Rescue from alligators in the swamp - note from APNIC

Hello all,
First, as a general note, it is worth mentioning that there are several
staff at the APNIC Secretariat who keenly follow the discussions on
NZNOG.
Currently, we have been closely following the discussion on the effects
of implementing the 'whois privacy' policy on address ranges in use in
New Zealand. This email is intended to clarify some of the issues
raised, to provide explanations, and to try to identify a path forward.
As there have been quite a lot of issues raised, I apologise in advance
for the length of this reply.
1) Creating and changing policies
---------------------------------
It is not necessary to be a member of APNIC to be involved in the
policy making process. Anyone can propose policy changes and take part
in the policy discussions. Also, you dont have to attend the meetings
to take part. APNIC provides facilities for people not present to take
part in discussions while the meetings are actually taking place. In
addition, everyone is welcome to join the APNIC mailing lists where
policies are proposed and discussed.
The main list used to discuss the management of Internet resources is
the Policy Special Interest Group (SIG) mailing list. A description of
the Policy SIG is available at:
http://www.apnic.net/meetings/archive/sigs/policy.html
Details of how to subscribe to this and other APNIC mailing lists is
available at:
http://www.apnic.net/community/lists/
It is highly recommended that anyone holding resources does subscribe
to this list (and others) so that they can voice their opinions and
give feedback when policies are circulated for comment.
You can also find a list of active policies under discussion at:
http://www.apnic.net/docs/policy/proposals/
Feedback and participation in developing policies from the NZ community
is very much appreciated.
2) Membership fees and criteria for portable allocations and assignments
------------------------------------------------------------------------
The fees for membership can be found here:
http://www.apnic.net/member/feesinfo.html
The criteria for a minium allocation (/21*) of portable address space
are as follows:
- the applicant must have used a /23 from their upstream provider
or demonstrate an immediate need for a /23;
- the applicant must have complied with applicable policies in
managing all address space previously allocated to it;
- the applicant must demonstrate a detailed plan for use of a /22
within a year; and commit to renumber from previously deployed
space into the new address space within one year.
[* it is worth noting that the size of the minimum allocation and the
criteria for obtaining an allocation were recently lowered from a /20
to a /21 as a result of input and consensus from the community]
More information is here:
http://www.apnic.net/docs/policy/add-manage-policy.html#9.3
If you wish to obtain a portable assignment of address space as a
multihomed organisation you can apply under the small multi-homing
assignment policy. The criteria are:
- the requestor must be currently multihomed with provider-based
addresses, or demonstrates a plan to multihome within one month; and
- agree to renumber out of previously assigned address space.
The small multi-homing assignments are available to both members and
non-members.
3) National Internet Registries (NIRs)
--------------------------------------
APNIC recognises NIRs which operate within certain economies.
Prospective NIRs must meet specific criteria and adopt the operational
policies detailed in:
http://www.apnic.net/docs/policy/nir-criteria.html
and
http://www.apnic.net/docs/policy/operational-policies-nirs.html
4) Whois database privacy policy
--------------------------------------
Details of and the motivations for this policy are documented at:
http://www.apnic.net/docs/policy/proposals/prop-007-v001.html
In summary, the policy means that all non-portable assignments and
non-portable sub-allocations will be private by default. Details of
these resources remain registered in the whois database but are just
not visible to the public. They can be made visible by the custodian of
the allocation object through MyAPNIC, to which all APNIC members have access.
5) Next steps
-------------
Under the database privacy policy, all non-portable assignments and
non-portable sub-allocations that have not been specifically marked as
public have now been made private. However, because some allocations
and assignments within certain ranges appear to have been considered
'portable' by default from earlier practices in New Zealand, APNIC
will restore the affected ranges from private to public. The ranges
in question are:
- 202.27.0./16
- 202.36.0.0/16
- 202.37.0.0/16
- 202.49.0.0/16, and
- 202.50.0.0/16
Anyone holding addresses from these ranges that they wish to be made
private, should contact APNIC helpdesk. The update will be done this
week.
6) NZTelecom custodianship
--------------------------
In regard to the wider issue of NZTelecom as a custodian of the ranges
listed above, APNIC operated in good faith, trying to promote
aggregation and provide a clearer framework for the custodianship of
address space in New Zealand.
That said, clearly there are now major concerns being expressed on this
mailing list concerning portability of blocks within these ranges. The
APNIC Secretariat will examine the records within these ranges and will
work with NZTelecom, affected parties, and the community to find an
appropriate solution. The solution will not happen overnight but the
process is beginning immediately. Of course, APNIC will keep the New
Zealand community fully up to date on the progress of the discussions.
The APNIC Secretariat would be happy to assist anyone with concerns. If
you want to discuss your concerns with us, please call the helpdesk on
+61-7-3858-3188 or send email to

On Wed, 1 Dec 2004, John Tran wrote: *SNIP* a really interesting e-mail First, John, that was most enlightening. Thanks. One point that was raised in this discussion is that, for many NZ (and other pacific-based) organisations, a /21 is a huge requirement. A lot of companies can justify a /24, maybe even a /23, or a /22 at a stretch, but a /21 is just out of the realms of possibility, probably ever. APNIC policies seem to be more biased towards the A than the P, even with the change from /20 to /21. Obviously a country could set up an NIR to do smaller allocations, but a lot of the little islands out there are unlikely to have the infrastructure to run their own NIR with any kind of reliability. Not to mention that their sub-allocation requirements wouldn't justify the resources and expense. With this in mind, is there anything that can be done to create something like a sub-RIR under APNIC to better serve the needs of the large number of sparsely-populated countries in this region? It may be that anyone can suggest policy, but the actual voting is weighted towards large organisations and not even NZ's largest user of IP addresses makes it into the Extra Large category. -- Matthew Poole "Don't use force. Get a bigger hammer."

