Dear SIG members,
A new version of the proposal "prop-157-v003: Temporary IPv4 Transfers"
has been sent to the Policy SIG for review.
Information about earlier versions is available from:
http://www.apnic.net/policy/proposals/prop-157
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.
Regards,
Bertrand, Shaila, and Anupam
APNIC Policy SIG Chairs
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prop-157-v003: Temporary IPv4 Transfers
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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. However, there may be other resons for such temporary
transfers, so no limit on the prefix size is proposed.
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 public log will contain the
initial date of the transfer, as well as the final one.
The final date must be updated if the transfer period is extended by
agreement of both parties, which must be legitimized by APNIC.
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.
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 (initial transfer period in case of temporary transfers),
• Show past usage rate, and
• Provide evidence of compliance with APNIC policies with respect to
past delegations.
11.1.4. Additional conditions for temporary transfers
Temporary transfers are subjected to additional conditions, that must be
warranted by the transfer contract among the parties:
• Must include terms of immediate 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 announce the IPv4 transferred resources as well
the IPv6 resources and plan for the IPv6 deployment.
• The recipient must have RPKI for the transferred resources.
• The IRR and geolocation must be correctly updated.
• The recipient must follow MANRS best practices.
The source is responsible for the oversight of those conditions. APNIC
will be able to establish operational practices to ensure compliance.
In case of lack of due diligence by a source, even with different
temporary transfers or recipients, APNIC will initiate a warning, which,
if ignored will trigger the immediate revocation of the resources involved.
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. It also offers a solution of other cases
that can benefit from this proposal.
Disadvantages:
None.
6. Impact on resource holders
--------------------------------
None.
7. References
--------------
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