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Re: [nznog] New Trans-Tasman submarine cable
by Peter Lambrechtsen 19 Feb '13

19 Feb '13

And the other important part is SCCN "could" charge more to NZ due to the monopoly. But they don't. Plus talking about 1gb plans. That is by far and above the edge cases. We have to remember this is bb for the masses. Most OECD countries have an average GB usage below 40 or so... And they have far more options in the online video content space. So NZ isn't *that* different in that respect. Plus in many of those countries have underground ducting that is reused unlike NZ which makes a massive impact on costs. Last of all much of it gets run by the government so issues with the RMA doesn't apply. Sent from my HTC Wildfire S on Telecom's XT mobile network. ----- Reply message ----- From: "Mauricio Freitas" <freitasm(a)geekzone.co.nz> To: "dean(a)deanpemberton.com" <dean(a)deanpemberton.com>, "Peter Lambrechtsen" <Peter.Lambrechtsen(a)telecom.co.nz> Cc: "nznog(a)list.waikato.ac.nz" <nznog(a)list.waikato.ac.nz> Subject: [nznog] New Trans-Tasman submarine cable Date: Wed, Feb 20, 2013 9:19 am Peter was saying that SCX charges the same to NZ companies as they charge AU companies, even though one could obviously say there is a much bigger market in AU. In effect we are paying the (lower) Australian prices for the SCX data. Cheers Mauricio Freitas (@freitasm) www.geekzone.co.nz<http://www.geekzone.co.nz> www.freitasm.com<http://www.freitasm.com> www.twitter.com/freitasm<http://www.twitter.com/freitasm> -----Original Message----- From: nznog-bounces(a)list.waikato.ac.nz [mailto:nznog-bounces(a)list.waikato.ac.nz] On Behalf Of Dean Pemberton Sent: Wednesday, 20 February 2013 08:58 To: Peter Lambrechtsen Cc: nznog(a)list.waikato.ac.nz Subject: Re: [nznog] New Trans-Tasman submarine cable On Wed, Feb 20, 2013 at 7:16 AM, Peter Lambrechtsen <Peter.Lambrechtsen(a)telecom.co.nz> wrote: > How are prices high when it costs the same to land data on SCCN NZ-US > as it does AU-US and there is 3 cables going into AU? > Sorry I don't get what you're saying here. Probably just me being dense, could you expand? > NZ is a small population with a low wage economy spread across a very > mountainous geography that the vast majority of people only use less > than 30gb of data.... Thats true, but it changes. At one point it was impossible to imagine that people would even require 1gb/month. You want the speed of capability to keep pace with the speed of demand. The problem is that capability is always slower to accelerate. > > Fix those issues and we will all have cheaper internet. I don't necessarily want cheaper. I want one which matches my expectations more. =) Dean _______________________________________________ NZNOG mailing list NZNOG(a)list.waikato.ac.nz http://list.waikato.ac.nz/mailman/listinfo/nznog

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Re: [nznog] New Trans-Tasman submarine cable
by Peter Lambrechtsen 19 Feb '13