Matthew Poole wrote:
On Wed, 1 Dec 2004, John Tran wrote: *SNIP* a really interesting e-mail
First, John, that was most enlightening. Thanks.
One point that was raised in this discussion is that, for many NZ (and other pacific-based) organisations, a /21 is a huge requirement. A lot of companies can justify a /24, maybe even a /23, or a /22 at a stretch, but a /21 is just out of the realms of possibility, probably ever. APNIC policies seem to be more biased towards the A than the P, even with the change from /20 to /21. Obviously a country could set up an NIR to do smaller allocations, but a lot of the little islands out there are unlikely to have the infrastructure to run their own NIR with any kind of reliability. Not to mention that their sub-allocation requirements wouldn't justify the resources and expense.
Let's keep this on the topic of getting the five blocks in question sorted out. The problems of Pacific countries and IP allocations to them is not relevant to the question in hand. It is possible to get a /24 allocated from APNIC as far as I can see if you're applying for multihomed address space which is often the reason that people want their own address space. You then still face potential problems in having that routed globally but that's part of the trade off for not using address space from an ISP. I'm also interested in the truism that having your own /24 is a "good thing". How many entities with a /24 actually have anything remotely approaching 254 machines which are publicly visible from the net? From the perspective of having unwanted net probes delivered to your gateway router the smaller block you have the better - but a /28 or /29 is something that you get from your ISP.

John Tran wrote:
5) Next steps ------------- Under the database privacy policy, all non-portable assignments and non-portable sub-allocations that have not been specifically marked as public have now been made private. However, because some allocations and assignments within certain ranges appear to have been considered 'portable' by default from earlier practices in New Zealand, APNIC will restore the affected ranges from private to public. The ranges in question are: - 202.27.0./16 - 202.36.0.0/16 - 202.37.0.0/16 - 202.49.0.0/16, and - 202.50.0.0/16
Anyone holding addresses from these ranges that they wish to be made private, should contact APNIC helpdesk. The update will be done this week.
I'd encourage anyone who has a stake in a particular address block to contact APNIC and make real efforts to get their details sorted out - they should at least attempt to get their contact details up to date. Just because details reappear in the database the problem has not been resolved. Many people who believe they 'own' particular blocks of address space will not even be aware of this debate. I think the onus falls on the ISPs who are routing these blocks to contact their customers and help make them aware that they need to sort this out now. I was involved in the discussions in Auckland back in 98 when we came up with a pragmatic solution and it all got pushed back down the stack at that time as people were busy - let's not repeat that! From discussions I've had off line I believe there's good will around to sort this out once and for all. Let's not blow the opportunity.
6) NZTelecom custodianship -------------------------- In regard to the wider issue of NZTelecom as a custodian of the ranges listed above, APNIC operated in good faith, trying to promote aggregation and provide a clearer framework for the custodianship of address space in New Zealand.
That said, clearly there are now major concerns being expressed on this mailing list concerning portability of blocks within these ranges. The APNIC Secretariat will examine the records within these ranges and will work with NZTelecom, affected parties, and the community to find an appropriate solution. The solution will not happen overnight but the process is beginning immediately. Of course, APNIC will keep the New Zealand community fully up to date on the progress of the discussions.
The APNIC Secretariat would be happy to assist anyone with concerns. If you want to discuss your concerns with us, please call the helpdesk on +61-7-3858-3188 or send email to
.
This looks like it can be a positive outcome for all. The key issue is that those holders of historical allocations need to take steps to sort out their entitlement to use the address space in question. The mind shift that people need to make is that they don't 'own' address space - it's allocated to them on the basis of need and there are fees involved.
7) The past and the future -------------------------- Clearly, much of this stems back to a time when the framework for allocating and assigning resources was much less defined than it is today. The RIRs, with the community, are trying to provide a responsible framework for managing resources, both historical and existing resources.
Some of you may be aware of the ERX transfer project in which resources in use in this region were previously registered in the ARIN database and are now being transferred to the APNIC database and are now managed by APNIC. More information about this project is available at:
Many other steps are being taken. One such example is the policy recently implemented to support transfers of historical address space:
http://www.apnic.net/docs/policy/proposals/prop-006-v001.html
Others recently approved by the community, but yet to be implemented are:
* Recovery of unused address space: http://www.apnic.net/docs/policy/proposals/prop-017-v001.html
* Protecting historical records in the whois database: http://www.apnic.net/docs/policy/proposals/prop-018-v001.html
I would strongly urge anyone who is a custodian of Internet resources to read these policies and to contact APNIC if they have any queries.
Finally it is worth mentioning that four APNIC staff members will be at the forthcoming NZNOG meeting, and will be happy to meet with people and to provide a forum for discussing these issues.
Clearly there are policies here that will affect members of the NZ community. I'd encourage people to get across these so that more "astonishment" can be avoided.
participants (3)
-
Andy Linton
-
John Tran
-
Matthew Poole