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[ppml] Policy Proposal 2007-18 - Staff Assessment

Policy Proposal 2007-18
Global Policy for the Allocation of the Remaining IPv4 Address Space

ARIN Staff Assessment

The assessment of this proposal includes comments from ARIN staff and
the ARIN General Counsel. It contains analysis of procedural, legal, and
resource concerns regarding the implementation of this policy proposal
as it is currently stated. Any changes to the language of the proposal
may necessitate further analysis by staff and Counsel.

I. Proposal

Policy Proposal is available as Annex A below and at:
http://www.arin.net/policy/proposals/2007_18.html

II. Understanding of the proposal

ARIN staff understands that this proposal is a global proposal. It would
reserve a certain number of /8s in the IANA pool to be allocated to the
RIRs when the remaining IANA /8s run out. The suggested reserve is 25
/8s, 5 per each RIR. When the IANA can not fulfill the last RIR request,
they will give what they can to that RIR. The IANA will then allocate
the 5 /8s to each RIR.

III. Comments

   A. ARIN Staff

     1. The policy conflicts with the spirit of RFC 2050 in which
fairness and efficiency of allocation by IANA to the RIRs is cited.

     2. If additional addresses are made available to IANA at some point
after the exhaustion phase is triggered, this policy would need to be
revised before IANA could do anything with the addresses.

     3. Author did not indicate placement in the NRPM. Staff would add
it to Section 10.

   B. ARIN General Counsel

"These two policies address the same issue, the global policy of what
allocation should be made and when regarding the last unissued IPv4
slash 8's from the IANA. Based on legal considerations counsel has
serious concerns about the implications of adopting 2007-18. Counsel
does not have similar concerns about 2007-23.

2007-23 describes a policy to allocate equally the last 5 blocs of
unissued slash 8's, providing one each to each of the 5 RIR's. This is a
rationing mechanism to allocate the last slash 8's.

2007-18 describes much more aggressive policy which would allocate the
last 25 such blocs equally, providing 5 each to each RIR.
The first policy proposal, 2007-23, is more consistent with the current
legal underpinnings of the RIR system, while 2007-23 substitutes a new
basis of allocation, equality between RIRs, who have very different
rates of utilization and need. The substitution of utilizing RIR
equality instead of a utilization based allocation may have significant
legal implications for ARIN.

Currently, if ARIN is legally challenged about its allocation policies,
and the underlying global policy, all current policies are based in need
and utilization. Since the takeup rate in each RIR is very different the
allocation policy proposed in 2007-23 undermines the current rationale
of need and utilization based allocation, and it is inconsistent with
all prior ARIN and global allocation policies.

Adoption of 2007-23 discriminates against the ARIN service region and
could reduce the amount of IPv4 resources available and instead shift
these resources to other continents, with less actual need than the ARIN
region. This will, in my opinion, raise fiduciary responsibility issues
for ARIN's Board, and may lead to counsel cautioning the Board members
regarding adoption of global policy that has an intentionally
discriminatory impact against or adverse to ARIN's service region."

Resource Impact – Minimal

The resource impact of implementing this policy is viewed as minimum.
Barring any unforeseen resource requirements, this policy could be
implemented within 30 - 90 days from the date of the ratification of the
policy by the ARIN Board of Trustees.  It will require the following:

-  Updates to Guidelines will be required
-  Staff training will be required

Respectfully submitted,

Member Services
American Registry for Internet Numbers (ARIN)


##*##


Annex A

Policy Proposal 2007-18
Global Policy for the Allocation of the Remaining IPv4 Address Space

Author: Roque Gagliano
Co-authors: Francisco Obispo, Hytham EL Nakhal, Didier Allain Kla

Proposal type: new

Policy term: permanent

Policy statement:

This policy describes the process for the allocation of the remaining
IPv4 space from IANA to the RIRs. When a minimum amount of available
space is reached, an identical number of IPv4 allocation units (/8s)
will be allocated from IANA to each RIR, replacing the current IPv4
allocation policy.

In order to fulfill the requirements of this policy, at the time it is
adopted, an identical number of IPv4 allocation units (N units) will be
reserved by IANA for each RIR. The number N is defined as: 5. The
reserved allocation units will no longer be part of the available space
at the IANA pool. The process for the allocation of the remaining IPv4
space is divided in two consecutive phases:

1. Existing Policy Phase:

During this phase IANA will continue allocating IPv4 addresses to the
RIRs using the existing allocation policy. This phase will continue
until a request for IPv4 address space from any RIR to IANA cannot be
fulfilled with the remaining IPv4 space available at the IANA pool.

This will be the last IPv4 address space request that IANA will accept
from any RIR. At this point the next phase of the process will be initiated.

2. Exhaustion Phase:

IANA will automatically allocate the reserved IPv4 allocation units to
each RIR (N units to each one) and respond to the last request with the
remaining available allocation units at the IANA pool (M units).

2.1. Size of the final IPv4 allocations:

During this phase IANA will automatically allocate N allocation units to
each RIR from the reserved space defined in this policy. IANA will also
allocate M allocation units to the RIR that submitted the last request
for IPv4 addresses.

2.2. Allocation of the remaining IPv4 Address space:

After the completion of the evaluation of the final request for IPv4
addresses, IANA MUST:

A) Immediately notify the NRO about the activation of the second phase
of this policy.

B) Proceed to allocate M allocation units to the RIR that submitted the
last request for IPv4 address space.

C) Proceed to allocate N allocation units to each RIR from the reserved
space.

Rationale:

The IANA pool of allocation units of IPv4 addresses (/8s) is decreasing
rapidly. A new policy is proposed to replace the current "on demand"
policy in order to bring certainty on how the remaining space will be
allocated. This policy eliminates the pressure on the remaining central
pool of addresses by allocating equal amount of allocation units (N) to
each RIR.

RIR may be studying slow-landing policies or the possibility to reserve
specific address spaces for "critical infrastructure" or new companies
in order to comply with anti-trust regulations in its region. This
policy allows each RIR to adopt those policies through its PDP, which is
simpler than a global policy discussion process.

Each RIR will have the exact information on the amount of address spaces
that they will be receiving as a last allocation from the IANA.

The policy is written in such a way that the discussion could be split
in two sections: first do we agree on the concept of the policy and
second what is the appropriate value for the last allocation units N.

Timetable for implementation: This is a Global policy that needs to be
approved by all RIRs and then ratified by ASO/ICANN. It has already
reached consensus at LACNIC meeting.