19 Feb '13

How are prices high when it costs the same to land data on SCCN NZ-US as it does AU-US and there is 3 cables going into AU? NZ is a small population with a low wage economy spread across a very mountainous geography that the vast majority of people only use less than 30gb of data.... Fix those issues and we will all have cheaper internet. Sent from my HTC Wildfire S on Telecom's XT mobile network. ----- Reply message ----- From: "Chris Hodgetts" <chris(a)archnetnz.com> To: "nznog(a)list.waikato.ac.nz" <nznog(a)list.waikato.ac.nz> Subject: [nznog] New Trans-Tasman submarine cable Date: Tue, Feb 19, 2013 11:15 pm Yes - more cables does equal good... However, given the three Telco's involved... does it still mean high prices? On Tue, 19 Feb 2013 00:32:43 +0000, Christian Nielsen <cnielsen(a)microsoft.com> wrote: > More Cables = Good. > > This is a pretty good site. Still shows Tasman-2. > http://submarinecablemap.com/ > > Christian > > -----Original Message----- > From: nznog-bounces(a)list.waikato.ac.nz > [mailto:nznog-bounces(a)list.waikato.ac.nz] On Behalf Of Kris Price > Sent: Monday, February 18, 2013 4:29 PM > To: nznog(a)list.waikato.ac.nz > Subject: [nznog] New Trans-Tasman submarine cable > > Oh, looky, a new cable: > > http://www.telecom-media.co.nz/releases_detail.asp?id=3880&page=index > > I'm curious about something though, maybe someone on the list can share a > bit of history. Is Tasman-2 still active in some capacity? > > I had always assumed it was shutdown after southern cross was built, but > it's still shown often on cable maps such as the one in that press release: > > http://twitpic.com/c4wu2k > > > Cheers > Kris > _______________________________________________ > NZNOG mailing list > NZNOG(a)list.waikato.ac.nz > http://list.waikato.ac.nz/mailman/listinfo/nznog > _______________________________________________ > NZNOG mailing list > NZNOG(a)list.waikato.ac.nz > http://list.waikato.ac.nz/mailman/listinfo/nznog _______________________________________________ NZNOG mailing list NZNOG(a)list.waikato.ac.nz http://list.waikato.ac.nz/mailman/listinfo/nznog

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APNIC EC election online voting and proxy appointment open
by Dean Pemberton 16 Feb '13

16 Feb '13

Morning all, If you're an APNIC member then it's time to exercise your voting powers. Online voting is now open for the upcoming Executive Council elections. There are four seats open, so you will get a number of votes. Here's a very cut down version of the biographies (wording taken from http://conference.apnic.net/35/elections#nominees) if you're still undecided. James Spenceley James founded Vocus, now one of the largest IP backbone providers in Australia and New Zealand. James has successfully managed Vocus into the awarded fastest growing technology company in Australia. Vocus now listed on the Australian Stock Market offers IP transit, fibre and data centre services in three markets (Australia, New Zealand, Singapore Hong Kong and USA) giving James a strong perspective on operating an Internationally diverse operation and valuable experience in technical and financial matters and corporate governance. James is also a founding director of AusNOG (Australian Network Operators Group), defining the company structure and not for profit nature of the AusNOG orgaisation. Since it's founding in 