[AfriNIC-rpd] Global Policy for IPv4 Allocations by the IANA Post Exhaustion

[Owen DeLong]

On Nov 16, 2010, at 4:52 PM, Chris Grundemann wrote:

> On Tue, Nov 16, 2010 at 17:22, Sam Dickinson <sam at apnic.net> wrote:
>> Hi Owen
>> 
>> On Nov 13, 2010, at 2:18 AM, Owen DeLong wrote:
>> 
>> <snip>
>> 
>>>>  "Disallow transfers of addresses sourced from the Reclamation Pool
>>>>   in the absence of an IPv4 Global Transfer Policy to neutralize
>>>>   transfer process inequities across RIR regions."
>>>> 
>>>> What do you mean by "neutralize transfer process inequities across RIR
>>>> regions"?
>>>> 
>>> My understanding is this is meant to address the following concern:
>>> 
>>> APNIC passed a transfer policy which does not require justified need on
>>> the part of the
>>> recipient. Absent this provision, such a global policy would allow an
>>> entity within APNIC
>>> that has justified need to obtain space, transfer it to a broker, then,
>>> obtain more space,
>>> lather, rinse, repeat until such time as all possible space had been
>>> transferred to a broker
>>> in the APNIC region to the detriment of all other regions.
>> 
>> This reading of the APNIC transfer policy is not correct. Justification of
>> need is required for transfers right up until the final /8 policy. At that
>> point, any organization must justify its existing holdings before it is
>> eligible to receive its single /22 from that final space. When combined with
>> APNIC's final /8 policy, there is no room for the transfer, rinse, repeat
>> cycle suggested above. In fact, to date, nobody has used the transfer
>> policy.

So as APNIC policy currently stands, any additional space from IANA
under this policy would be subject to the last /8 policy and APNIC would
be unable to issue it except to new entrants that hand't already received
a /22 from the final /8?

My bet is that would change, likely without changes to the transfer
policy.

>> 
>> To clarify, there are 2 stages of the transfer policy.
>> 
>> Transfers stage 1:
>> 
>>  - Active:
>>      Now until APNIC begins allocations from the final /8
>>  - Source of transfer:
>>      - Ineligible to receive any further addresses from APNIC for 12
>>        months OR until the final /8 phase is reached.
>>      - On requesting resources from APNIC, would need to justify need
>>        for those addresses.
>>  - Recipient of transfer:
>>      - Required to justify need for addresses according to the same
>>        criteria as account holder requesting addresses directly from
>>        APNIC.
>>      - Must fully justify use of the transferred addresses if the
>>        organization requests further space from APNIC.

Understood... This stage is not the issue...

>> 
>> Transfers stage 2:
>> 
>>  - Active:
>>     When APNIC's final /8 allocation policy is activated
>>  - Source of transfer:
>>     - Can request resources immediately from APNIC, but is limited
>>       by final /8 policy to receiving a single /22 from the final /8,
>>       and must justify need for the addresses.

Would this apply to space that came from IANA after the final /8 under
the proposed global policy we are discussing, or, would it only apply
to the final /8?

>>  - Recipient of transfer:
>>     - No need to justify resources at time of transfer.
>>     - If requesting resources from APNIC's final /8:
>>       - organization is eligible to receive only a single /22, and
>>       - must justify need for the addresses, including demonstrating
>>         use of any previously transferred resources the recipient
>>         holds.
>> 
>> I have included the most important details above. Full details are available
>> in section 3 of the policy document, "APNIC transfer, merger, acquisition,
>> and takeover policy" at:
>> 
>>   http://www.apnic.net/policy/transfer-policy
>> 
>> It should also be read in conjunction with the final /8 policy in section
>> 9.10 of the "Policies for IPv4 address space management in the Asia Pacific
>> region".
>> 
>>    http://www.apnic.net/policy/add-manage-policy
> 
I've read both and there is definite ambiguity as to how space received
by APNIC under this policy would be treated (whether or not it would
be subject to the last /8 policy). If it is not, then, the juxtaposition of the
two policies (which were clearly written with the assumption that there
would be no more space coming from IANA after the exhaustion of
the IANA free pool) could create the result I described.

In any case, while the ambiguity of existing APNIC policy in light of
this proposal is of concern, Chris is right that any RIR could pass
a policy with such a damaging result (intentionally or through such
accidental ambiguity as appears to be the case with APNIC). As
such, I would not support the global policy without this protection.

Owen