Dear SIG members,Please see below the Secretariat's impact assessment for this proposal version 003. Which is also posted on the proposal page at:
http://www.apnic.net/policy/proposals/prop-157
The Secretariat 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:_
* The Secretariat notes that temporary transfers under the proposal
would inherit the conditions under section 11.1.2. of the APNIC
Internet Number Resource Policies, being “Conditions on the source
of the transfer”.
* The Secretariat notes that under the redrafted proposal the source
will be responsible for oversight of the criteria set out in section
11.1.4, however APNIC ‘will be able to establish operational
practices to ensure compliance’. Given enforcement actions taken by
APNIC in accordance with such operational practices may encroach on
the responsibilities of the source and thereby increase APNIC’s
liability, it is unclear how it is proposed that APNIC ensure
compliance with section 11.1.4, especially in the event of a dispute
between the parties. The Secretariat will need to develop procedures
and additional conditions (for example under a template transfer
agreement) to account for numerous situations which may arise, such as:
o where there is a disagreement between the source and recipient,
such as:
+ source requests cancellation but the recipient declines, or
if the recipient requests a transfer extension but the
source declines; or
+ source alleges a breach of policy regarding compliance with
MANRS best practice or the correct updating of IRR and
geolocation.
o the treatment of the resources if the source and/or recipient’s
account is closed for any reason (non-payment, company
deregistered etc.).
o if the source account is acquired (such as under a merger or
acquisition scenario) and the acquiring account holder requests
to transfer all their resource to another account, including any
temporary transferred resources.
The time required to consider such scenarios and develop appropriate
conditions and procedures has been factored into the Implementation
period set out below.
* The Secretariat requests clarification of the meaning of the
following sentence in section 11.1.4 – “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.” It is
unclear what is meant by:
o “lack of due diligence by the source”, is this intended to
reference where the source fails to adequately monitor the
criteria in section 11.1.4?
o “even with different temporary transfers or recipients” the
meaning here is unclear.
o “APNIC will initiate a warning” this suggests that APNIC will
still be required to enforce the criteria set out in section
11.1.4 rather than the source.
o “trigger the immediate revocation of the resources involved” is
this intended to refer to the revocation of the temporary
transfer or the revocation of the resources from the original
source, such that they are returned to the free pool for
redelegation?
_Implementation:_
This proposal may require changes to APNIC systems, internal policy,
procedures, and agreements. If this proposal reaches consensus,
implementation may be completed within twelve (12) months.
Regards, Sunny On 5/08/2024 7:01 pm, Bertrand Cherrier via SIG-policy wrote:
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 --------------------------------------------------------------- prop-157-v003: 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. 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 arecontemplated. 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 -------------- _______________________________________________ SIG-policy -https://mailman.apnic.net/[email protected]/ To unsubscribe send an email [email protected]
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