2007 AusNOG has held six annual conferences which regularly exceed 200 attendees. Guarab Raj Upadhaya Presently employed by Limelight Networks (LLNW) as Network Architect on their backbone engineering team, Gaurab supports Limelight's high speed backbone in Asia, Europe and North America. Gaurab previously worked for Packet Clearing House (PCH) as Senior Internet Analyst Gaurab is one of the 14 global Trusted Community Representatives who cryptographically sign the root of the domain name system in ICANN Root DNSSEC Key ceremonies. During his career, he has spoken and presented at INET, APRICOT, SANOG, APNIC, NZNOG, MENOG, AUSNOG, PHNOG, JANOG, AfNOG, NANOG, ICANN conferences as well as RIPE and LINX Meetings. Kenny Huang Dr. Huang's contributions have been acknowledged especially in the development of Internet technology. Dr. Kenny Huang is the co-author of RFC3743 of the IETF, the Co-Chair of JET (Joint Engineering Team, formed by JPNIC, KRNIC, CNNIC, TWNIC), Advisor of CDNC (Chinese Domain Name Consortium). Dr. Huang is working closely with government departments in developing technology policies. Wei Zhao Deputy Director of Operation Management Department,CNNIC, responsible for IP services, related external cooperation and innovation. At APNIC community, she has been involved in policy developing and other community events since she joined CNNIC. She was served as NIR SIG co-chair in 2009 to 2010, and elected as APNIC Executive Council in 2011. Lengchheang Hong Lengchheang Hong began his career at AsiaForm where he was a network administrator. He then moved on to become a Senior Customer Solutions Support Officer for ONLINE before moving up and becoming the Key Account Manager. He became the Technical Support Manager for SINET-MOOV in March 2010 and was responsible for NOC ISP and its branches' operations. ________________________________________________________________________ Proxy appointment/online voting for 2013 APNIC EC election open now ________________________________________________________________________ Online voting and proxy appointment for the APNIC Executive Council (EC) election opens today, Wednesday, 13 February 2013 for a two-week period until 09:00 (UTC +8), Wednesday, 27 February 2013. The EC members whose positions are up for re-election are: - Kenny Huang - James Spenceley - Guarab Raj Upadhaya - Wei Zhao The nominees are: - Lengchheang Hong - Kenny Huang - Guarab Raj Upadhaya - James Spenceley - Wei Zhao Online voting is available to APNIC Member Corporate Contacts and Member Contacts with voting rights via MyAPNIC. By default, all Corporate Contacts have voting rights, and they can assign voting rights to other contacts in MyAPNIC. https://myapnic.net Full details of the election and alternative voting methods are available at: http://conference.apnic.net/35/elections If you have any questions or need further assistance, please contact: helpdesk(a)apnic.net ________________________________________________________________________ APNIC Secretariat secretariat(a)apnic.net Asia Pacific Network Information Centre (APNIC) Tel: +61 7 3858 3100 PO Box 3646 South Brisbane, QLD 4101 Australia Fax: +61 7 3858 3199 6 Cordelia Street, South Brisbane, QLD http://www.apnic.net ________________________________________________________________________ * Sent by email to save paper. Print only if necessary.

