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[arin-ppml] Draft Policy 2009-2: Depleted IPv4 reserves

Draft Policy 2009-2
Depleted IPv4 reserves

The following draft policy text is being posted for feedback and
discussion on the Public Policy Mailing List (PPML).

This draft policy was developed by the ARIN Advisory Council (AC) from
Policy Proposal 81: Depleted IPv4 reserves. The AC has taken the
proposal and developed it into a draft policy. The AC was required to
submit text to ARIN for staff and legal assessment prior to selecting it
as a draft policy. The assessment, along with the text that was
assessed, is located below the draft policy.

On 20 March 2009 the ARIN Advisory Council (AC) selected Draft Policy
2009-2: Depleted IPv4 reserves for adoption discussion on the PPML and
at the upcoming Public Policy Meeting.

Draft Policy 2009-2 is below and can be found at:
https://www.arin.net/policy/proposals/2009_2.html

We encourage you to discuss Draft Policy 2009-2 on the PPML prior to the
ARIN XXIII Public Policy Meeting. Both the discussion on the PPML and at
the Public Policy Meeting will be used by the AC to determine the
community consensus regarding adopting this as policy.

The ARIN Policy Development Process can be found at:
https://www.arin.net/policy/pdp.html

All of the Draft Policies under discussion can be found at:
https://www.arin.net/policy/proposals/index.html

Regards,

Member Services
American Registry for Internet Numbers (ARIN)


## * ##


Draft Policy 2009-2
Depleted IPv4 reserves

Date: 23 March 2009

Policy statement:

(add the following section to the NRPM)

4.1.8 Depleted IPv4 reserves

A limit will be applied to all IPv4 address requests when ARIN's reserve
of unallocated IPv4 address space drops below an equivalent /9. When
this happens, an ISP or End User may receive up to a single /20 within a
six month period. This restriction will be lifted in the event the
reserve of unallocated IPv4 address space increases to an equivalent /7.

Rationale:

As the reserve of IPv4 address space becomes smaller, there is a risk
that many organizations will be denied resources by a large, last minute
request. By implementing a throttle on the last of the IPv4 address
space, a more limited group of organizations will be impacted, allowing
many organizations to receive ongoing resources during the transition to
IPv6.

According to the ARIN statistics page
http://www.arin.net/statistics/index.html, 1,993 organizations were
issued IP space in 2006 and 2007. Of these allocations 41% of the
applicants received less than a /20. On the opposite end, 82
organizations received large blocks. Given that the last reserve of IPv4
space cannot possibly meet the needs of the 82 organizations, the space
could be managed in a way to provide for the needs of a wider base of
consumers while the largest ISPs build momentum behind IPv6.

The goal is to find a balance between the needs of organizations
requiring space, and avoiding the restrictions on end user growth. For
this reason, any caps on allocations should be implemented when the
reserves are essentially depleted, rather than trying to restrict end
user growth when IP space is still readily available.

By putting a six month window on the maximum allocation, the remaining
IP space could provide at least one year for everyone to implement other
solutions while still being able to obtain an IPv4 address allocation.
The time period was also added to provide a consistent rate of
depletion, avoiding a scenario where a large organization could queue
multiple, justifiable requests, resulting in the scenario the proposal
is intended to avoid.

Additional language may need to be added in the event a paid transfer
policy is approved. The thinking is to have two pools of available IP.
One being the current, IANA allocated, reserve of IP space. The second
being IP blocks recovered through monetary incentive. This proposal
would apply to the IANA allocated reserves and would not apply to blocks
made available by monetary means.

An additional thought was to avoid tying this policy shift specifically
to the last /8 allocated by IANA. This allows the policy to come in and
out of play in the event that IPv4 address space is abandoned or
returned to ARIN.

Timetable for implementation: Immediate



#####


ARIN Staff Assessment

*Title: Depleted IPv4 Reserves*

*Proposal Submitted: 02 Dec 2008*

*Revision Submitted: 16 Feb 2009*

*Date of Assessment: 10 March 2009*

I. Understanding of the Policy:

*Staff Understanding of the Proposal:*

ARIN understands this policy goes into effect when ARIN has less than a
/9 worth of IPv4 address space available to be issued to customers. At
that time, an ISP or End user can only receive a /20 from ARIN within a
six month period. This restriction will be removed if ARIN’s available
pool of addresses increases to a /7 equivalent.

II. Comments:

A. ARIN Staff Comments:

          o One question to consider is whether staff should be setting
            aside a /9 in anticipation of this policy. If that is not
            done, there is the potential that one large request could
            take away a very large block of ARIN’s remaining inventory
            and leave us with far less than the /9 equivalent needed to
            implement this policy. For example, if there is one /8 left,
            and ISP A qualifies for a /8, and it gets issued, then there
            will be no address space left to issue under this policy.
                + If the intent is to make sure there is at least a /9
                  available to give out in /20 blocks, then the trigger
                  point may need to be reconsidered. Here are two
                  potential options:
                      # Trigger the policy when filling a request would
                        drop the supply below a /9
                      # Give the org whose request would drop the supply
                        below a /9 as many addresses as would take us to
                        a /9, then trigger the policy.

B. ARIN General Counsel Comments:

The policy does not pose any significant legal risk to ARIN. A community
decision to segment the remaining unissued IPV4 numbers to serve a
larger number of users on its face does not discriminate against or for
any user, large or small. Therefore it is legally unobjectionable. It is
a rational scheme for distribution reasonably related to meeting the
needs of as many end users as possible. Counsel respectfully suggests
that the policy as drafted may contain potential seeds of confusion by
providing for switching back to current distribution policies, and then
back to this policy.

III. Resource Impact

The resource impact of implementing this policy is viewed as minimal. It
is estimated that this policy could require up to 3 person months of
effort to implement following ratification by the ARIN Board of
Trustees. Because this implementation is not planned, it may preempt
ARIN’s current project deployment schedule. It may require the following:

    * Guidelines Changes
    * Modifications to existing registration software tools – they need
      to be able to report to staff existing inventory levels and to
      notify us when the /9 threshold is reached or is imminent.

Text assessed:

Depleted IPv4 reserves

*Policy statement:*

4.1.8 Depleted IPv4 reserves

A limit will be applied to all IPv4 address requests when ARIN's reserve
of unallocated IPv4 address space drops below an equivalent /9. When
this happens, an ISP or End User may receive up to a single /20 within a
six month period. This restriction will be lifted in the event the
reserve of unallocated IPv4 address space increases to an equivalent /7.