I 
don't see how this would open doors to bureaucracy and unfairness, 
rather it is a transparent process.



NIRs are never meant to be "mini-RIRs"or something in that line.



By ICANN ICP-2 that estabilish the criteria for new RIRs and
process of Policy Development and don't say a word about NIRs.

The ICP-2 process does not cover the establishment of NIRs, therefore 
ICP-2 is irrelevant in their discussion. Should the NIR wish to 
convert to becoming an RIR then yes, ICP-2 would then apply.


Any numbering resources assigned to a RIR must be treated under the 
policies developed by that RIR community. No resources would arrive to a 
NIR if not via the RIR which have always the ultimate prerogative to 
revoke and re-assign resources when policies say so, therefore ICP-2 at 
the end is what matters with regarding the policy development process 
applied to that community and that must be followed and applied by any 
NIR below that RIR. Not NIRs are out of the umbrella of a RIR when 
regarding IP space management.



Again, one thing are specific administrative specificity that may
be required in certain countries and jurisdictions and another are
the policies that are developed by the community of that RIR in a
bottom-up process.

If I interpreted that correctly, you said that it's one thing for an 
NIR to define a policy that is legally mandated, but it's another 
thing for an RIR to define a policy using a bottom-up approach. If 
that is correct, the two cannot be compared as the legally mandated 
policy has a legal requirement for its implementation, whereas 
policies at an RIR that follow a PDP don't have legal requirements for 
implementation (in the sense that law states that they must be 
implemented). If the Australian government were to pass legislation 
which required APNIC to operate in a certain manner or to implement a 
specific policy, I'm sure APNIC's legal counsel would be all over it 
before we even caught wind of it.


No NIRs should ever be mandated to do something regarding how the to 
manage IP space. Only community can do that via the proper process. NIR 
in their jurisdictions may have administrative and legal obligations 
that apply to that context which are different things.


Fernando


Regards,
Christopher Hawker


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[sig-policy] Re: New proposal: prop-158-v001: IPv6 auto-allocation for each IPv4 request

[MAEMURA Akinori]

Chiristopher, Fernando et al,


I am an employee of the entity which runs an NIR.  Let me clarify on some points 
which have appeared in this thread.


1) an NIR needs to enter into  "APNIC and NIR Member Relationship Agreement" and 
needs to comply with it. Its article 3.2-e stipulates


"Enter into a formal membership agreement or other suitable contractual 
arrangement with its own members or account holders who receive Internet 
resources from the NIR Member, requiring such members or account holders to 
comply with resource and address management policies which are consistent, and 
not in conflict, with APNIC Address Management Policies, and to take all 
reasonable steps to enforce compliance with such agreement or arrangement;"


therefore, the NIR's policy should be consistent and not in conflict with 
APNIC's one.


2) This doesn't mean "NIR shouldn't think about its own policy" but "NIR can 
think about its own policy if it be consistent and not in conflict with APNIC's 
one".  Some NIRs predate APNIC as David pointed out, some has additional 
constraint by national law and there may be local circumstances, which may 
require a bit different setup domestically.


3) In JPNIC case we had elaborated our own policy process to have an independent 
community process to develop JPNIC's IP address policy and established the 
mechanism to develop policies which the local community wants and at the same 
time which are consistent with APNIC's one.  It was presented by Mr NAKAGAWA 
Akira, Chair of Japan's forum, in APNIC56 in Kyoto.


https://conference.apnic.net/56/assets/files/APJS642/ip-address-as-commun_1694574856.pdf

Maybe it's beyond your imagination, but we are doing our policy process with 
consistency with APNIC's one well taken into account.  If you had any unclear 
point, I will try to answer as far as I can.


Hope it helps,

Akinori


On 2024/01/24 8:49, Christopher Hawker wrote:


They play a important administrative role in certain places and economies,
but that doesn't mean they should be allowed to develop policies.

