[arin-ppml] Draft Policy 2011-13: IPv4 Number Resources for Use Within Region

[ARIN]

Draft Policy ARIN-2011-13
IPv4 Number Resources for Use Within Region


On 18 August 2011 the ARIN Advisory Council (AC) selected "IPv4 Number 
Resources for Use Within Region" as a  draft policy for adoption 
discussion on the PPML and at the Public Policy Meeting in Philadelphia 
in October.

The draft was developed by the AC from policy proposal "ARIN-prop-155 
IPv4 Number Resources for Use Within Region." Per the Policy Development 
Process the AC submitted text to ARIN for a staff and legal assessment 
prior to its selection as a draft policy. Below the draft policy is the 
ARIN staff and legal assessment, followed by the text that was submitted 
by the AC.

Draft Policy ARIN-2011-13 is below and can be found at:
https://www.arin.net/policy/proposals/2011_13.html

You are encouraged to discuss Draft Policy 2011-13 on the PPML prior to
the October Public Policy Meeting. Both the discussion on the list and
at the meeting will be used by the ARIN Advisory Council to determine
the community consensus for adopting this as policy.

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

Draft Policies and Proposals 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 ARIN-2011-13
IPv4 Number Resources for Use Within Region

Date: 24 August 2011

Policy statement:

Insert the following text in the NRPM:

4.2.1.7 - Presence within the ARIN region
These IPv4 addresses are issued solely for use in networks within the 
ARIN region. Organizations requesting IPv4 addresses from ARIN must 
provide documentation to demonstrate the addresses will be used to 
number customers/devices within the ARIN region and must agree to use 
the addresses solely for that purpose.  This requirement shall be 
binding only on number resources requested after its ratification by the 
ARIN Board of Trustees.

4.3.7 - Presence within the ARIN region
These IPv4 addresses are issued solely for use in networks within the 
ARIN region. Organizations requesting IPv4 addresses from ARIN must 
provide documentation to demonstrate the addresses will be used to 
number customers/devices within the ARIN region and must agree to use 
the addresses solely for that purpose.  This requirement shall be 
binding only on number resources requested after its ratification by the 
ARIN Board of Trustees.

Rationale:

ICANN's ICP-2 document established a framework for regional
Internet registries, each to serve a well-defined geographically
scoped constituency.

The various RIRs will exhaust their free-pools at different times.
This creates a situation in which requesting organizations attempt an
end-run on ICP-2 and the RIR framework by coming directly to ARIN for
space to use outside the ARIN region. In other cases, subsidiaries,
sister organizations located within the ARIN region, or global
organizations headquartered within the ARIN region have requested
space that is ultimately destined for use outside the ARIN region.
Failure to address this situation in a timely fashion will grant an
unfair advantage to large multinationals who will be able to "shop
around" requests for space and hasten RIR free pool runout in the ARIN
region.

Leaving this loophole unaddressed is incompatible with ARIN's
principle of stewardship.

This problem is not unique to ARIN. Similar proposals are under
consideration in the LACNIC and AfriNIC regions.

Timetable for implementation: Immediate


#####


ARIN STAFF ASSESSMENT

Proposal:  ARIN-prop-155 IPv4 Number Resources for Use Within Region
Date of Assessment: 18 August 2011

1.  Proposal Summary (Staff Understanding)

This policy makes clear that ARIN should provide address assignments and 
allocations to organizations that are for use solely within the ARIN region.

2. Comments

A. ARIN Staff Comments

•	ARIN staff has identified in a past policy experience report that ARIN 
is receiving an increasing number of requests where it is clear that the 
intended use is outside the region.  While the definition of a Regional 
Internet Registry in NRPM 2.2 supports the principle that ARIN issues 
space for use in the region, this is not clearly stated within existing 
policy.

•	This lack of criteria has caused confusion for both staff and 
customers alike.   Clear policy direction is needed, particularly now 
that IPv4 depletion is upon us, so that ARIN will issue space in a 
manner consistent with community expectations.

•	Staff notes that the proposed policy text is absolute in its phrasing, 
and while this appears to be appropriate for the policy intent, this 
staff evaluation does not include any specific assessment of the 
resources or efforts in enforcement post-issuance since the proposal 
does not address this aspect of the policy.

B. ARIN General Counsel

Directionally, counsel has no concern regarding a proposed ARIN policy 
intended to restrict the remaining allocations of IPV4 addresses within 
the ARIN service region.  However, this policy is rigid--it prohibits 
any use of such resources issues outside of the service region. Since a 
violation of the policy would justify revocation this aspect must be 
clearly evaluated.

3. Resource Impact

This policy would have minimal resource impact from an implementation 
aspect.  It is estimated that implementation would occur within 3 months 
after ratification by the ARIN Board of Trustees. The following would be 
needed in order to implement:

•	Updated guidelines
•	Staff training

4. Proposal Text

ARIN-prop-155
IPv4 Number Resources for Use Within Region

Policy statement:

Insert the following text in the NRPM:

4.2.1.7 - Presence within the ARIN region
These IPv4 addresses are issued solely for use in networks within the 
ARIN region. Organizations requesting IPv4 addresses from ARIN must 
provide documentation to demonstrate the addresses will be used to 
number customers/devices within the ARIN region and must agree to use 
the addresses solely for that purpose.  This requirement shall be 
binding only on number resources requested after its ratification by the 
ARIN Board of Trustees.

4.3.7 - Presence within the ARIN region
These IPv4 addresses are issued solely for use in networks within the 
ARIN region. Organizations requesting IPv4 addresses from ARIN must 
provide documentation to demonstrate the addresses will be used to 
number customers/devices within the ARIN region and must agree to use 
the addresses solely for that purpose.  This requirement shall be 
binding only on number resources requested after its ratification by the 
ARIN Board of Trustees.

Rationale:

ICANN's ICP-2 document established a framework for regional
Internet registries, each to serve a well-defined geographically
scoped constituency.

The various RIRs will exhaust their free-pools at different times.
This creates a situation in which requesting organizations attempt an
end-run on ICP-2 and the RIR framework by coming directly to ARIN for
space to use outside the ARIN region. In other cases, subsidiaries,
sister organizations located within the ARIN region, or global
organizations headquartered within the ARIN region have requested
space that is ultimately destined for use outside the ARIN region.
Failure to address this situation in a timely fashion will grant an
unfair advantage to large multinationals who will be able to "shop
around" requests for space and hasten RIR free pool runout in the ARIN
region.

Leaving this loophole unaddressed is incompatible with ARIN's
principle of stewardship.

This problem is not unique to ARIN. Similar proposals are under
consideration in the LACNIC and AfriNIC regions.

Timetable for implementation: Immediate