Dear Colleagues, I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team..
I would like to share key feedback in our community for prop-157,based on a meeting we organised on 31th Jan to discuss these proposals. This feedback is sent on my behalf, but please note that it is a summary of the discussions among the 12 Japanese community members (5 on-site, 7 remote) who attended the meeting. While most participants understood the importance of logging the accutural resouce users, many oppose opinions were expressed about this proposal. (comment details) - Section 11.1.4. establishes a number of additional conditions, but these conditions should not be used to clarification about the transfer. - The method and criteria for checking additional conditions specified in Section11.4.1. are not clear. For example, it is not clear whether additional conditions need to be checked once at the time of application or whether it is necessary to continue to check that additional conditions are met on a regular basis. - At the end of the transfer period, the IP address is to be returned to the original organization. Is justification for IP address usage required at this time? - I believe it is important to record actual users like a this policy. Regards, 2023年12月14日(木) 11:55 Bertrand Cherrier <[email protected]>: > > 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 > ------------- > > _______________________________________________ > 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]
