Key Policy Proposals: Highlights from APNIC 56 OPM

Introduction

In this article, we offer a brief overview of policy proposals discussed during the Open Policy Meeting (OPM) in the Policy Special Interest Group (SIG) that took place at APNIC 56 in Kyoto on September 14th.

We have reviewed the most significant proposals related to Address Policy, which have the potential to significantly impact the IP address market and compared them with existing practices in other Regional Internet Registries (RIRs). Let’s take a closer look at each proposal, its status, and the key points of the proposal discussion.

What are the goals of SIG and OPM?

The Policy SIG’s mandate is to formulate policies pertaining to the administration and utilization of Internet number resources within the Asia-Pacific region. These policies encompass guidelines for resource allocation, retrieval, and transfer, as well as resource registration across various services such as WHOIS, reverse DNS, RPKI, and associated services. At the Open Policy Meeting (OPM), participants review and vote on policy projects. Following this, the projects that receive affirmative votes undergo final commentary and are incorporated into APNIC’s policies.

In this article, the following proposals will be reviewed:

prop-148: Leasing of Resources is not Acceptable. Status: Withdrawn
prop-152: Reduce the IPv4 delegation from /23 to /24 Status: Sent back to the mailing list.
prop-154: Resizing of IPv4 assignment for the IXPs. Status: Sent back to the mailing list.
prop-155: IPv6 PI assignment for associate members. Status: Reached consensus.
prop-147: Historical resources Management. Status: Implemented

The first proposal considered at the OPM was prop-148, which we will begin our review with:

1. prop-148: Leasing of Resources is not Acceptable

This is the fifth version of the proposal. This time in their presentation, the author extended the title of the project “Leasing of Resources is not Acceptable” by adding “unless justified in the original resource request” to the end of the title.

The author, JORDI PALET MARTINEZ, representing theIPv6Company, proposed the following amendment to the Policies:

5.8. Leasing of Internet Number Resources

In the case of Internet number resources delegated by APNIC or a NIR, the justification of the need implies the need to use on their own infrastructure and/or network connectivity services provided to customers. As a result, any form of IP address leasing is unacceptable, nor does it justify the need, unless otherwise justified in the original request. Even for networks that are not connected to the Internet, any form of leasing of IP addresses is not permitted, because such sites can request direct assignments from APNIC or the relevant NIR and, in the case of IPv4, use private addresses or arrange transfers. APNIC should proactively investigate lack of compliance with the original resource request justification, including suspected cases for any form of leasing and also initiate the investigation in case of reports by means of a form, email address or other means developed by APNIC.

If any form of leasing, regardless of when the delegation has been issued, is confirmed by an APNIC investigation, it will be considered a policy violation and revocation may apply against any account holders who are leasing or using them for any purposes not specified in the initial request.

The primary idea behind this proposal, according to the author, is not to change existing APNIC policies but to make it explicit that leasing IP addresses is prohibited. This aligns with existing policies where allocated addresses are intended to be used only for the purposes for which they were initially allocated. The proposal emphasizes that resources cannot be leased independently unless the leasing purpose was documented and approved as part of the initial justification. If it is found that the use of addresses differs from the originally stated purpose, such addresses must be deregistered.

While the proposal lacks a specific list of what constitutes “leasing,” the author requests understanding that any form of leasing should be considered as such. Despite the attention-grabbing title, the author insists that the key point is not leasing but rather the use of resources for purposes not aligned with the original request.

Voting Outcome: The proposal did not reach a consensus and has been withdrawn.

The author was given recommendations to revise the project and submit it under a different title.

What does current APNIC policies say about IP leasing?

According to section 3.1.3 of APNIC Internet Number Resource Policies:

LIRs must only delegate addresses to customers who will be using those addresses in relation to network connectivity services provided by the LIR.

Furthermore, according to section 5.2.2:

LIRs may delegate address space to their downstream customers, which are operating networks, such as ISPs, subject to the following conditions:
Delegations are non-portable and must be returned to the LIR if the downstream customer ceases to receive connectivity from the LIR.
The downstream customer is not permitted to further allocate the address space.
For the purposes of evaluating the LIR’s usage rate, address space delegated to downstream LIRs will be considered as “used”. However, APNIC will give careful consideration to the registration of delegations made by the downstream LIR to their customers and may request supporting documentation as necessary.

In this context, if it is determined that addresses are being used for purposes other than those initially specified, and the address holder has not agreed to the change within the specified timeframe, the addresses may be withdrawn. This is governed by sections 4.1.1 and 4.1.2:

A resource delegation is valid only while the original criteria on which it was made remains valid. If a delegation becomes invalid, then the resource must be returned to the appropriate IR.
An allocation or assignment becomes invalid if it is: Made for a specific purpose that no longer exists, or Based on information that is later found to be false or incomplete.