I disagree. As David has identified, NIRs may in some cases may have legal 
mandates set by the governments of their economies relating to the management 
of address space which may not be relevant to other economies. In these 
circumstances it would be appropriate for these NIRs to set these policies at 
an economy level, rather than that of a regional level. Further, some NIR 
policies may be defined as a means to better serve their communities whereas 
they could be detrimental to others (not saying that they would).


Allowing this to happen open doors to unnecessary discrepancies,
bureaucracy and sometimes unfairness within the same RIR region which
should not exist.

Again, I disagree. NIRs that fall under APNIC are seen and treated as regular 
APNIC members and any relationship between an LIR and an NIR is exactly that - 
between them. Network operators within NIR service regions are welcome to 
choose whether to obtain resources directly from APNIC or their NIR and can 
move their holdings between the two. I don't see how this would open doors to 
bureaucracy and unfairness, rather it is a transparent process.


I just found really strange when you write a proposal in APNIC having to
specify in the text if that policy is to be apply also to the NIRs. This
type of things should never be necessary.

To my knowledge, you do not need to expressly state whether a policy applies 
at an RIR level only or must apply to members of NIRs as well. An NIR is 
permitted to define their own policies, however, under APNIC's policies any 
policy defined by an NIR must not conflict with an APNIC policy.


By ICANN ICP-2 that estabilish the criteria for new RIRs and process of
Policy Development and don't say a word about NIRs.

The ICP-2 process does not cover the establishment of NIRs, therefore ICP-2 is 
irrelevant in their discussion. Should the NIR wish to convert to becoming an 
RIR then yes, ICP-2 would then apply.


Since any resources are allocated to RIRs and than to NIRs they must
always be submit to the policies developed solely by that RIR community
and that is quiet reasonable.

As NIRs within the APNIC service region are members of APNIC themselves, yes, 
they are subject to the policies as defined by APNIC and its members through 
the PDP. NIRs have special agreements and MoUs in place that allow and afford 
them other roles, responsibilities and functions.


Again, one thing are specific administrative specificity that may be
required in certain countries and jurisdictions and another are the
policies that are developed by the community of that RIR in a bottom-up
process.

If I interpreted that correctly, you said that it's one thing for an NIR to 
define a policy that is legally mandated, but it's another thing for an RIR to 
define a policy using a bottom-up approach. If that is correct, the two 

[sig-policy] Re: New proposal: prop-158-v001: IPv6 auto-allocation for each IPv4 request

[Christopher Hawker]

They play a important administrative role in certain places and economies, but that doesn't mean they should be allowed to develop policies.

I disagree. As David has identified, NIRs may in some cases may have legal mandates set by the governments of their economies relating to the management of address space which may not be relevant to other economies. In these circumstances it would be appropriate for these NIRs to set these policies at an economy level, rather than that of a regional level. Further, some NIR policies may be defined as a means to better serve their communities whereas they could be detrimental to others (not saying that they would).

Allowing this to happen open doors to unnecessary discrepancies, bureaucracy and sometimes unfairness within the same RIR region which should not exist.

Again, I disagree. NIRs that fall under APNIC are seen and treated as regular APNIC members and any relationship between an LIR and an NIR is exactly that - between them. Network operators within NIR service regions are welcome to choose whether to obtain resources directly from APNIC or their NIR and can move their holdings between the two. I don't see how this would open doors to bureaucracy and unfairness, rather it is a transparent process.

I just found really strange when you write a proposal in APNIC having to specify in the text if that policy is to be apply also to the NIRs. This type of things should never be necessary.

To my knowledge, you do not need to expressly state whether a policy applies at an RIR level only or must apply to members of NIRs as well. An NIR is permitted to define their own policies, however, under APNIC's policies any policy defined by an NIR must not conflict with an APNIC policy.

By ICANN ICP-2 that estabilish the criteria for new RIRs and process of Policy Development and don't say a word about NIRs.

