Dear chairs In my view there is no point in prohibiting transfer as a proxy to prohibiting ’sales' because people will still carry out those sales and all that will happen is that they will not be registered correctly any more.
I also agree with Mike Henderson, with the current role/strategy for RIRs there is no need for any more changes to IPv4 policy. regards Jay > On 30/01/2017, at 12:39 AM, Sumon Ahmed Sabir <[email protected]> wrote: > > 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 and Sumon > > > > > > > ------------------------------------------------------- > > prop-116-v003: 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 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. > > Updated by APNIC Secretariat on 27 January 2017: > > 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 | 63 | 239 | > +------+-----------+------------+- > > 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 | 103 | 394 | > +------+-----------+-----------+ > > 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 > ----------------------------- > > None. > > > 4. Proposed policy solution > --------------------------- > > Prohibit transfer IPv4 addresses under /8 address block (103/8) which > have not passed two years after its allocation/assignment. > If the address block allocated to a LIR in two years is not needed any > more, it must return to APNIC to allocate to another organization > using final /8 policy. > > In the case of transfers due to M&A, merged organization can have > up to /22 IPv4 address in the 103/8 block in principle. If there > are technical reasons such as all address is used in separate networks > and announced from multiple ASes, merged organization can keep them. > Otherwise, the 103/8 IPv4 address more than /22 must return to APNIC > to allocate to another organization using final /8 policy. > > > 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 > ------------- > * sig-policy: APNIC SIG on resource management policy > * > _______________________________________________ > sig-policy mailing list > [email protected] > https://mailman.apnic.net/mailman/listinfo/sig-policy -- Jay Daley Chief Executive NZRS Ltd desk: +64 4 931 6977 mobile: +64 21 678840 linkedin: www.linkedin.com/in/jaydaley * sig-policy: APNIC SIG on resource management policy * _______________________________________________ sig-policy mailing list [email protected] https://mailman.apnic.net/mailman/listinfo/sig-policy