So, can IPv4 subnets allocated by APNIC be leased?

While there is currently no explicit prohibition on IP-leasing, we do not recommend leasing IP-networks if, from a technical perspective, such leasing does not comply with the requirements outlined in sections 3.1.3 and 5.2.2, and if this intended usage has not been previously approved by APNIC.

If these criteria cannot be met, we recommend that, if you have unused IPv4 networks allocated by APNIC, you consider transferring them to a party in need of IP addresses, following the existing APNIC policies.

Voldeta, an authorized APNIC broker, will be happy to assist you with IPv4 address transfer questions. You can schedule an online call with our specialist here or send an email .

How about leasing in other RIRs?

ARIN: Leasing is partially permitted.
AFRINIC: Not allowed.
RIPE NCC: Policies restricting address leasing for ALLOCATED PA addresses are currently absent. However, it is stated that addresses of the ASSIGNED PI type can only be used for an organization’s own infrastructure. A more detailed overview of RIPE policies is presented here.
LACNIC: Not allowed if the lease is not an integral part of a communication service. Currently, a similar proposal to explicitly prohibit address leasing is under discussion in LACNIC.

Did you know that you can become the author of a new policy?

To do this, simply publish the policy on the Policy SIG mailing list, and then it should go through the next round to be published.

Image. The procedure for implementing a policy in APNIC:

2. prop-152: Reduce the IPv4 delegation from /23 to /24

The author’s message leads to the fact that currently, APNIC has only 0.3% left of the last allocated 103/8, and soon it will be necessary to start allocating networks from the reserve. Currently, according to APNIC policies, a minimum IPv4 subnet size to be allocated is /24, and the maximum size of an IPv4 network that an LIR can request is /23.

Based on this, the author has proposed the following amendments:

No change to the current policy to current minimum delegation size for IPv4 is a /24 and each APNIC account holder is only eligible to receive IPv4 address delegations totaling a maximum /23 from the APNIC 103/8 IPv4 address pool. APNIC can continue with this policy until all of the available 2,792,192 (0.3%) resources are depleted.
Once the available 2,792,192 (0.3%) resources are depleted, APNIC and NIR account holders who already received IPv4 address space cannot receive any further IPv4 addresses.
APNIC and NIRs will delegate a maximum of /24 IPv4 addresses to their new account holders, with no IPv4 addresses, from the current ‘Reserved’ pool and any subsequent reserved pool in the future which will be made available for delegation.
If APNIC runs out of all of IPv4 addresses, a waiting list for new requestors with no IPv4 addresses must be created on a first come, first served basis.

Voting Outcome: Did not reach consensus . The decision is to send back to the mailing list.

And how does IPv4 allocation work in other RIRs?

ARIN: ARIN will only issue future IPv4 allocations (excluding 4.4 and 4.10 space) from the ARIN Waitlist. All ISP organizations without direct allocations from ARIN qualify for an initial allocation of up to a /22, subject to ARIN’s minimum allocation size.
AFRINIC: The minimum allocated subnet size is /24, the maximum allocated subnet size is /22
RIPE NCC: /24 via a waiting list.
LACNIC: slow start: /22, otherwise /21 (can be exceeded when documented immediate need exceeds /21).

3. prop-154: Resizing of IPv4 assignment for the IXPs

The authors have proposed the following amendment to the policies:

6.2.4. IPv4 for Internet Exchange Points

By default, a /26 of IPv4 address block will be assigned to the new IXPs. IXPs can seek an assignment of up to a /25 when they can justify having more than 60 peers on the IXP fabric (peering LAN) in the next 12 months. IXPs can seek an assignment of up to a /23 or current highest assignment size when they can justify having more than 100 peers on the IXP fabric (peering LAN) in the next 12 months.

An IXP which received an assignment less than /24 can request up to /23 IPv4, only if 60% of the original assignment has been used. The existing assignment must be returned by the IXP within 3 months of the new assignment. Existing Large IXPs that already have used their maximum assignment of /23 from current policy can request a contiguous block (if available) of /22, only if they have already used 60% of existing assignment. The existing assignment must be returned by the IXP within 3 months of the new assignment. Any existing IXP that wants to open new POPs can request for more IPv4 addresses (which will be allocated using the same principle as defined above /26 and /25) as long as the total allocation doesn’t exceed /22. Any resources assigned under this policy will not be announced in the global routing table (mistakes are exempted) and must be used for IXP peering only, in case otherwise the resources will be revoked by APNIC.

