ARIN-PPML Message

[arin-ppml] Draft Policy 2012-4: Return to 12 Month Supply and Reset Trigger to /8 in Free Pool

Draft Policy ARIN-2012-4
Return to 12 Month Supply and Reset Trigger to /8 in Free Pool

On 8 March 2012 the ARIN Advisory Council (AC) selected "Return to 12 
Month Supply and Reset Trigger to /8 in Free Pool" as a  draft policy 
for adoption discussion on the PPML and at the Public Policy Meeting in 
Vancouver in April.

The draft was developed by the AC from policy proposal "ARIN-prop-162 
Redefining request window in 4.2.4.4." 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-2012-4 is below and can be found at:
https://www.arin.net/policy/proposals/2012_4.html

You are encouraged to discuss Draft Policy 2012-4 on the PPML prior to
the April 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-2012-4
Return to 12 Month Supply and Reset Trigger to /8 in Free Pool

Date: 14 March 2012

Policy statement:

4.2.4.4. Subscriber Members After One Year

After an organization has been a subscriber member of ARIN for one year, 
they may choose to request up to a twelve (12) month supply of IP addresses.

When the ARIN Free Pool is down to the equivalent of one /8, excluding 
all special reservations, the length of supply that an organization may 
request will be reduced. An organization may choose to request up to a 
three (3) month supply of IP addresses. Any request that reduces the 
ARIN free pool below the /8 threshold above will trigger the reduction 
for that and all subsequent requests by all organizations.

Rationale:

There has been discussion in the community that ARIN's inventory of IPv4 
addresses may be excessive given the reduction in the rate of 
consumption which is concurrent with the reduction to a 3 month supply 
when ARIN received its last /8 at IANA run-out. And that such an excess 
inventory in the ARIN region may be damaging the transition to IPv6 by 
elongating the amount of time between ARIN's exhaustion and exhaustion 
by other RIR's, thus creating a dangerous skew across parts of Internet 
in the need to transition to IPv6. One solution for this issue is to 
increase ARIN's rate of consumption by restoring the a 12 month supply 
of addresses.

ARIN's stewardship responsibilities are of primary concern in this 
region. However, restoring the a 12 month supply of addresses is 
consistent with these stewardship responsibilities. Asking businesses to 
request addresses on a three month basis with such large inventory 
available at ARIN unnecessarily increases the cost and complexity of 
operating networks; repeated and slow interactions with ARIN, duplicate 
paperwork requirements and an inefficient use of resources by all 
compound the pain.

The original intent of ARIN-2009-8 "Equitable IPv4 Run-Out" wasn't 
necessarily to slow the consumption of IPv4 but to limit the competitive 
disadvantage created by unequal run-out. However, when the trigger of 
IANA run-out was selected it wasn't anticipated that ARIN would have 
more that 5 /8s in inventory when the IANA run-out occurred. Therefore, 
restoring the 12-month supply and resetting the trigger for a reduction 
to a 3-month supply to a locally controlled event seems consistent with 
the original intent of ARIN-2009-8 as well.

Considering that the ARIN region has consumed significantly less than a 
/8 since the 3-month supply was triggered at IANA run-out approximately 
a year ago; Resetting the trigger for the 3-month supply to /8 in the 
free pool, excluding all special reservations, seems reasonable. The 
special reservations to be excluded, should include all reservations 
made in policy, including those in sections 4.4, 4.10, any new 
reservations made by subsequent policies, and may also include 
reservations for draft policies in process at the board's discretion, 
such as Draft Policy ARIN-2011-5: Shared Transition Space for IPv4 
Address Extension.

Please Note: By triggering on any request that would drop the free pool 
below /8 it is possible that there will be slightly more or slightly 
less than /8 available after the triggering request is fulfilled. The 
size of the triggering request and the exact amount above /8 available 
in the free pool will determine how much more or less than /8 will be 
available after the triggering request is fulfilled. This could be as 
much as 3/4 of the triggering request above /8 or as much as 1/4 of the 
triggering request below /8 available after fulfilling the triggering 
request.

To help clarify how this policy proposal changes Section 4.2.4.4, the 
current policy text as of Feb 10, 2012 is included below;

4.2.4.4. Subscriber Members After One Year

After an organization has been a subscriber member of ARIN for one year, 
they may choose to request up to a 12-month supply of IP addresses.

When ARIN receives its last /8, by IANA implementing section 10.4.2.2, 
the length of supply that an organization may request will be reduced. 
An organization may choose to request up to a 3-month supply of IP 
addresses.

Timetable for implementation: Immediate


##########


ARIN STAFF ASSESSMENT

Draft Policy: Proposal 162 “Return to 12 month Supply and Reset Trigger 
to /8 in Free Pool”
Date of Assessment:  23 Feb 2012

1.  Proposal Summary (Staff Understanding)

This proposal would revert NRPM section 4.2.4.4 “Subscriber Members 
After One Year” back to an earlier version in which an organization may 
request up to a 12 month supply of IPv4 addresses.  At the time that the 
ARIN free pool is the equivalent of a /8, an organization would only be 
able to request a 3 month supply.

2. Comments

A.	ARIN Staff Comments

•	Background Information for consideration:

Currently, ARIN has ~1,900 /24s free, ~800 /23s free, ~400 /22s free, 
etc. These smaller blocks are very useful to a large segment of ARIN's 
customers as we typically issue mostly small blocks to customers on a 
daily basis.  The total number of these small, discontiguous IPv4 blocks 
fluctuates often due to returns and revocations, which are quite common 
with these smaller blocks.

