I agree that there's an element of 'deck chair rearrangement' but it's a reality that there is a commercial market for IPv4 and competitive value in having addresses available. To simply say 'who cares about IPv4, move on' will simply encourage predatory practices.
I have no doubt that the M&A process will be used to abuse the process, and believe there needs to be a deterrent to the abuse of the bureaucratic process. But legitimate M&A needs to be permitted (having had to engage this process in the last couple of years due to organisational and commercial changes at my then-employer, I wouldn't want to see that process made any more complex than necessary). I think that the modified proposal has merit for that reason, and would support it. Mark. On Tue, Sep 27, 2016 at 8:50 AM, Alastair Johnson <[email protected]> wrote: > I agree with Mike. I don't support this proposal. > > AJ > > On Sep 26, 2016, at 2:26 PM, HENDERSON MIKE, MR < > [email protected] <[email protected]>> 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:* [email protected] [mailto:sig-policy-bounces@ > lists.apnic.net <[email protected]>] *On Behalf Of *Masato > Yamanishi > *Sent:* Monday, 26 September 2016 11:06 p.m. > *To:* [email protected] > *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 > [email protected] > > > > > 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 > > 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. 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