Dear Dave and Secretariat, Thank you for providing the impact analysis and for your careful review of prop-165. Please find our responses inline below.
On 15 Aug 2025, at 6:35 am, Dave Phelan wrote: >1. APNIC’s Understanding of the Proposed Policy > >This Proposed Policy is unclear due to terminology used in the proposal not >being consistent with the 2.0 Definitions. APNIC does not use the terms PA >(Provider Aggregatable) and PI (Provider Independent) for resource holdings, >and such terms do not have exact equivalents in APNIC-127. We agree. The terms “PA” and “PI” will be removed. Instead, we will revise the proposal to refer to organisations that meet the requirements of section 8.1 of APNIC-114. >The Secretariat notes that resource holders with IPv6 only address allocations >are eligible to receive an IPv4 allocation under existing policy, provided the >relevant needs justification is met. Could you please provide a specific reference to where in the current policy this is described and how it applies? > The Secretariat has the following questions in relation to the Proposed > Policy for which clarification is requested: > >“Organizations qualifying for IPv6 PA allocations may request an IPv4 /24.” >Will this /24 count toward the resource holder’s last /8 holding? >If so, can they also apply for their second /24 under regular IPv4 policy as >the maximum delegation size for IPv4 is currently /23. Yes, our intention is that, including the /24 allocated under this proposal, the total maximum per organisation remains /23. Yes, members may also apply for an additional /24 under the regular IPv4 policy. >“The IPv4 block must be used only for IPv6-only network support.” >How should the Secretariat monitor if their IPv4 is being used to support >their IPv6-only network and not being used for some other purpose? We consider this to be consistent with other policy requirements. We do not expect active monitoring, but rather that the Secretariat would act if non-compliance is later identified. >“The block is non-transferable and cannot be leased.” >How should the Secretariat monitor if the address is being leased? It is our understanding that leasing is already prohibited under current policy. This statement was intended to restate and emphasise the existing restriction. >“Additional usage restrictions apply in accordance with current APNIC >policies.” >Which specific existing usage restrictions are intended to apply? Most >existing usage restrictions are based on the needs justification required >under section 6.2 of APNIC-127 which appears to be intended not to apply under >the Proposed Policy wording. We do not intend to introduce any additional restrictions. This wording will be removed in the next version. We thank the Secretariat for raising these important clarifications, which we will reflect in the next version of the proposal. We plan to publish the revised version before the next SIG meeting. Best regards, Tomohiro Fujisaki and Hiroki Kawabata 2025年8月15日(金) 15:36 Dave Phelan <[email protected]>: > > Dear SIG members, > > > > Here is the Secretariat impact analysis for proposal “prop-165-v001 Provision > of IPv4 Address Space to IPv6-only Networks for Transitional Purpose” and the > same is also published at: > > > > https://www.apnic.net/community/policy/proposals/prop-165/ > > > > 1. APNIC’s Understanding of the Proposed Policy > > This Proposed Policy is unclear due to terminology used in the proposal not > being consistent with the 2.0 Definitions. APNIC does not use the terms PA > (Provider Aggregatable) and PI (Provider Independent) for resource holdings, > and such terms do not have exact equivalents in APNIC-127. > > > > The Secretariat has interpreted the intent of the Proposed Policy as being to > allow resource holders with IPv6 only address allocations to be able to > obtain a /24 IPv4 for transition purposes, without requiring any further > justification of need as is ordinarily required for IPv4 under section 6.2 of > APNIC-127. The Secretariat understands that the Authors believe the burden of > proof for these networks might be too high under current policy. > > > > 2. Impact of Proposed Policy on Registry and Addressing System > > The Secretariat notes that resource holders with IPv6 only address > allocations are eligible to receive an IPv4 allocation under existing policy, > provided the relevant needs justification is met. > > However, the Secretariat is unable to assess the impact of the Proposal on > the Registry and Addressing System based on the Proposed Policy wording. > > > > The Secretariat has the following questions in relation to the Proposed > Policy for which clarification is requested: > > “Organizations qualifying for IPv6 PA allocations may request an IPv4 /24.” > > Will this /24 count toward the resource holder’s last /8 holding? > If so, can they also apply for their second /24 under regular IPv4 policy as > the maximum delegation size for IPv4 is currently /23. > > “The IPv4 block must be used only for IPv6-only network support.” > > How should the Secretariat monitor if their IPv4 is being used to support > their IPv6-only network and not being used for some other purpose? > > “The block is non-transferable and cannot be leased.” > > How should the Secretariat monitor if the address is being leased? > > “Additional usage restrictions apply in accordance with current APNIC > policies.” > > Which specific existing usage restrictions are intended to apply? Most > existing usage restrictions are based on the needs justification required > under section 6.2 of APNIC-127 which appears to be intended not to apply > under the Proposed Policy wording. > > > > 3. Impact of Proposed Policy on APNIC Operation/Services > > Additional work would be required on APNIC core registry back-end and > front-end systems to allow for the delegation of these addresses. > > Additional changes to APNIC’s operating procedures will be required to > account for exceptions to standing policy, including with respect to reduced > demonstrated need (section 6.2 of APNIC-127) and modified transfer > restriction period (section 11 of APNIC-127). > > > > 4. Legal Impact of Proposed Policy > > The Proposed Policy will require a number of amendments to APNIC-127, however > the specific implementation of such changes has not been made clear by the > Authors. This uncertainty may create a number of enforcement and assessment > challenges depending on its implementation, which can be considered further > following clarification of the Secretariat’s questions in Part 2 of this > Impact Analysis. > > > > 5. Implementation > > The Secretariat is unable to confirm the extent of the implication impact on > APNIC systems and operations at this time until further clarification is > provided in response to the questions in Part 2 of this Impact Analysis. > > > > _______________________________________________ > SIG-policy - https://mailman.apnic.net/[email protected]/ > To unsubscribe send an email to [email protected] -- Tomohiro Fujisaki _______________________________________________ SIG-policy - https://mailman.apnic.net/[email protected]/ To unsubscribe send an email to [email protected]
