From info at arin.net Tue Mar 4 11:06:51 2008 From: info at arin.net (Member Services) Date: Tue, 04 Mar 2008 11:06:51 -0500 Subject: Policy Proposal 2008-3: Community Networks IPv6 Allocation Message-ID: <47CD739B.3060905@arin.net> On 21 February 2008, the ARIN Advisory Council (AC) concluded its review of "Community Networks IPv6 Allocation" and accepted it as a formal policy proposal with the condition that the policy text be revised by the author so that it can be put into the ARIN Number Resource Policy Manual. The author submitted a revised version of the proposal. The proposal is designated Policy Proposal 2008-3: Community Networks IPv6 Allocation. The proposal text is below and can be found at: http://www.arin.net/policy/proposals/2008_3.html All persons in the community are encouraged to discuss Policy Proposal 2008-3 prior to it being presented at the upcoming ARIN XXI Public Policy Meeting. Both the discussion on the Public Policy Mailing List and at the Public Policy Meeting will be used to determine the community consensus regarding this policy proposal. The ARIN Internet Resource Policy Evaluation Process can be found at: http://www.arin.net/policy/irpep.html ARIN's Policy Proposal Archive can be found at: http://www.arin.net/policy/proposals/proposal_archive.html Regards, Member Services American Registry for Internet Numbers (ARIN) ## * ## Policy Proposal 2008-3 Community Networks IPv6 Allocation Author: Joshua King Proposal Version: 1 Date: 4 March 2008 Proposal type: new Policy term: permanent Policy statement: [Add Section 2.8 to the NRPM.] 2.8 Community Network A community network is a generic reference to any network that is operated by a group of people living in a particular local area organized for the purposes of delivery or provision of network services to the residents of an incorporated or unincorporated regional municipality, city, town, village, rural municipality, township, county, district or other municipality or other such geographic space, however designated. [Modify 6.5.8.1b as follows.] b. qualify for an IPv4 assignment or allocation from ARIN under the IPv4 policy currently in effect or be a Community Network as defined in Section 2.8. Rationale: There are currently a number of projects globally that aim to develop community network infrastructure and related technologies. These are usually coordinated by volunteer-run, grassroots organizations which lack many of the resources of traditional internet service providers and other network operators. They have diverse goals, including public policy, software development, and implementation of community services and resources. Many of them provide services free of charge, and thus lack any paying user base. However, in order to create and maintain community networks that are often composed of hundreds if not thousands of inexpensive, commodity hosts and devices, a significant amount of address space will be required. Current-generation workarounds to this problem, such as NAT, not only make it difficult to develop next-generation decentralized network technology by segmenting the community's architecture from the Internet as a whole, but will cease to be as viable a stopgap as the Internet moves towards IPv6 integration. Even now, common community networking software solutions such as CUWiNware (http://www.cuwin.net) and Freifunk (http://www.freifunk.at) have nascent IPv6 addressing support, but participating organizations lack the address space for widespread testing or adoption. As such, it is necessary to implement an procedure as soon as possible for these segregated networks to acquire address space. These organizations do not meet the criteria traditionally defined for LIR's, and thus cannot acquire address allocations through existing templates. By establishing a procedure by which these organizations can seek to acquire the resources they require for further development, ARIN can reach out to this active community and establish a small but definite space for them in the future of Internet. Timetable for implementation: Immediate. From info at arin.net Thu Mar 6 09:27:15 2008 From: info at arin.net (Member Services) Date: Thu, 06 Mar 2008 09:27:15 -0500 Subject: Lame Delegations Message-ID: <47CFFF43.5080608@arin.net> ARIN has elected to remove the Lame Delegation identification and notification software from production. Following several months of periodic issues, ARIN determined it is best to take the software offline, review, and retest several components. One recent problem resulted in blank e-mail messages being sent to approximately one hundred organizations. We apologize for this inconvenience. The software is expected to be back online in early April 2008. If you have any further questions or comments, please contact info at arin.net. Regards, Mark Kosters Chief Technology Officer From info at arin.net Fri Mar 7 17:19:07 2008 From: info at arin.net (Member Services) Date: Fri, 07 Mar 2008 17:19:07 -0500 Subject: Policy Proposal 2008-2: IPv4 Transfer Policy Proposal - Revised Text Message-ID: <47D1BF5B.9030707@arin.net> Policy Proposal 2008-2, IPv4 Transfer Policy Proposal, has been revised. This proposal is open for discussion on this mailing list and will be on the agenda at the upcoming ARIN Public Policy Meeting in Denver. The current policy proposal text is provided below and is also available at: http://www.arin.net/policy/proposals/2008_2.html Regards, Member Services American Registry for Internet Numbers (ARIN) ### * ### Policy Proposal 2008-2 IPv4 Transfer Policy Proposal Author: ARIN Advisory Council Proposal Version: 