[arin-ppml] LAST CALL: Recommended Draft Policy ARIN-2014-10: Remove Sections 4.6 and 4.7

[ARIN]

The ARIN Advisory Council (AC) met on 16 April 2014 and decided to
send the following to last call:

   Recommended Draft Policy ARIN-2014-10: Remove Sections 4.6 and 4.7

Feedback is encouraged during the last call period. All comments should
be provided to the Public Policy Mailing List. This last call will
expire on 5 May 2014. After last call the AC will conduct their
last call review.

The draft policy text is below and available at:
https://www.arin.net/policy/proposals/

The ARIN Policy Development Process is available at:
https://www.arin.net/policy/pdp.html

Regards,

Communications and Member Services
American Registry for Internet Numbers (ARIN)


## * ##


Recommended Draft Policy ARIN-2014-10
Remove Sections 4.6 and 4.7

Date: 25 March 2014

AC's assessment of conformance with the Principles of Internet Number 
Resource Policy:

"Draft Policy ARIN-2014-10: Remove Sections 4.6 and 4.7 - This proposal
will permanently remove suspended NRPM policies 4.6 and 4.7, due to the
potential for abuse by large requests. The ARIN staff has noted that
these two policies have rarely been used by the community since their
implementation and have not been used at all in the past 6 years. 
Removing these Policies has received support from the community and is 
technically sound."

Problem Statement:

The ARIN Board of Trustees has suspended sections 4.6 and 4.7 of the 
Number Resource Policy Manual at their January 6, 2014 meeting. This was 
done in response to the potential for abuse of these sections as the 
IPv4 free pool approaches runout.

The last request to use section 4.6, amnesty and aggregation requests, 
was in 2004. The last request to use section 4.7, aggregation requests, 
was in 2008. These sections have not been used to request resources in 
more than five years.

There are a number of organizations who could use these sections as 
justification to request an allocation or assignment that could deplete 
the remaining ARIN IPv4 free pool. This could have unintended 
consequences with ARIN running out so unexpectedly, that outweigh the 
intended benefits the sections were meant to provide.

These sections could also be used to justify large transfers, that would 
put ARIN in an undesirable position trying to reclaim previous 
resources, when the IPv4 pool is depleted. This risk also outweighs the 
intended benefits the sections were meant to provide.

Efforts could be made to patch these sections, and provide additional 
measures to limit abuse. There does not appear to be a need, however, 
given how little the sections have been utilized. As we become aware of 
other implications it may be best to try and deal with them through a 
separate, independent proposal.

Policy statement:

Remove sections 4.6 and 4.7.

Comments:
a.Timetable for implementation: Immediate
b.Anything else:

4.6. Amnesty and Aggregation Requests

4.6.1 Intent of this policy

This policy is intended to allow the community and ARIN staff to work
together with holders of address resources in the best interests of the
community by facilitating the return of unused address space and the
aggregation of existing space in a manner which is in the best interests
of both parties.

All transactions under this policy must either create greater
aggregation (a reduction in the number of prefixes) or the return of
address space. Transactions should only be accepted under this policy if
they are in the interests of the community (e.g. they improve
aggregation or result in a net reclamation of space).

4.6.2 No penalty for returning or aggregating

ARIN shall seek to make the return of address space as convenient and
risk-free to the returning organization as possible. An organization
with several non-contiguous blocks seeking to aggregate and return space
at the same time should be accommodated if possible. If it is possible
to expand one block, for example, to facilitate the return of other
blocks, ARIN should do that.

4.6.3 Return should not force renumbering

An organization shall be allowed to return a partial block of any size
to ARIN. For any return larger than a /24, ARIN shall not require that
the non-returned portion of the block be renumbered unless the returning
organization wishes to do so.

4.6.4 Timeframe for return

Any organization which is returning addresses under this policy shall
negotiate with ARIN an appropriate timeframe in which to return the
addresses after any new resources are received under this policy. In the
case of a simple return, the timeframe shall be immediate. In the case
where renumbering into new addresses out of existing addresses to be
returned is required, the returning organization shall sign a contract
with ARIN which stipulates a final return date not less than 6 months
nor more than 18 months after the receipt of new addresses. If an
organization misses this return date, but, ARIN believes the
organization is working in good faith to complete the renumbering, ARIN
may grant a single extension of 6-12 months as staff deems appropriate
to the situation. Such an extension must be requested in writing (email
to hostmaster at arin.net) by the organization at least 15 days prior to
the original expiration date.