The author’s message boils down to the fact that in the APNIC region, there are many countries with fewer than 100 ASNs in total, and it’s evident that IXPs in these countries would require a maximum of half of a /25, let alone IXPs within those countries.

Considering the practicality, given the above, it would be appropriate to reduce the current default size of IPv4 networks allocated to IXPs from /23 to /26. However, IXPs retain the right to replace the allocated network with up to a /22, taking into account the return of a previously allocated smaller network if they can justify the need for such a network size due to having a sufficient number of peers.

Voting Outcome: Did not reach consensus . The decision is to send back to the mailing list.

And how does IPv4 allocation to IXPs work in other RIRs?

ARIN: The minimum allocated subnet size is /24
AFRINIC: Each IXP can obtain a /24
RIPE NCC: /27 minimum (on request), /24 default, /22 maximum.
LACNIC: The minimum allocated subnet size is /24, the maximum allocated subnet size is /22

4. prop-155: IPv6 PI assignment for associate members

In APNIC, there currently isn’t a procedure similar to practices in RIPE NCC, for example, where an end-user can independently request an IPv6 /48 block without becoming a member of the RIR. In APNIC, there is currently no option to obtain an IPv6 subnet without being a member of the organization. Moreover, even the lowest Associate level does not allow the issuance of any addresses. Additionally, obtaining an IPv6 subnet in the absence of an IPv4 subnet incurs annual costs amounting to 1180 AUD.

As a result, organizations in need of an IPv6 block would have to pay unreasonably high membership fees for this resource and go through a complex acquisition process. To make IPv6 addresses more accessible, authors Aftab Siddiqui and Simon Baroi proposed a comprehensive set of solutions, of which, for the purposes of our review, we have highlighted the key proposals:

Allow associate members to apply for IPv6 PI resources with minimum justification criteria as currently specified in Section 9.1.4 of APNIC-114, provided that the member will use the resources in the next 12 months period.
Update APNIC 121 (APNIC Membership: Tiers and Voting rights) Section 2.2 as per below structure.
There will be no change in the membership tier after receiving IPv6 PI address space.
IPv6 PI address space assigned under this policy will be excluded from Annual Fee calculation as defined in APNIC-120 Section 1 (Fee Schedule) and will be termed as non-chargeable resource.
IPv6 PI address space will be non-transferable.

The full list of proposals can be reviewed here

Voting Outcome: Reached consensus at APNIC 56 OPM and AMM.

And how does IPv6 PI assignment work in other RIRs?

ARIN: The minimum IPv6 PI assignment size is /48
AFRINIC: Must not be a LIR, /48 minimum
RIPE NCC: /27 minimum (on request), /24 default, /22 maximum.
LACNIC: The minimum allocated subnet size is /24, the maximum allocated subnet size is /22

5. Proposal 147 – Historical resources Management

According to this policy, all legacy (historical) resources owned by non-APNIC members that are listed in the APNIC database will no longer be published in the APNIC database as of January 1, 2023. Instead, they will be placed in reserve for a period of 12 months. After this period, if the owners do not claim them, these resources will be placed in the pool for re-delegation in regular status.

Сurrent status: Implemented. Policy published in: apnic-127-v013.

What happens with legacy internet number resources status in other RIRs?

ARIN: ARIN will not reclaim unused or minimally used legacy address space from organizations that have signed the Service Agreement, nor will ARIN make efforts to deregister legacy resources from organizations that opt not to sign it. When legacy number resources are transferred to ARIN, the recipient organization is required to sign an RSA/LRSA, and the resources being transferred do not retain their legacy status.
AFRINIC: Legacy resources transferred into the AFRINIC region will no longer be considered legacy resources.
RIPE NCC: Legacy subnets owners reserve the right to keep legacy status or convert it to PA/PI even after the transfer.
LACNIC: Legacy resources transferred into the LACNIC region will no longer be considered legacy resources.

Conclusion:

This article offered valuable insights into the evolving landscape of address policies within APNIC, providing readers with a clear understanding of the proposed changes and their potential consequences in the realm of IP address management.

In light of the ongoing depletion of IPv4 addresses, the proposed policies clearly show a trend toward stricter regulations. Specifically, there is a move to reduce the minimum size of allocated IPv4 networks and introduce more clear amendments to detect policy violations, which could lead to the possibility of reclaiming IPv4 addresses back into the pool.

We anticipate that all proposals not accepted this time will undergo revisions based on the feedback received and may be approved in the near future.

At the same time, there is a trend towards easing policies regarding IPv6 networks to make them more accessible.

Author: Anastasia Kleiman

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