The ICP-2 process does not cover the establishment of NIRs, therefore ICP-2 is irrelevant in their discussion. Should the NIR wish to convert to becoming an RIR then yes, ICP-2 would then apply.

Since any resources are allocated to RIRs and than to NIRs they must always be submit to the policies developed solely by that RIR community and that is quiet reasonable.

As NIRs within the APNIC service region are members of APNIC themselves, yes, they are subject to the policies as defined by APNIC and its members through the PDP. NIRs have special agreements and MoUs in place that allow and afford them other roles, responsibilities and functions.

Again, one thing are specific administrative specificity that may be required in certain countries and jurisdictions and another are the policies that are developed by the community of that RIR in a bottom-up process.

If I interpreted that correctly, you said that it's one thing for an NIR to define a policy that is legally mandated, but it's another thing for an RIR to define a policy using a bottom-up approach. If that is correct, the two cannot be compared as the legally mandated policy has a legal requirement for its implementation, whereas policies at an RIR that follow a PDP don't have legal requirements for implementation (in the sense that law states that they must be implemented). If the Australian government were to pass legislation which required APNIC to operate in a certain manner or to implement a specific policy, I'm sure APNIC's legal counsel would be all over it before we even caught wind of it.
Regards,Christopher Hawker
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[sig-policy] Re: New proposal: prop-158-v001: IPv6 auto-allocation for each IPv4 request

[Fernando Frediani]

Hello David

On 23/01/2024 12:08, David Conrad wrote:



You appear to have an interesting perception of the function/prerogative of 
NIRs.  You are aware that some NIRs pre-date the RIRs and generally, NIRs 
reflect the preferences (or, in some cases, legal mandates) related to the 
management of address space by the Internet community within their economy, 
right?
Sure I am. Why interesting ? Interesting in my view is to allow them to 
have this prerogative.
In cases where NIRs pre-date RIRs resources allocated at the point in 
time may just be treated as legacy, but since the existence of all 5 
current RIRs no unallocated address assignment should have been done 
other than through the RIRs therefore any rules that apply to these 
resources must be the ones developed by the community of that RIR.
Don't get me wrong, I am not against the existence of the NIRs. They 
play a important administrative role in certain places and economies, 
but that doesn't mean they should be allowed to develop policies. Their 
community and preferences may well be manifested in the proper Policy 
Development Forum of the respective RIR as in most RIRs.
Allowing this to happen open doors to unnecessary discrepancies, 
bureaucracy and sometimes unfairness within the same RIR region which 
should not exist. I just found really strange when you write a proposal 
in APNIC having to specify in the text if that policy is to be apply 
also to the NIRs. This type of things should never be necessary.



NIRs should restrict their functions to administrative functions at regional or 
national level and leave exclusively with the RIR the ability to set and check 
the compliance of what is the current rule.

By what right/under what authority do you believe the behavior of NIRs should 
be constrained?
By ICANN ICP-2 that estabilish the criteria for new RIRs and process of 
Policy Development and don't say a word about NIRs. Since any resources 
are allocated to RIRs and than to NIRs they must always be submit to the 
policies developed solely by that RIR community and that is quiet 
reasonable.


Again, one thing are specific administrative specificity that may be 
required in certain countries and jurisdictions and another are the 
policies that are developed by the community of that RIR in a bottom-up 
process.


Regards
Fernando



Regards,
-drc
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[sig-policy] Re: New proposal: prop-158-v001: IPv6 auto-allocation for each IPv4 request

[David Conrad]

Fernando,

On Jan 23, 2024, at 12:15 AM, Fernando Frediani  wrote:
> On 15/01/2024 21:34, Christopher Hawker wrote:
>> 
>> > One thing that must end in APNIC is the possibility for NIR to have their 
>> > own set of policies.
>> 
>> An NIR at the APNIC level, is treated as any other APNIC member with the 
>> exception of the fees they charge. They effectively perform the same 
>> functions as an RIR, with the exception that they perform it at an economy 
>> level and not a regional level. They also do so much more than just existing 
>> to "facilitate language and cultural stuff". Why should NIRs not be able to 
>> form their own policies that may better align with their economy's systems 
>> and processes, after consultation with their members and APNIC? This is akin 
>> to saying that RIRs should not be able to adopt their own policies and 
>> instead should operate under one global policy system.
>> 
> They should not because it is not their function nor their prerogative. This 
> belongs to RIRs only and if NIRs are doing more than they should it is not a 
> justification for them to make up rules they don't have prerogative to do. 

