[arin-ppml] Draft Policy ARIN-2013-4: RIR Principles

[Andrew Dul]

I support adding these guiding principles to the NRPM, furthermore I
would support efforts to introduce this policy in all RIR regions to
make this a global policy. 

Comments on the proposed text in-line below.

Andrew

On 5/17/2013 9:53 AM, ARIN wrote:
> Draft Policy ARIN-2013-4
> RIR Principles
>
> On 16 May 2013 the ARIN Advisory Council (AC) accepted "ARIN-prop-187
> RIR Principles" as a Draft Policy.
>
> Draft Policy ARIN-2013-4 is below and can be found at:
> https://www.arin.net/policy/proposals/2013_4.html
>
>
> ## * ##
>
>
> Draft Policy ARIN-2013-4
> RIR Principles
>
> Date: 17 May 2013
>
> Problem Statement:
>
> The original text in RFC 2050 both "describes the registry system for
> the distribution of globally unique Internet address space and
> registry operations" and provides "rules and guidelines [principles]
> governing the distribution of this address space."
>
> The currently proposed update (RFC2050bis) "provides information about
> the current Internet Numbers Registry System used in the distribution
> of globally unique Internet Protocol (IP) address space and autonomous
> system (AS) numbers" and "provides information about the processes for
> further evolution of the Internet Numbers Registry System."
>
> This means that the guiding principles of stewardship are not
> currently being carried forward into the new document. The goals of
> Conservation (efficient utilization based on need), Routability
> (hierarchical aggregation), and Registration (uniqueness) are as
> important, if not more so, now that the transition to IPv6 is upon us.
> This can be rectified by documenting these principles in RIR policy.
>
> Policy Statement:
>
> Section 0: Principles and Goals of the Internet Registry System
>
> 0.1. Efficient utilization based on need (Conservation)
>
> Policies for managing Internet number resources must support fair
> distribution of globally unique Internet address space according to
> the operational needs of the end-users and Internet Service Providers
> operating networks using this address space. The registry should
> prevent stockpiling in order to maximize the conservation and
> efficient utilization of the Internet address space.

This section should use the new proposed convention of "LIR/ISP" as
being developed in ARIN-2013-5.

s/this address space/IP number resources/r
s/Internet address space/IP number resources/r

I think this section should have an explicit reference to the difference
in conservation techniques for IPv4 and IPv6.  A proposed sentence might
be something like this... "Conservation goals may vary due to the
technical differences between IP number resources pools, for example the
relatively limited size of the IPv4 address pool causes a desire to see
the number space more highly utilized compared to the vast availability
of IP numbers within the IPv6 address pool."

>
> 0.1.1. Documented Justified Need (Needs Based)
>
> Assignment of Internet number resources is based on documented
> operational need. Utilization rate of address space will be a key
> factor in number resource assignment. To this end, registrants should
> have documented justified need available for each assignment.
> Organizations will be assigned resources based on immediate
> utilization plus expected utilization.

Utilization rate is much more important for IPv4 than IPv6. 

Suggested revision for "Utilization rate of address space will be a key
factor in number resource assignment."

"Utilization rate of address space will be an important factor in
justifying need for IP number resources.  However, utilization rates
will vary due to the technical differences (e.g. IPv4 vs. IPv6) between
number resource pools."

>
> In order to promote increased usage of Internet number resources,
> resource holders will be required to provide an accounting of
> resources currently held demonstrating efficient utilization. Internet
> number resources are valid as long as the criteria continues to be
> met. The transfer of Internet number resources from one party to
> another must be approved by the regional registries. The party trying
> to obtain the resources must meet the same criteria as if they were
> requesting resources directly from the IR.
>
> All Internet number resource requests are subject to audit and
> verification by any means deemed appropriate by the regional registry.
>

I suspect the above two paragraphs may be lightning rods against the
policy proposal.   May I suggest the following single paragraph in lieu 
of the above two paragraphs.

In order meet the Principles and Goals of the Internet Registry System,
resource holders may be required from time to time to provide an
accounting and current usage of resources currently held.  The RIRs
shall set policies to define these accounting mythologies as part of
their community driven policy process.


> 0.2. Hierarchical aggregation (Routability)
>
> Policies for managing Internet number resources must support
> distribution of globally unique Internet addresses in a hierarchical
> manner, permitting the routing scalability of the addresses. This
> scalability is necessary to ensure proper operation of Internet
> routing, although it must be stressed that routability is in no way
> guaranteed with the allocation or assignment of IPv4 addresses.
>

Should the RIR's goals be "LISP agnostic"?  That is if LISP becomes the
predominant routing methodology in the future, one would not necessarily
expect the goals of the RIRs to change. 

Suggested change to end of first sentence.

... permitting the routing scalability of the addresses as required by
the current technical limitations of global routing protocols.

> 0.3. Uniqueness (Registration)
>
> Provision of a public registry documenting Internet number resource
> allocation, reallocation, assignment, and reassignment is necessary to:
>
> a) ensure uniqueness and to to provide operational staff with
> information on who is using the number resource b) to provide a
> contact in case of operational/security problems (e.g. Law
> Enforcement) c) to ensure that a provider has exhausted a majority of
> its current CIDR allocation, thereby justifying an additional
> allocation d) to assist in IP allocation studies.

Suggested revision for "C"

to allow a LIR to demonstrate and disclose reassignment of IP number
resources to third-parties

>
> It is imperative that reassignment information be submitted in a
> prompt and efficient manner to facilitate database maintenance and
> ensure database integrity.
>
> 0.4. Stewardship
>
> It should be noted that efficient utilization and hierarchical
> aggregation are often conflicting goals. All the above goals may
> sometimes be in conflict with the interests of individual end-users or
> Internet Service Providers. Care must be taken to ensure balance with
> these conflicting goals given the resource availability, relative size
> of the resource, and number resource specific technical dynamics, for
> each type of number resource. For example, efficient utilization
> becomes a more prominent issue than aggregation as the IPv4 free pool
> depletes and IPv4 resource availability in any transfer market
> decreases. Conversely, because the IPv6 number space is orders of
> magnitude larger than the IPv4 number space, the scale tips away from
> efficient utilization towards hierarchical aggregation for IPv6 number
> resources.

Perhaps add a statement specifically about Stewardship

"Stewardship of IP number resources is the balance of overseeing and
protecting the interests of all Internet stakeholders to further the
development and expansion of the Internet and the Internet Registry System."

Also...

justified need as a conflicting goal should be explicitly mentioned. 

"It should be noted that efficient utilization, justified need, and
hierarchical aggregation are often conflicting goals."

Use the new LIR/ISP convention instead of "Internet Service Providers"



>
> Comments:
>
> a. Timetable for implementation: immediately
>
> b. I believe that it would be beneficial for IANA to adopt these
> principles as well, and encourage the community to consider a global
> policy proposal.
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