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Fwd: [ECS Seminars] 2013-02-20 Fred Baker - Buffer Bloat!
by Andy Linton 16 Feb '13

16 Feb '13

---------- Forwarded message ---------- From: ECS Seminar Notification <seminar-admin(a)ecs.vuw.ac.nz> Date: Fri, Feb 15, 2013 at 10:30 AM Subject: [ECS Seminars] 2013-02-20 Fred Baker - Buffer Bloat! To: ecs-seminars(a)ecs.vuw.ac.nz Date: Wednesday 20th February 2013 Time: 11:00 AM - 12:30 PM Location: Cotton Club, Cotton 350 Fred Baker is scheduled to present a seminar about: Buffer Bloat! School of Engineering and Computer Science Seminar Abstract: The networking industry has looked at Quality of Service numbers times, resulting in the Integrated and Differentiated Services Architectures and numerous papers and articles on the topic. In the past few years, the topic has been popularly renamed "Buffer Bloat", and looked at again from the view of autoconfiguration and deployment. In this talk, we will look at Buffer Bloat in access networks, multistage networks such as WiFi, and data centers, each of which has unique issues and requirements. Bio: Cisco Fellow Fred Baker has been involved in data communications since 1978 and the development of the Internet since the 1980's. He participated in early development of IEEE 802.1d switching and IP routing. He has served as the Chair of the Internet Engineering Task Force, chaired several working groups, and written or edited numerous RFCs. He now chairs the IETF's IPv6 Operations Working Group, working with the operational community on IPv6 deployment issues. He also contributes to the Broadband Internet Technical Advisory Group (BITAG). At Cisco, he works with researchers within the company, and with university researchers outside, on various projects. He also advises management and technologists on technical direction. Any queries about this seminar, please email Qiang.Fu(a)ecs.vuw.ac.nz ============================================================================= This message was automatically generated by the ECS Seminars System. View seminars at http://ecs.victoria.ac.nz/Events/Seminars Sub/unsub at http://ecs.victoria.ac.nz/mailman/listinfo/ecs-seminars

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ihug Ultra and Proxy Caching
by neals5 12 Feb '13

12 Feb '13

In order to defeat a patent troll, I'm looking for someone who can tell me from their own experience when ihug starting using proxy caching in conjunction with their Ultra satellite service. Unless we've all used so much caffeine our memories don't stretch back to last century? Any replies to me off list, please. I'll be happy to summarise. - Donald Neal

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Transit in Sky Tower for OOB
by Cameron Ferdinands 10 Feb '13

10 Feb '13

Hi All, I'm looking for transit in Sky Tower for OOB access, we're on Level 48, Window 16. looking for anyone on the same level or willing to help do a copper cross-connect between floors Thanks,

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Traceroute question
by Andy Linton 10 Feb '13

10 Feb '13

What do you see if you: $ traceroute 216.81.59.173 with maxhops > 30?

