prop-149: Change of maximum delegation for less than /21 total IPv4 holdings

This proposal suggests increasing the maximum IPv4 delegation size for new APNIC account holders from a /23 to a /22 and, if requested, delegating an additional /23 for APNIC account holders with less than a total of a /21 of IPv4 resources.

APNIC account holders with a total amount of IPv4 resources equal to and more than a /21 are not eligible for further IPv4 delegations.

Shubham Agarwal and Gaurav Kansal

APNIC notes this proposal suggests increasing the maximum IPv4 delegation size for new APNIC account holders from a /23 to a /22 and, if requested, delegating an additional /23 for current APNIC account holders with less than a total of a /21 of IPv4 addresses. Current APNIC account holders with a total amount of IPv4 addresses equal to and more than a /21 are not eligible for further IPv4 delegations.

APNIC believes that the eligibility criteria for this proposal are unclear and raises the following concerns:

1. The proposal assumes that all IPv4 addresses marked as reserved can be delegated to the account holders. However, some of these addresses are reserved for specific policy and these cannot be delegated under this proposal. For example, a /21 IPv4 address space is reserved for experimental allocations.
2. There is a risk that current account holders who have already transferred IPv4 address space from their account may use this proposal to request additional IPv4 addresses for market transfers. The same could happen to new account holders in the future.
3. The proposed solution will create disparity among account holders. Current account holders who have received /22 + /23 + /24 are eligible for another /23 under this proposal, bringing their total to /21 + /24. At the same time, current account holders with a total IPv4 addresses equal to or greater than /21 are not eligible. It is unclear why new account holders will be eligible for a maximum of /22, whereas current account holders who already have a /22 will be eligible for an additional /23.
4. Please note that the recent data shared by the Secretariat on the Policy SIG mailing list shows that if all current members with less than /21 request additional address space under this proposal, APNIC’s entire IPv4 free pool would be depleted, and a waiting list may have to be created.

This proposal makes no mention of the current policy which states that IPv4 addresses delegated from the available pool cannot be transferred for a minimum of five years after the initial delegation. However, if this proposal is accepted by the community, it will be subject to this restriction.

To address some of these concerns, APNIC recommends that the authors and community simplify the proposal. A suggested proposed solution is as follows:

New APNIC account holders are eligible for a maximum of /## IPv4 addresses from the APNIC available pool.

Current APNIC account holders are eligible to request an additional /## IPv4 delegation (provided the total IPv4 addresses holding is not exceeding /##) from the APNIC available pool, provided the applicant meets these terms:

• No IPv4 addresses have been transferred out of the account holder’s account since joining APNIC.

• According to the current policy, IPv4 addresses delegated under this proposal cannot be transferred for a minimum of five years after the original delegation.

This policy will remain in effect until APNIC has exhausted all available IPv4 addresses. Following that, requests will be placed in the first-come-first-served waiting list to delegate IPv4 addresses as they become available, with no guarantees.

If this proposal reaches consensus and is endorsed by the EC, implementation will require changes to systems, procedures, and service level agreements.  The Secretariat also believes a likely rush by Members to apply for additional IPv4 space will mean additional staff will need to be recruited and trained to handle a high volume of requests in a short period of time.  For these reasons, implementation may be completed in eight to nine months.