Hi,

I do not like any proposal that will restrict some of the rights a 'new' member has as compared to the rights of a member from pre-2011.

Companies that are members after 2011 will see their right to transfer IP addresses restricted (as most of these only have IPs from the 'Final /8').

IF this proposal becomes policy, some IP transfers will be moved underground while some others will be 'painted' as M&As.

So, *no* support from me.

regards,

elvis


On 9/26/16 12:50 PM, Alastair Johnson wrote:
I agree with Mike. I don't support this proposal.

AJ

On Sep 26, 2016, at 2:26 PM, HENDERSON MIKE, MR <michael.hender...@nzdf.mil.nz <mailto:michael.hender...@nzdf.mil.nz>> wrote:

The objectives of this proposal are laudable, but in my view policy development for IPv4 is just ‘rearranging the deck chairs on the Titanic’: a waste of time and effort.

I do *not* support this proposal

Regards

*/Mike/*

*From:*sig-policy-boun...@lists.apnic.net <mailto:sig-policy-boun...@lists.apnic.net> [mailto:sig-policy-boun...@lists.apnic.net] *On Behalf Of *Masato Yamanishi
*Sent:* Monday, 26 September 2016 11:06 p.m.
*To:* sig-policy@lists.apnic.net <mailto:sig-policy@lists.apnic.net>
*Subject:* [sig-policy] New version of prop-116: Prohibit to transfer IPv4 addresses in the final /8 block

Dear SIG members

A new version of the proposal "prop-116: Prohibit to transfer IPv4
addresses in the final /8 block" has been sent to the Policy SIG for
review.

Information about earlier versions is available from:

http://www.apnic.net/policy/proposals/prop-116

You are encouraged to express your views on the proposal:

 - Do you support or oppose the 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,

Masato, Sumon

-------------------------------------------------------

prop-116-v002: Prohibit to transfer IPv4 addresses in the final /8 block

-------------------------------------------------------

Proposer:       Tomohiro Fujisaki
fujis...@syce.net <mailto:fujis...@syce.net>




1. Problem statement
--------------------

There are a lot of transfers of IPv4 address blocks from 103/8
happening, both within the APNIC region and among RIRs.

Then number of transfer from 103/8 block are about 200, which is
about 12% of the total number of transfers. This looks so hight
high, since APNIC manages about 40/8.

And based on the information provided by APNIC secretariat, number
of transfers from the 103/8 block are increasing year by year.

Provided by George Kuo on the sig-policy ML at 8th September 2016:

1) M&A 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 |
+------+-----------+-----------+


And also, transfers from the 103/8 block include:
  - Take place within 1 year of distribution, or
  - Multiple blocks to a single organization in case of beyond 1 year.

Further, there is a case where a single organization have received 12
blocks transfers from 103 range.

see: https://www.apnic.net/transfer-resources/transfer-logs <https://www.apnic.net/transfer-resources/transfer-logs>

From these figures, it is quite likely that substantial number of 103/8
blocks are being used for transfer purpose.

This conflicts with the concept of distribution of 103/8 block
(prop-062), which is intended to accommodate minimum IPv4 address blocks
for new comers.

 prop-062: Use of final /8
 https://www.apnic.net/policy/proposals/prop-062


2. Objective of policy change
-----------------------------

When stated problem is solved, distribution from 103/8 block will be
consistent with its original purpose, for distribution for new entrants
to the industry. Without the policy change, substantial portion of 103/8
blocks will be consumed for transfer purpose.


3. Situation in other regions
-----------------------------

RIPE-NCC has been discussing to prohibit transfer under the final /8
address block.


4. Proposed policy solution
---------------------------

Prohibit transfer IPv4 address under /8 address block (103/8).
If the address block allocated to a LIR is not needed any more, it have
to return to APNIC to allocate to another organization.

In the case of transfers due to M&A, merged organization can have
up to /22 IPv4 address in the 103/8 block. The 103/8 IPv4 address
more than /22  have to return to APNIC to allocate to another
organization.


5. Advantages / Disadvantages
-----------------------------

Advantages:
  - It makes 103/8 blocks available according to the original purpose,
    as distribution for new entrants (rather than being consumed for
    transfer purpose)

  - IPv4 addresses under final /8 are not transferred to outside APNIC.

  - By prohibiting transfer them, it is possible to keep one /22 for
    each LIRs state,  which is fair for all LIRs.

Disadvantages:

None.


6. Impact on resource holders
------------------------------

  - LIRs cannot transfer address blocks under 103/8. No big impact while
    they use it.

  - Organizations which needs to receive transferred IPv4 can continue
    to do so, outside 103/8 blocks (which should be made available for
    new entrants)


7. References
-------------

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