You appear to have an interesting perception of the function/prerogative of 
NIRs.  You are aware that some NIRs pre-date the RIRs and generally, NIRs 
reflect the preferences (or, in some cases, legal mandates) related to the 
management of address space by the Internet community within their economy, 
right?

> NIRs should restrict their functions to administrative functions at regional 
> or national level and leave exclusively with the RIR the ability to set and 
> check the compliance of what is the current rule.

By what right/under what authority do you believe the behavior of NIRs should 
be constrained?

Regards,
-drc

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[sig-policy] Re: New proposal: prop-158-v001: IPv6 auto-allocation for each IPv4 request

[Christopher Hawker]

> One thing that must end in APNIC is the possibility for NIR to have their own set of policies.
An NIR at the APNIC level, is treated as any other APNIC member with the exception of the fees they charge. They effectively perform the same functions as an RIR, with the exception that they perform it at an economy level and not a regional level. They also do so much more than just existing to "facilitate language and cultural stuff". Why should NIRs not be able to form their own policies that may better align with their economy's systems and processes, after consultation with their members and APNIC? This is akin to saying that RIRs should not be able to adopt their own policies and instead should operate under one global policy system.
> Isn't /32 the default allocation to any ISP type of ASN (or should be) ? Why /34 ?
Yes, the minimum allocation is a /32 (an oversight on my part). Should this proposal gain consensus and be implemented, and If a member were to apply for a /24 v4 prefix for ISP/multihoming use, they would be automatically provided with a /32 v6 allocation which results in a higher fee being payable by the member. I do not believe this is the author's intention. In this case, I would recommend the authors amend the proposal to allow for longer v6 prefixes to be allocated for ISP/multihoming use.
Regards,Christopher Hawker
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[sig-policy] Re: New proposal: prop-158-v001: IPv6 auto-allocation for each IPv4 request

[Christopher Hawker]

Hi David and Andri,
If I understand the proposal correctly, the idea is to provide IPv6 space to applicants when receiving IPv4, and require them to dual-stack when deploying a network, yes?
A few things I'd like to get clarification on:

If a new member were to apply for a /24 or /23 IPv4 prefix they could apply at the same time for up to a /34 or /33 IPv6 prefix (respectively) without affecting the membership fee. What size delegation do you propose if someone applies for a /24 or /23 IPv4 prefix respectively, or would this be left to the discretion of APNIC to determine?
Looking at the policy solution, I see that it refers to both APNIC and NIR members. To my knowledge, NIRs have their own set of policies they implement provided they don't directly conflict with APNIC's policies. How would this apply to resource applications from organisations to NIRs?
If a member receives a IPv6 delegation alongside an IPv4 delegation and they do not deploy IPv6 within the timeframe allotted, do they lose the right to the IPv4 space as well?
Is this designed to be retrospectively applied to existing members that only hold IPv4 address space, or only applications from new members?
If this is not retrospectively applied and a new member operates a stub network that uses an upstream which has not adopted IPv6, will the new member be considered as failing to adopt IPv6?

I don't believe that this policy will change the pricing scheme, because if a member applies for (as an example) a /24 v4 prefix they can receive up to a /34 v6 prefix with no change in the member fee they pay (see #1 above).
I like the idea and support the concept, I just believe it needs a bit of clarification and completeness before it is adopted (should it reach consensus).
Regards,Christopher Hawker
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