4.6.5 RSA Required if new addresses received

Any organization which receives any additional addresses under this
policy shall be required to sign an ARIN RSA which will apply to all new
addresses issued and to any retained blocks which are expanded under
this policy.

4.6.6 Annual contact required

Any organization which participates in this policy shall be required to
sign an agreement stipulating that ARIN will attempt contact at least
once per year via the contact mechanisms registered for the organization
in Whois. Should ARIN fail to make contact, after reasonable effort the
organization shall be flagged as "unreachable" in Whois. After six
months in "unreachable" status, the organization agrees that ARIN may
consider all resources held by the organization to be abandoned and
reclaim such resources. Should the organization make contact with ARIN
prior to the end of the aforementioned six month period and update their
contact information appropriately, ARIN shall remove the "unreachable"
status and the annual contact cycle shall continue as normal. If the
organization pays annual fees to ARIN, the payment of annual fees shall
be considered sufficient contact.

4.7. Aggregation Requests

If an organization, whether a member or non-member, ISP or end-user,
relinquishes a group of portable, non-aggregatable address blocks to
ARIN, they shall be allowed to receive a block in exchange, /24 or
larger, but no more than the largest block that could contain all of the
returned blocks. Exchanged space shall be returned within 12 months. If
the gain in the number of addresses is greater than 4096, the
aggregation request must be evaluated by the ARIN in accordance with the
current IPv4 allocation policy. If all of the previous address blocks
were maintained in the ARIN database without maintenance fees, the
replacement space shall be as well, but if any one of the returned
blocks had associated maintenance fees, then the replacement block shall
also be subject to maintenance fees.

##########

ARIN Staff and Legal Assessment

ARIN-prop-2014-10 – “Remove Sections 4.6 and 4.7”

Date of Assessment: 04 Mar 2014

1. Summary (Staff Understanding)

This proposal seeks to permanently remove suspended NRPM policies 4.6 
and 4.7 based on the rationale that any number of large organizations 
could potentially abuse these policies and request enough IPv4 address 
space to completely deplete ARIN’s available pool of addresses in one 
request.

2. Comments

A. ARIN Staff Comments

· These two policies have rarely been used by the community since 
their implementation and in fact, have not been used at all in the past 
6 years.
o The last request to use section 4.6, amnesty and aggregation requests, 
was in 2004.
o The last request to use section 4.7, aggregation requests, was in 2008.
· Customers wishing to return resources to ARIN have always been able 
to, and can continue to do so, by simply submitting a request ticket to 
hostmaster at arin.net. Staff then does the requisite verification of the 
request for the return of space.
o The ARIN website has recently been updated to more clearly outline the 
procedure for returning address space to ARIN.
· This proposal could be implemented as written and would have no 
operational impact.

B. ARIN General Counsel - Legal Assessment

The policy does not create legal concerns.

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

4. Proposal Text

Problem Statement:

The ARIN Board of Trustees has suspended sections 4.6 and 4.7 of the 
Number Resource Policy Manual at their January 6, 2014 meeting. This was 
done in response to the potential for abuse of these sections as the 
IPv4 free pool approaches runout.

The last request to use section 4.6, amnesty and aggregation requests, 
was in 2004. The last request to use section 4.7, aggregation requests, 
was in 2008. These sections have not been used to request resources in 
more than five years.

There are a number of organizations who could use these sections as 
justification to request an allocation or assignment that could deplete 
the remaining ARIN IPv4 free pool. This could have unintended 
consequences with ARIN running out so unexpectedly, that outweigh the 
intended benefits the sections were meant to provide.

These sections could also be used to justify large transfers, that would 
put ARIN in an undesirable position trying to reclaim previous 
resources, when the IPv4 pool is depleted. This risk also outweighs the 
intended benefits the sections were meant to provide.

Efforts could be made to patch these sections, and provide additional 
measures to limit abuse. There does not appear to be a need, however, 
given how little the sections have been utilized. As we become aware of 
other implications it may be best to try and deal with them through a 
separate, independent proposal.

Policy statement:

Remove sections 4.6 and 4.7.