1.1 Date: 7 March 2008 Proposal type: modify Policy term: permanent Policy statement: Replace the current NRPM section 8 with the following -- 8. Transfers [8.1. Transfers ? retain as is: Number resources are non-transferable and are not assignable to any other organization unless ARIN has expressly and in writing approved a request for transfer. ARIN is tasked with making prudent decisions on whether to approve the transfer of number resources. It should be understood that number resources are not "sold" under ARIN administration. Rather, number resources are assigned to an organization for its exclusive use for the purpose stated in the request, provided the terms of the Registration Services Agreement continue to be met and the stated purpose for the number resources remains the same. Number resources are administered and assigned according to ARIN's published policies. Number resources are issued, based on justified need, to organizations, not to individuals representing those organizations. Thus, if a company goes out of business, regardless of the reason, the point of contact (POC) listed for the number resource does not have the authority to sell, transfer, assign, or give the number resource to any other person or organization. The POC must notify ARIN if a business fails so the assigned number resources can be returned to the available pool of number resources if a transfer is not requested and justified.] [8.2 ? remove the word ?only?, and retitle to ?Transfers as an Artifact of Change in Resource Holder Ownership?: 8.2. Transfers as an Artifact of Change in Resource Holder Ownership ARIN will consider requests for the transfer of number resources upon receipt of evidence that the new entity has acquired the assets which had, as of the date of the acquisition or proposed reorganization, justified the current entity's use of the number resource. Examples of assets that justify use of the number resource include, but are not limited to: ? Existing customer base ? Qualified hardware inventory ? Specific software requirements.] [Renumber existing 8.3 to 8.2.1 and retitle to ?Documentation Requirements for Transfers as an Artifact of Change in Resource Holder Ownership?: 8.2.1. Documentation Requirements for Transfers as an Artifact of Change in Resource Holder Ownership In evaluating a request for transfer, ARIN may require the requesting organization to provide any of the following documents, as applicable, plus any other documents deemed appropriate: ? An authenticated copy of the instrument(s) effecting the transfer of assets, e.g., bill of sale, certificate of merger, contract, deed, or court decree ? A detailed inventory of all assets utilized by the requesting party in maintaining and using the number resource ? A list of the requesting party's customers using the number resource. If further justification is required, the requesting party may be asked to provide any of the following, or other supporting documentation, as applicable: ? A general listing of the assets or components acquired ? A specific description of acquisitions, including: o Type and quantity of equipment o Customer base ? A description of how number resources are being utilized ? Network engineering plans, including: o Host counts o Subnet masking o Network diagrams o Reassignments to customers] 8.3. Simple Transfer of IPv4 Addresses After the exhaustion of the IANA IPv4 free pool (when IANA allocates its last unallocated unicast IPv4 address block), ARIN will also process IPv4 address transfer requests subject to the following conditions. These conditions apply only to Simple IPv4 transfers, not to transfers performed according to section 8.2. 8.3.1 Conditions on the transferor (the organization providing addresses for transfer): ? The transferor resides in the ARIN service area. ? The transferor has signed an RSA and/or a legacy RSA covering the IPv4 addresses transferred. ? The transferor has no outstanding balances with ARIN. ? The transferor has not received any IPv4 allocations or assignments from ARIN (through ordinary allocations or assignments, or through this Simple Transfer policy) within the preceding 24 months. ? The transferor may not request any IPv4 allocations or assignments from ARIN (through ordinary allocations or assignments, or through this Simple Transfer policy) within the subsequent 24 months. 8.3.2 Conditions on the transferee (the organization receiving the transferred addresses): ? The transferee resides in the ARIN service area and intends to use the transferred IPv4 addresses within the ARIN service area. ? The transferee has no outstanding balances with ARIN. ? The transferee?s need is confirmed by ARIN, according to current ARIN policies, including but not limited to confirmation of utilization rate of any prior IPv4 allocations, assignments, or previously transferred IPv4 addresses held by the transferee. ? The transferee signs (or has previously signed) an RSA covering the IPv4 addresses transferred. ? The transferee has not provided any IPv4 addresses for transfer through this Simple Transfer process within the preceding 24 months. ? The transferee may not provide any IPv4 addresses for transfer through this Simple Transfer process within the subsequent 24 months, except in the case of business failure. ? The transferee may request and receive a contiguous CIDR block large enough to provide a 12 month supply of IPv4 addresses. ? The transferee may only receive one IPv4 address transfer through this Simple Transfer process every 6 months. 