In contrast, ARIN has a very limited supply of large aggregates – 
currently there is a single contiguous /8 free (104.0.0.0/8), two /9s, 
three /10s, five /11s, etc.  Because we have a limited number of these 
larger aggregates, we will exhaust the supply of large aggregates long 
before we exhaust the supply of smaller aggregates.  We see very little 
churn with these larger blocks as ARIN rarely receives back large 
aggregates for re-distribution.

It is important to note that NRPM 4.1.6 prevents ARIN from issuing 
multiple prefixes to satisfy a single request – e.g. a large operator 
cannot receive a /12 allocation compromised of multiple prefixes.

•	Taking the above information into consideration, staff believes it may 
be operationally prudent and practicable to reserve a single contiguous 
/8 to serve as the trigger for this policy.

o	Doing it this way offers a fixed, easily understood target for the 
community to track.
o	It's a very clear window into our inventory status, and is therefore 
more transparent to the community.
o	It would allow operators to better plan for the future as ARIN policy 
switches from a 12-month allocation window back to a 3-month allocation 
window.

•	Issuing a 12-month supply of IPv4 addresses will likely significantly 
accelerate the depletion of ARIN’s existing IPv4 free pool. 
Historically, ARIN’s IPv4 consumption rate was roughly doubled when 
issuing a 12-month supply vs a 3-month supply.
o	From 2008 through 2010, ARIN issued 3.36, 2.46, and 2.69  /8s 
respectively when issuing a 12-month supply, vs 1.32 /8s in 2011 when 
the 3-month supply policy went into effect.

•	With the reintroduction of a 12-month supply window, there is the 
possibility that several very large requests could quickly deplete 
ARIN’s free pool.  In light of this fact, the community may want to 
consider bringing back a maximum allocation/assignment size.


B. ARIN General Counsel

The policy proposal is a major event, since it will dramatically change 
the date of IPV4 run out at ARIN. This is a profound policy, but not 
legal change.


3. Resource Impact

This policy would have major 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:

•	Software needed to track the /8 equivalent trigger
•	Updated guidelines
•	Staff training

4. Proposal Text

Policy statement:

New Title: Return to 12 Month Supply and Reset Trigger to /8 in Free Pool

Date: 22 FEB 2012

Policy statement:

4.2.4.4. Subscriber Members After One Year
After an organization has been a subscriber member of ARIN for one year, 
they may choose to request up to a twelve (12) month supply of IP addresses.

When the ARIN Free Pool is down to the equivalent of one /8, excluding 
all special reservations, the length of supply that an organization may 
request will be reduced. An organization may choose to request up to a 
three (3) month supply of IP addresses. Any request that reduces the 
ARIN free pool below the /8 threshold above will trigger the reduction 
for that and all subsequent requests by all organizations.

Rationale:

There has been discussion in the community that ARIN's inventory of IPv4 
addresses may be excessive given the reduction in the rate of 
consumption which is concurrent with the reduction to a 3 month supply 
when ARIN received its last /8 at IANA run-out. And that such an excess 
inventory in the ARIN region may be damaging the transition to IPv6 by 
elongating the amount of time between ARIN's exhaustion and exhaustion 
by other RIR's, thus creating a dangerous skew across parts of Internet 
in the need to transition to IPv6. One solution for this issue is to 
increase ARIN's rate of consumption by restoring the a 12 month supply 
of addresses.

ARIN's stewardship responsibilities are of primary concern in this 
region. However, restoring the a 12 month supply of addresses is 
consistent with these stewardship responsibilities. Asking businesses to 
request addresses on a three month basis with such large inventory 
available at ARIN unnecessarily increases the cost and complexity of 
operating networks; repeated and slow interactions with ARIN, duplicate 
paperwork requirements and an inefficient use of resources by all 
compound the pain.

The original intent of ARIN-2009-8 "Equitable IPv4 Run-Out" wasn't 
necessarily to slow the consumption of IPv4 but to limit the competitive 
disadvantage created by unequal run-out. However, when the trigger of 
IANA run-out was selected it wasn't anticipated that ARIN would have 
more that 5 /8s in inventory when the IANA run-out occurred. Therefore, 
restoring the 12-month supply and resetting the trigger for a reduction 
to a 3-month supply to a locally controlled event seems consistent with 
the original intent of ARIN-2009-8 as well.
Considering that the ARIN region has consumed significantly less than a 
/8 since the 3-month supply was triggered at IANA run-out approximately 
a year ago; Resetting the trigger for the 3-month supply to /8 in the 
free pool, excluding all special reservations, seems reasonable. The 
special reservations to be excluded, should include all reservations 
made in policy, including those in sections 4.4, 4.10, any new 
reservations made by subsequent policies, and may also include 
reservations for draft policies in process at the board's discretion, 
such as Draft Policy ARIN-2011-5: Shared Transition Space for IPv4 
Address Extension.

Please Note: By triggering on any request that would drop the free pool 
below /8 it is possible that there will be slightly more or slightly 
less than /8 available after the triggering request is fulfilled. The 
size of the triggering request and the exact amount above /8 available 
in the free pool will determine how much more or less than /8 will be 
available after the triggering request is fulfilled. This could be as 
much as 3/4 of the triggering request above /8 or as much as 1/4 of the 
triggering request below /8 available after fulfilling the triggering 
request.

To help clarify how this policy proposal changes Section 4.2.4.4, the 
current policy text as of Feb 10, 2012 is included below;
4.2.4.4. Subscriber Members After One Year
After an organization has been a subscriber member of ARIN for one year, 
they may choose to request up to a 12-month supply of IP addresses. When 
ARIN receives its last /8, by IANA implementing section 10.4.2.2, the 
length of supply that an organization may request will be reduced. An 
organization may choose to request up to a 3-month supply of IP addresses.