I would think that in any case where there is a (valid and verified) request which cannot be fulfilled otherwise, but could be fulfilled by early termination of the quarantine period that APNIC should contact the requestor and offer them the option of accepting the space in that condition. Once informed consent is obtained, I would expect APNIC to make a good faith effort to complete any remaining quarantine activities (with added caution not to step on the new recipient).
If this requires a policy proposal I can submit one, but I think it’s a fairly common sense approach to the circumstance, should it arise. Owen > On Jan 29, 2024, at 16:20, Sunny Chendi <[email protected]> wrote: > > Dear SIG members, > > The Secretariat's impact assessment for this proposal is provided below as > well as published at: > http://www.apnic.net/policy/proposals/prop-157 > > APNIC notes that this proposal suggests a policy modification that would > allow for temporary transfers between account holders (applying to intra-RIR > transfers, e.g. APNIC and NIR account holders, but not inter-RIR transfers, > e.g. APNIC to another RIR). > > Questions/Comments: > - APNIC would like to remind the community that the current policy outlined > in Section 11.1.2. “Conditions on the source of the transfer” which applies > to ‘permanent’ transfers would also apply to ‘temporary’ transfers if this > proposal reaches consensus. > > - Based on the current wording of the APNIC Fee Schedules, Transfer Fees > would be applicable to the temporary transfers. > > - The intent of the proposed text appears to be that APNIC update the > existing transfer log to include temporary transfers, however this would > change the meaning of the file in a fundamental way that will likely cause > problems for some clients (mainly because an entry in that log no longer > represents a permanent transfer). APNIC suggests that the temporary transfers > should be logged separately from permanent transfers for this reason. > > - The proposal suggests that the transfer contract "include terms of transfer > cancellation in case of usage of the resources for network abuse." If the > intention is that APNIC revoke resources for network abuse, APNIC will not be > able to do so under this provision as APNIC cannot enforce the terms of a > contract it is not a party to. > > - Does the author propose that APNIC will implement a temporary transfers > agreement template and standardised the process in a similar way to RIPE NCC? > > - Ensuring compliance with MANRS practices would require APNIC to monitor and > enforce policies over which it has no control. How does the author propose > APNIC ensure compliance with ‘11.1.4. Additional conditions for temporary > transfers’, especially "The recipient must follow MANRS best practices."? > > Implementation: > This proposal may require changes to APNIC systems. If this proposal reaches > consensus, implementation may be completed within three months. > > Regards, > Sunny > APNIC Secretariat > > On 14/12/2023 12:55 pm, Bertrand Cherrier wrote: >> 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://aus01.safelinks.protection.outlook.com/?url=https%3A%2F%2F2024.apricot.net%2Fprogram%2Fprogram%2F%23%2Fday%2F9%2F&data=05%7C02%7C%7C96c320a0c7bb4e6a778008dbfc501ddd%7C127d8d0d7ccf473dab096e44ad752ded%7C0%7C0%7C638381193266052234%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=wHJMNZRDt48kdnbwDKs2Sc2uGR9ZleDC7IY2kAaAwXQ%3D&reserved=0 >> >> >> 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 >> ------------- >> >> _______________________________________________ >> SIG-policy - https://mailman.apnic.net/[email protected]/ >> To unsubscribe send an email to [email protected] > > _______________________________________________ > SIG-policy - https://mailman.apnic.net/[email protected]/ > To unsubscribe send an email to [email protected] _______________________________________________ SIG-policy - https://mailman.apnic.net/[email protected]/ To unsubscribe send an email to [email protected]
