Dear SIG members,
A new proposal "prop-157-v001: Temporary IPv4 Transfers" has been sent to
the Policy SIG for review.
It will be presented at the Open Policy Meeting (OPM) at APNIC 57 on
Thursday, 29 February 2024.
https://2024.apricot.net/program/program/#/day/9/
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-157
Regards,
Bertrand, Shaila, and Anupam
APNIC Policy SIG Chairs
---------------------------------------------------------------
prop-157-v001: Temporary IPv4 Transfers
----------------------------------------------------------------
Proposer: Jordi Palet Martinez ([email protected])
1. Problem statement
--------------------
When in the community we discuss the need for leasing, understood
broadly in any of its possible modalities, as one of the mechanisms to
facilitate small sets of IPv4 addresses for the transition to IPv6,
specially for new actors, there are mixed feelings about accepting the
leasing or not. However, we are forgetting that there is already a
mechanism, already accepted by the community, that could be slightly
modified to be equivalent to a leasing, and yet have many advantages for
both parties: temporary transfers.
It is about guaranteeing compliance with the policies with a system
equivalent to leasing, and that makes it easier to avoid security
problems, keeping the control by the RIR/NIR, and the security of the
return of the addresses when the leasing period concludes.
At the same time, it seeks to cover the need to be flexible without
excessive operational burden for the RIR/NIR, so that the leasing period
can be simply extended, since it is understood that there may be
situations in which the initially agreed period may be insufficient.
It is important to emphasize that those who need these transfers, as a
“leasing”, tend to be smaller entities or with more moderate initial
investments and consequently are financially weaker. Therefore, given
that the ultimate goal must be the deployment of IPv6, using IPv6-only
and IPv4aaS, the number of IPv4 addresses that may be needed will be
truly reduced.
Finally, it seeks to prioritize the benefit of the region and therefore
it makes sense that it is only applicable to operations carried out
within the region. Furthermore, this prevents permanent transfers from
losing reciprocity with those regions that require it.
The EC could establish specific rates for this type of transfers and/or
their extensions.
2. Objective of policy change
-----------------------------
APNIC current policies only allow permanent IPv4 address transfers.
This proposal specifies a change in the policy to allow temporary
transfers.
3. Situation in other regions
-----------------------------
As far as we know, only in RIPE NCC temporary transfers are allowed. At
the same time, RIPE NCC does not contemplate leasing, but it does not
explicitly prohibit it either.
In AFRINIC and LACNIC, neither leasing nor temporary transfers are
contemplated. However, an equivalent proposal has been submitted in LACNIC.
Temporary transfers are not contemplated in ARIN, and leasing is not a
valid justification of the need. When leasing addresses, no more
addresses can be requested. Additionally, certain blocks cannot be leased.
4. Proposed policy solution
---------------------------
Actual text:
11.0. IPv4 transfers
APNIC will maintain a public log of all number resource (IPv4, IPv6,
ASN) transfers, including unused (market) transfer, merger and
acquisitions, and historical resource transfer.
11.1. IPv4 transfers within the APNIC region
APNIC will process and record IPv4 address transfer requests between
current APNIC account holders subject to the following conditions.
11.1.1. Conditions on the space to be transferred
The minimum transfer size is a /24.
The address block must be:
• In the range of addresses administered by APNIC
• Allocated or assigned to a current APNIC account holder
• The address block will be subject to all current APNIC policies
from the time of transfer.
• Addresses delegated from the 103/8 free pool cannot be transferred
for a minimum of five years after the original delegation.
11.1.3. Conditions on recipient of the transfer
The recipient will be subject to current APNIC policies. Recipients that
do not already hold IPv4 resources must demonstrate a detailed plan for
the use of the transferred resource within 24 months. Recipients that
already hold IPv4 resources must:
• Demonstrate a detailed plan for the use of the transferred resource
within 24 months,
• Show past usage rate, and
• Provide evidence of compliance with APNIC policies with respect to
past delegations.
Proposed text:
11.0. IPv4 transfers
APNIC will maintain a public log of all number resource (IPv4, IPv6,
ASN) transfers, including unused (market) transfer, merger and
acquisitions, and historical resource transfer.
In the case of temporary IPv4 transfers, the log will contain the
initial date of the transfer, as well as the final one. The final date
will have no value for the permanent transfers, however for the
temporary ones, will be the date when the transfer period ends. This
value must be updated if the transfer period is extended by agreement of
both parties, which must be legitimized by APNIC.
The extension must be anticipated by a minimum of 30 days before the
previously agreed end-date.
In the case of temporary transfers, APNIC will restore the original
registration information in the Whois Database once the transfer period
is over.
11.1. IPv4 permanent and temporary transfers within the APNIC region
APNIC will process and record permanent and temporary IPv4 address
transfer requests between current APNIC account holders subject to the
following conditions.
11.1.1. Conditions on the space to be transferred
The minimum transfer size is a /24.
In case of temporary transfers, the maximum prefix (in total) that a
single recipient can get, is a /22.
The address block must be:
• In the range of addresses administered by APNIC
• Allocated or assigned to a current APNIC account holder
• The address block will be subject to all current APNIC policies
from the time of transfer.
• Addresses delegated from the 103/8 free pool cannot be transferred
for a minimum of five years after the original delegation.
11.1.3. Conditions on recipient of the transfer
The recipient will be subject to current APNIC policies. Recipients that
do not already hold IPv4 resources must demonstrate a detailed plan for
the use of the transferred resource within 24 months. Recipients that
already hold IPv4 resources must:
• Demonstrate a detailed plan for the use of the transferred resource
within 24 months,
• Show past usage rate, and
• Provide evidence of compliance with APNIC policies with respect to
past delegations.
In the case of temporary transfers, the plan for usage will match the
initial expected transfer period, instead of 24 months.
11.1.4. Additional conditions for temporary transfers
Temporary transfers are subjected to additional conditions, which in
case of lack of compliance, will imply the immediate revocation of the
temporary transfer:
• The transfer contract among the parties must include terms of
transfer cancellation in case of usage of the resources for network abuse.
• The recipient must have an ASN to announce the transferred resources.
• The recipient must have operational IPv6 when announcing the IPv4
transferred resources.
• The recipient must have RPKI for the transferred resources.
• The IRR and geolocation must be correctly updated.
• The recipient must follow MANRS best practices.
5. Advantages / Disadvantages
-----------------------------
Advantages:
It allows a way to obtain resources in a temporary basis, in order to
facilitate the IPv6 deployment in a convenient and cheaper way than
permanent transfers, which is especially important for smaller
organizations and newcomers.
Disadvantages:
None.
6. Impact on resource holders
-----------------------------
None.
7. References
-------------
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