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NZNOG2013
by Patrick Sharp 06 Feb '13

06 Feb '13

Hi, In the aftermath of the NZNOG conference this year, we got sent a portable Optoma Projector. It's not ours which presumably means that someone else is missing it. If it's yours, can you email me and I'll arrange to get it back to you? Cheers, Patrick Sharp CityLink patrick.sharp(a)citylink.co.nz<mailto:patrick.sharp(a)citylink.co.nz> 021 2269 269

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InternetNZ position on APNIC prop-106-v001: Restricting excessive IPv4 address transfers under the final /8 block
by Dean Pemberton 04 Feb '13

04 Feb '13

Here is the InternetNZ position on the second policy for discussion in Singapore. The original policy text can be found here: http://www.apnic.net/__data/assets/text_file/0009/56871/prop-106-v001.txt ------------------------------------------------------------------------ InternetNZ position on prop-106-v001: Restricting excessive IPv4 address transfers under the final /8 block ------------------------------------------------------------------------ Authors: Dean Pemberton dean(a)internetnz.net.nz <javascript:;> 1. Executive Summary -------------------- Prop-106 suggests that based on observations of APNIC IP resource transfer history records, some LIRs seems to be collecting IPv4 address blocks from the ‘final /8’ (103/8). It also suggests that this is being accomplished through the use of multiple accounts to apply for individual /22s, and then transferring these blocks to a single account and that this kind of behaviour is against the spirit of the final /8 policy (prop-088). Prop-106 intends to restrict IPv4 address transfers which were allocated/assigned from the final /8 block. In assessing whether Iupport, oppose, or adopt a position of neutrality on a particular policy proposal, three questions are considered: 1. Does this policy seek to address a well-defined, well-accepted problem? 2. Will the solutions outlined within the proposal effectively mitigate the stated problem? 3. Does the policy proposal fit with InternetNZ policy principles? After consideration the questions above, InternetNZ believes that: 1. Based on information provided by the APNIC secretariat, there is no evidence supporting a threat to exploit any perceived loophole in the APNIC transfer policy. As such this proposal does not address a well-defined, well-accepted problem. 2. The options presented within this policy proposal will have no material effect on the sorts of IP resource hoarding activity being suggested to occur in the problem statement. 3. This policy proposal does not fit within several of InternetNZ policy principles, namely those of: Openness, Market competition, Working with the architecture of the internet and accessibility of the internet for all. As such InternetNZ opposes the adoption of APNIC prop-106 as presented in version 001. 2. Does this policy seek to address a well-defined, well-accepted problem? ------------------------------------------------------------------------ Prop-106 states: "The current APNIC IPv4 address transfer policy allows to obtain a maximum of /22 distribution(s) per each APNIC account holder. We propose add a restriction to IPv4 address transfer policy to restricting excessive IPv4 address transfers under the final /8 block." This proposal looks to close a perceived loophole in APNIC's transfer policy that is suggested would allow a single actor to obtain, through mergers and acquisitions (M&As), more than their allowed /22 from the final /8. Prop-106 suggests that this activity has already been observed and as such a policy is required to close the perceived loophole. In considering if this perceived loophole exists and is actually being exploited, InternetNZ has used information provided by the APNIC secretariat. There are 16,384 /22 blocks available from 103/8. APNIC has made 2,110 (12.9%[1]) delegations so far. Of those delegations, 32 (1.5% of allocations, or 0.2% of the total available) have been transferred. This consists of 24 standard transfers and 8 M&A transfers. 15 APNIC members have more than a single /22 from 103/8 associated with their account. The highest number is 5 x /22s in one account. These five /22 blocks represent 0.03% of the address space within 103/8. It would appear, based on this information, that there is not currently a large amount of activity looking to exploit any perceived loophole in existing APNIC transfer policy. As such, InternetNZ does not believe that this proposal seeks to address a well-defined, well-accepted problem. 3. Will the solutions outlined within the proposal effectively mitigate the stated problem? ------------------------------------------------------------------------ Prop-106 suggests two options that claim to close the perceived loophole in APNIC's transfer policy: Option 1: Restrict IPv4 address transfers under the final /8 address block for two years. Option 2: Set a deposit for transfers under the final /8 range. Pay ten years of APNIC's annual fees for transferred address block[s] in advance when receiving the final /8 address range by address transfer or account name change. Both of these options seek to dissuade an actor from transferring 103/8 addresses from multiple shell companies to a single APNIC account. It should be noted however, that there is nothing to stop such an actor from registering and using the same addresses and wilfully failing to notify APNIC. In such a scenario the actor would have access to multiple /22s from the 103/8 block, but the APNIC registration database would reflect that these were held by different entities. The options presented in prop-106 are intended to influence the behaviour of actors that are operating outside the intent of the last /8 policy. InternetNZ suggests that if such actors exist, and are seeking to operate outside APNIC policy, they are unlikely to comply with the proposed policy presented here. As such, InternetNZ believes that this proposed policy will have no material effect on the sorts of IP resource-hoarding activity that is suggested in the problem statement. 