Hi Elvis,
Even though I also don't support the policy as it stands but...

> 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.
>
Why not? If you are late to the party then there are no free drinks for
you.. simple is that isn't it?

> 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').
>
Wrong, they all have /22 from final /8 and another /22 from IANA recovered
pool.

> IF this proposal becomes policy, some IP transfers will be moved
> underground
>
People are still leasing out IPv4 as we speak.. its not the right thing
from any perspective but its happening and it will happen in future as
well..

> while some others will be 'painted' as M&As.
>
 Yes, it will happen no matter what policy you put in place..

> So, *no* support from me.
>
I agree with that as well :)

> 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 <
> [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:[email protected]
> <[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. References
> -------------
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-- 
Best Wishes,

Aftab A. Siddiqui
*              sig-policy:  APNIC SIG on resource management policy           *
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