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Secretariat Impact Assessment

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APNIC notes this proposal suggests increasing the maximum IPv4 delegation size for new APNIC account holders from a /23 to a /22 and, if requested, delegating an additional /23 for current APNIC account holders with less than a total of a /21 of IPv4 addresses. Current APNIC account holders with a total amount of IPv4 addresses equal to and more than a /21 are not eligible for further IPv4 delegations.

APNIC believes that the eligibility criteria for this proposal are unclear and raises the following concerns:

      1. The proposal assumes that all IPv4 addresses marked as reserved can be delegated to the account holders. However, some of these addresses are reserved for specific policy and these cannot be delegated under this proposal. For example, a /21 IPv4 address space is reserved for experimental allocations.

      2. There is a risk that current account holders who have already transferred IPv4 address space from their account may use this proposal to request additional IPv4 addresses for market transfers. The same could happen to new account holders in the future.

      3. The proposed solution will create disparity among account holders. Current account holders who have received /22 + /23 + /24 are eligible for another /23 under this proposal, bringing their total to /21 + /24. At the same time, current account holders with a total IPv4 addresses equal to or greater than /21 are not eligible. It is unclear why new account holders will be eligible for a maximum of /22, whereas current account holders who already have a /22 will be eligible for an additional /23.

      4. Please note that the recent data shared by the Secretariat on the Policy SIG mailing list shows that if all current members with less than /21 request additional address space under this proposal, APNIC's entire IPv4 free pool would be depleted, and a waiting list may have to be created.

https://orbit.apnic.net/hyperkitty/list/[email protected]/thread/VRB466LT3NCFMGSA2N3D27VX3QXINJLP/

This proposal makes no mention of the current policy which states that IPv4 addresses delegated from the available pool cannot be transferred for a minimum of five years after the initial delegation. However, if this proposal is accepted by the community, it will be subject to this restriction.

To address some of these concerns, APNIC recommends that the authors and community simplify the proposal. A suggested proposed solution is as follows:

---
New APNIC account holders are eligible for a maximum of /## IPv4 addresses from the APNIC available pool.

Current APNIC account holders are eligible to request an additional /## Ipv4 delegation (provided the total Ipv4 addresses holding is not exceeding /##) from the APNIC available pool, provided the applicant meets these terms:       •    No IPv4 addresses have been transferred out of the account holder’s account since joining APNIC.       •    According to the current policy, IPv4 addresses delegated under this proposal cannot be transferred for a minimum of five years after the original delegation.

This policy will remain in effect until APNIC has exhausted all available IPv4 addresses. Following that, requests will be placed in the first-come-first-served waiting list to delegate IPv4 addresses as they become available, with no guarantees.
---

If this proposal reaches consensus and is endorsed by the EC, implementation will require changes to systems, procedures, and service level agreements.  The Secretariat also believes a likely rush by Members to apply for additional IPv4 space will mean additional staff will need to be recruited and trained to handle a high volume of requests in a short period of time.  For these reasons, implementation may be completed in eight to nine months.

Regards,
Sunny

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_______________________________________________________________________

Srinivas (Sunny) Chendi (he/him)
Senior Advisor - Policy and Community Development

Asia Pacific Network Information Centre (APNIC) |  Tel: +61 7 3858 3100
PO Box 3646 South Brisbane, QLD 4101 Australia  |  Fax: +61 7 3858 3199
6 Cordelia Street, South Brisbane, QLD          |  http://www.apnic.net
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On 20/01/2023 10:22 am, Bertrand Cherrier wrote:
Dear SIG members,

The proposal "prop-149: Change of maximum delegation for less than /21 total
IPv4 holdings" has been sent to the Policy SIG for review.

It will be presented at the Open Policy Meeting (OPM) at APNIC 55 on
Wednesday, 1 March 2023.

https://conference.apnic.net/55/program/schedule/#/day/10

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-149

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


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prop-149-v001: Change of maximum delegation for less than /21 total IPv4 holdings

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Proposer: Shubham Agarwal ([email protected])
          Gaurav Kansal [email protected]


1. Problem statement
--------------------
Over the last three years, no more than 8,00,000 IPv4 addresses have been reassigned in a single year.

Status of IPv4 Allocation by APNIC in 2022:

Available Pool: 2,593,792 IPv4 Address | about 5,066 Of /23
Reserved Pool: 1,702,144 IPv4 Address | about 3,300 Of /23

A sizable portion of the IPv4 pool is 'available+reserved' at APNIC. If APNIC continues to delegate /23 IPv4 at its current rate of 145 x /23 delegations per month, the pool will be depleted by the end of 2027.

This implies that a significant portion of the IPv4 address space will remain available or unallocated for an extended period of time, and that a sizable community may continue to face resource shortages.

This is a proposal to give APNIC account holders with fewer than /21 delegated IPv4 resources (i.e. fewer
than 2,048 IPs) access to an additional /23 IPv4 address block.


2. Objective of policy change
-----------------------------
According to the current IPv4 allocation policy, APNIC account holders are only qualified to receive IPv4 address delegations totaling a maximum of 512 (/23) from the APNIC 103/8 IPv4 address pool. The current minimum delegation size for IPv4 is 256 (/24) addresses. It is as per APNIC defined current minimum and
maximum IPv4 delegation policy.

Thus, this proposal permits account holders to use an additional /23 if their total number of delegated
IPv4 addresses is fewer than 2,048 (less than /21).

Due to the increase in the maximum IPv4 delegation size from 512 (/23) to 1024 (/23 + /23) address pool, the number of IPv4 address resources will increase for new and existing APNIC account holders with a
total number of delegated IPv4 addresses less than 2,048 (less than /21).


3. Situation in other regions
-----------------------------
Other RIR regions do not have a similar policy in place.


4. Proposed policy solution
---------------------------
Current Policy text:

Since Thursday, 28 February 2019, each APNIC account holder is only eligible to receive IPv4 address delegations totaling a maximum /23 from the APNIC 103/8 IPv4 address pool.

Proposed Policy text:

New APNIC account holders are eligible to receive a maximum 1024 (/22) from the APNIC available IPv4 address pool. Current APNIC account holders with less than /21 total IPv4 resources, are eligible to recieve an additional /23 IPv4 delegation and must be requested. Account holders with total IPv4 resources equal to and more than /21 are not eligible for further IPv4 delegations.

This policy will be in effect till APNIC runs out of all IPv4 addresses.


5. Advantages / Disadvantages
-----------------------------
Advantages:
- This proposal allows for more IPv4 addresses to be received.
- This proposal increases the total number of IPv4 addresses that can be made available to networks, developing
nations, small and medium-sized businesses (SMBs), etc.

Disadvantages:
- No disadvantages are foreseen.


6. Impact on resource holders
-----------------------------
It increases the maximum size of a delegated address block available to some APNIC account holders who currently
have limited IPv4 resources.
NIR members will be affected in the same way as APNIC account holders.


7. References
-------------
https://www.apnic.net/community/policy/resources#a_h_6_1


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