4. Does the policy proposal fit within InternetNZ policy principles? ------------------------------------------------------------------------ A set of eight policy principles[2] underpin the work of InternetNZ and help ensure that our approach to Internet-related public and technical policy is transparent and predictable. Internally, the principles guide the development of policy positions and statements. Externally, they explain the basis of InternetNZ’s views to our stakeholders and to the general public. Any proposal that InternetNZ takes a position on is evaluated against these principles. Six of the eight principles apply with respect to prop-106. They are the following: ** Principle No. 1 The Internet should be open and uncapturable. ** In considering a policy proposal using this principle, InternetNZ looks to see if there will be a material effect to openness and/or non capturability. Openness -------- As stated above, there is a material concern that one outcome of this policy would be to discourage actors to from interacting with APNIC during merger & acquisition activity (regardless of their intentions for procuring the addresses). Such a move would have a material effect on the openness of the Internet through an erosion of trust in the ability of the APNIC database to accurately represent the ownership of IP resources. Uncapturable ------------ There is a small chance that an actor could register multiple companies, gain /22 resources and then acquire them. Information provided by the APNIC secretariat shows that this situation is either not occurring, or is occurring at such a low level as to not pose a material threat to the capturability of the Internet. It is accepted that should this situation change in the future that intervention may be required and a watching brief should be kept on the situation. ** Principle No. 2 Internet markets should be competitive. ** For a market to be competitive it must not place any significant barriers on new entrants, nor should it place significant barriers on the natural growth of organisations through M&As. As stated above, prop-106 proposes to place barriers on any entity looking to complete M&A activity involving IP resources from 103/8. If these actors have benign intent and wish to operate within APNIC policies, these barriers will place an undue burden on them. If on the other hand the actors have malicious intent, there are numerous ways for them to avoid the burdens imposed by these policies and achieve their outcomes. As such InternetNZ believes that this policy will have a negative impact on the competition within the Internet market. ** Principle No. 3 Internet governance should be determined by open, multi-stakeholder processes. ** APNIC has an open, multi-stakeholder policy development process. This proposal does nothing to alter that. ** Principle No. 4 Laws and policies should work with the architecture of the Internet, not against it. ** By placing barriers in the way of all M&A activity, APNIC may discourage actors from updating IP resource usage in the APNIC database. This would cause a loss of trust in the integrity of the information in the APNIC database. As this information is used to make decisions related to security, incident response and even routing decisions on the Internet, InternetNZ believes that the effects of this proposal could act against the architecture of the Internet. ** Principle No. 6 The Internet should be accessible by and inclusive of everyone. ** The Internet is undergoing a significant period of growth, especially in developing markets (such as BRIC[3]). While it is an established fact that IPv4 addresses have all but been exhausted and IPv6 represents the only sustainable future direction, access to IPv4 resources is currently a major requirement for the rapid deployment of Internet access throughout these growing economies. InternetNZ believes that placing barriers such as those proposed by prop-106 on M&A activities may have a negative effect on Internet deployment and growth within developing economies in the region. ** Principle No. 7 Technology changes quickly, so laws and policies should focus on activity. ** There is clear evidence of significant activity in terms of Internet growth within the region. This is shown through the allocation of 11-12% of the final /8 in a relatively short period of time. Given that IPv6 is accepted as the only clear future deployment direction for the Internet, yet there is a clear short-term demand for IPv4 resources, InternetNZ believes that barriers should not be placed in the way of getting these resources to those who require them to provide solutions to current technical problems. 5. Summary ---------- After consideration of the material above, InternetNZ believes that: 1. Based on information provided by the APNIC secretariat, there is no evidence supporting a threat to exploit any perceived loophole in the APNIC transfer policy. As such this proposal does not address a well-defined, well-accepted problem. 2. The options presented within this policy proposal will have no material effect on the sorts of IP resource hoarding activity being suggested to occur in the problem statement. 3. This policy proposal does not fit within several of InternetNZ policy principles, namely those of: Openness, Market competition, Working with the architecture of the internet and accessibility of the internet for all. As such InternetNZ opposes the adoption of APNIC prop-106 as presented in version 001. Dean Pemberton Policy Advisor InternetNZ dean(a)internetnz.net.nz <javascript:;> ________________ [1] Some delegations are of smaller size (/24 or /23) so the utilisation is actually closer to 11%. [2] https://internetnz.net.nz/content/Policy-Principles [3] http://en.wikipedia.org/wiki/BRIC

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InternetNZ position on APNIC prop-105-v001: Distribution of returned IPv4 address blocks
by Dean Pemberton 04 Feb '13

04 Feb '13

Morning all, There are two policy proposals for discussion at the upcoming APNIC conference in Singapore. They are in addition to the presentation Elly made at the conference (They came in late). InternetNZ has reviewed the proposals and made a submission on each. The first one is prop-105. The original text of the proposal can be found here: http://www.apnic.net/__data/assets/text_file/0010/56872/prop-105-v001.txt ------------------------------------------------------------------------ InternetNZ position on prop-105-v001: Distribution of returned IPv4 address blocks (Modification of prop-088) ------------------------------------------------------------------------ Authors: Dean Pemberton dean(a)internetnz.net.nz <javascript:;> 1. Executive Summary -------------------- Prop-105 highlight the fact that under current APNIC policy, any future IPv4 address resources made available via IANA (or any other mechanism) would be subject to allocation purely based on the guidelines within the ‘last /8’ policy (prop-088). Prop-105 suggests that, based on the demonstrated need for IPv4 addresses (citing that 70% of the respondents to a recent survey expressed a need to receive additional IPv4 address space), any additional APNIC allocations should be handled outside prop-088 guidelines. The central issue prop-105 has with the prop-088 guidelines is that once an APNIC member has applied to recieve a blocst /8 (currently a /22), they are not eligible for any additional address space. Prop-105 seeks to amend prop-088 to allow members to receive a single block from 103/8 (the last /8) in additional to a single block from any space which APNIC might receive subsequently. In assessing whether InternetNZ will support, oppose, or adopt a position of neutrality on a particular policy proposal, three questions are considered. 1. Does this policy seek to address a well defined, well accepted problem? 2. Will the solutions outlined within the proposal effectively mitigate the stated problem? 3. Does the policy proposal fit with InternetNZ policy principles? After consideration of the questions above, InternetNZ: 1. believes that even though there is a demonstrated demand for IPv4 addresses, it does not accept that a situation exists whereby changes are required to prop-088 for APNIC to cater for additional IPv4 resources from IANA. 2. does not believe that allowing APNIC members to receive additional allocations from small blocks received from IANA will make a material difference to the demand for IPv4 addressing. 3. believes that the proposal has the potential to send the wrong message with regard to the importance of IPv6 adoption as opposed to continued IPv4 deployment. 4. This policy proposal does not fit within several of InternetNZ policy principles, namely those of: Working with the architecture of the Internet and focusing on technical activity. As such InternetNZ opposes the adoption of APNIC prop-105 as presented in version 001. 2. Does this policy seek to address a well-defined, well-accepted problem? ------------------------------------------------------------------------ Prop-105 states: “While rapid implementation of IPv6 is in progress throughout the APNIC region, demands for IPv4 address still continue. According to our survey conducted to the APNIC community, over 70% of the respondents expressed the needs to receive IPv4 address space, if a separate distribution policy is defined from the final /8 policy. In May 2012, the global policy “Global Policy for Post Exhaustion: IPv4 Allocation Mechanisms by the IANA” was ratified by ICANN board, and it will be implemented soon. Based on this policy, IPv4 address space returned to IANA will be distributed to RIRs, and its size is not expected to be so large but substantial enough to be able to consider an additional minimum allocation for APNIC members.” The APNIC secretariat states that they have so far pre-approved 43 requests, for a total space of 1,717,504 IP addresses (this equates to roughly just over half a /12 worth of address space). The study cited in prop-105, coupled with the stats from the APNIC secretariat clearly demonstrates a demand for IPv4 resources, what is unclear however, is if a situation will ever exist under which this policy will become relevant. It can be effectively argued that it is uncertain if IANA will ever allocate a meaningful amount of additional IPv4 address space to APNIC for LIR allocation. In the absence of that occurring, this problem this policy seeks to solve would not exist. As such, InternetNZ accepts that there is a demonstrated demand for IPv4 addresses, but does not accept that a situation exists whereby changes are required to prop-088 for APNIC to cater for additional IPv4 resources from IANA. 3. Will the solutions outlined within the proposal effectively mitigate the stated problem? ------------------------------------------------------------------------ Prop-105 presents the following as a solution to the the perceived problem: “Modify prop-088 to distribute non-103 IPv4 address blocks to APNIC account holders who meet the IPv4 distribution criteria define in APNIC policies. If APNIC account holder, who was allocated an /22 from final /8 pool, needs an additional IPv4 address block, they are eligible to receive another distribution of IPv4 block. The same policy as the final /8 policy will be applied in terms of the criteria and the size of the distribution given the requestor has utilized a total of /22 block from 103/8.” This is assumed to mean that APNIC members are free to obtain a /22 from 103/8 as well as an additional /22 from any subsequent block of IPv4 addresses that APNIC might obtain from IANA (or other mechanisms). While at a high level this might appear to be a solution to the stated problem, it does not accurately present itself as a standalone policy, nor does it reference the parts of prop-88 which would need to change, nor any suggested replacement text. Prop-105 also neglects to define conditions such as the minimum size of additional allocation under which this policy would be enacted. The ICANN policy referred to by the author states: “The purpose of the proposal is to enable ICANN, as the IANA Functions Operator, to allocate IPv4 blocks returned by the RIRs. ICANN would place IPv4 blocks returned by the RIRs in a Recovered IPv4 Pool. This Pool would be declared active when one RIR has less than half its last /8 left, approximately 8m IPv4 addresses. The IANA Functions Operator would then allocate an "IPv4 allocation unit" (minimum size /24) to each RIR, if the Pool size so permits. If the space available in the Pool is too limited, allocation would be deferred in 6 month intervals until space is available.” It is clear from this wording that ICANN envisages small addresses being handed back to RIRs (evident by the use of a minimum /24 size reference). If for example APNIC were to receive a /20 from IANA (equivalent to 4 /22s) it would be hard to see how a change to the existing prop-088 policy would be justified. If on the other hand APNIC were to receive an additional /8 from IANA, then there may be a case to justify allowing members an additional allocation from this block. While all these are technical possibilities, InternetNZ in defining its position must take into account the probability of each event occurring. While it is impossible to predict the future, InternetNZ feels that it is far more likely that a number of small (<= /20) blocks, if any, will be made available from IANA rather than any significantly large blocks (<= /16). It should also be noted that it was the intent of prop-088 that an APNIC member’s allocation from the last /8 be used to facilitate adoption of and transition to IPv6. It was not intended to be used for day to day operational purposes. As such, InternetNZ does not believe that allowing APNIC members to receive additional allocations from small blocks received from IANA will make a material difference to the demand for IPv4 addressing. InternetNZ also believes that it has the potential to send the wrong message with regard to the importance of IPv6 adoption as opposed to continued IPv4 deployment. 4. Does the policy proposal fit within InternetNZ policy principles? ------------------------------------------------------------------------ A set of eight policy principles[1] underpin the work of InternetNZ and help ensure that our approach to Internet-related public and technical policy is transparent and predictable. Internally, the principles guide the development of policy positions and statements. Externally, they explain the basis of InternetNZ’s views to our stakeholders and to the general public. Any proposal that InternetNZ takes a position on is evaluated against these principles. Five of the eight principles apply with respect to prop-105. They are the following: ** Principle No. 2 Internet markets should be competitive. ** Allowing existing APNIC members to receive additional allocations from subsequent IANA allocations will reduce the ability of new entrants to receive initial allocations under the existing prop-088 framework. While this is a possibility, the amount of address space envisaged to be allocated by IANA is expected to be so small as for this effect to be considered minor. As such InternetNZ believes that this policy will have a negligible impact on the competition within the Internet market. ** Principle No. 3. Internet governance should be determined by open, multi-stakeholder processes. ** APNIC has an open, multi-stakeholder policy development process. This proposal does nothing to alter that. ** Principle No. 4. Laws and policies should work with the architecture of the Internet, not against it. ** InternetNZ believes that the future of Internet deployment is with IPv6. Anything which artificially prolongs the life of IPv4 at the expense of wide scale IPv6 adoption is seen to be acting against the architecture of the Internet. The intent of prop-088 was that an APNIC member’s allocation from the last /8 was to be used to facilitate adoption of and transition to IPv6. As such InternetNZ believes that this proposal acts against the architecture of the Internet, by prolonging members reliance on IPv4 resources. ** Principle No. 6 The Internet should be accessible by and inclusive of everyone. ** InternetNZ accepts that in order to ensure that the Internet is accessible to and inclusive of everyone that APNIC members require access to IPv4 resources while they transition to using IPv6. It is our position however that this access is already catered for under the existing prop-088 mechanism. If a situation exists under which a member requires additional IPv4 resources, then this can be accomplished through existing APNIC address transfer mechanisms and the growing IPv4 marketplace. As such, InternetNZ does not believe that the adoption of this proposal is required to ensure the accessibility of the Internet. ** Principle No. 7. Technology changes quickly, so laws and policies should focus on activity. ** InternetNZ accepts that there is a current demand for IPv4 addresses, it believes however that the appropriate mechanism for the fulfilment of this demand is: 1. Allocation of a final /22 from the last /8 as per prop-088 guidelines. 2. Timely adoption of IPv6 delivered services 3. Any additional IPv4 resources sourced through existing transfer policies and recorded accurately in the APNIC database. 5. Summary ---------- After consideration the questions above, InternetNZ: 1. believes that even though there is a demonstrated demand for IPv4 addresses, it does not accept that a situation exists whereby changes are required to prop-088 for APNIC to cater for additional IPv4 resources from IANA. 2. does not believe that allowing APNIC members to receive additional allocations from small blocks received from IANA will make a material difference to the demand for IPv4 addressing. 3. believes that the proposal has the potential to send the wrong message with regard to the importance of IPv6 adoption as opposed to continued IPv4 deployment. 4. This policy proposal does not fit within several of InternetNZ policy principles, namely those of: Working with the architecture of the Internet and focusing on technical activity. As such InternetNZ opposes the adoption of APNIC prop-105 as presented in version 001. Dean Pemberton Policy Advisor InternetNZ dean(a)internetnz.net.nz <javascript:;> ________________ [1] https://internetnz.net.nz/content/Policy-Principles

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