8.3.3 Conditions on the IPv4 address block to be transferred: ? The IPv4 block must comply with applicable ARIN requirements, including minimum allocation size (i.e. NRPM 4.2.2., 4.2.4., 4.3.2., 4.3.6.). However, an IPv4 allocation or assignment of /24 or larger, but smaller than the current minimum allocation size, may be transferred as a whole resource, but may not be subdivided. ? The IPv4 block must currently be registered for use within the ARIN service area, either as part of an address block assigned by IANA to ARIN, or as part of a legacy address block allocated within the ARIN service area. ? There must exist no dispute as to the status of the IPv4 block or regarding the allocation or assignment of such block to the transferor. ? The transferor may retain one contiguous address range out of their original allocation or assignment for their own use, and transfer the other contiguous address range. If the address range to be transferred consists of multiple non-aggregatable CIDR blocks, each may be transferred to a different transferee. The retained address range may not be further subdivided or transferred for a period of 12 months. Notwithstanding the preceding, the block may be subdivided as provided in section 8.3.6. 8.3.4 Fees ? Completion of a transfer requires payment of a transfer fee according to ARIN?s schedule of fees. ? The transferee will be subject to all future ARIN membership and service fees according to the transferee?s total address holdings. 8.3.5 Pre-qualification ? An interested transferee must seek pre-qualification from ARIN to confirm its eligibility to receive a transfer (including satisfaction of need according to current ARIN policies) before making any solicitation for transfer. Upon pre-qualification, ARIN will provide the transferee with documentation of the pre-qualification, including the size (CIDR prefix length) of the largest IPv4 address block the transferee is eligible to receive, and the expiration date of the pre-qualification. ? An interested transferor must seek pre-qualification from ARIN to confirm its eligibility to offer a transfer (including lack of outstanding balances and having signed an RSA) before offering IPv4 address resources for transfer. Upon pre-qualification, ARIN will provide the transferor with documentation of the pre-qualification, including the network block and the expiration date of the pre-qualification. 8.3.6 Deaggregation when Permitted by ARIN If ARIN determines that there is an inadequate supply of small blocks, ARIN may allow transferors to subdivide network blocks beyond the limited subdivision permitted under 8.3.3. ARIN will attempt to ensure an adequate supply of small blocks while minimizing deaggregation. 8.3.7. Safe Harbor for IPv4 Transfers through this Simple Transfer Process When an IPv4 address resource is made available for transfer, it shall be deemed exempt from ARIN utilization audit until 90 days after its transfer pre-qualification or until the transfer is completed, whichever comes first. In the event that a transfer is not consummated within the prequalification time period, the block may be immediately re-prequalified for transfer. Notwithstanding the current offered state of the address resource, however, the audit exemption period shall expire untolled 90 days after the expiration of the first pre-qualification period. After the expiration of any utilization audit exemption period, ARIN shall have 90 days in which to initiate a utilization audit. In no event shall non-exempt time be construed to extend the end of the next exemption period. 8.3.8. Simple IPv4 Transfers to or from Organizations Under Common Ownership or Control If an IPv4 transferor or transferee is under common ownership or control with any other organization that holds one or more IPv4 blocks, the IPv4 transfer request must report all such organizations under common ownership or control. When evaluating compliance with IPv4 Simple Transfer conditions, ARIN may consider a transferor?s transfer request in light of requests from other organizations under common ownership or control with the transferor. Similarly, ARIN may consider a transferee?s request in light of requests from other organizations under common ownership or control with the transferee. In evaluating requests from other organizations under common ownership or control, ARIN staff will consider the relationship between the organizations, the degree of coordination between the organizations, and the bona fide use of the addresses at issue to determine whether all appropriate conditions are met. 8.3.9. Record-keeping and Publication of Simple Transfers of IPv4 Addresses ARIN will develop and operate a listing service to assist interested transferors and transferees by providing them a centralized location to post information about IPv4 blocks available from prequalified transferors and IPv4 blocks needed by prequalified transferees. Participation in the listing service is voluntary. After completion of the transfer, ARIN will update the registration records pertaining to the IPv4 block at issue. ARIN will adjust its records as to the holdings of the transferor and transferee. After the transfer, ARIN will publish WHOIS data that reflects the current allocation or assignment of the transferred block. ARIN will also make available information about any prior recipient(s) of such block. ARIN will also publish a log of all transfers, including block, transferor, transferee, and date. Rationale: The ARIN Board of Trustees asked the Advisory Council to consider a set of questions around the depletion of the free pool of IPv4 addresses, the transition to IPv6 for Internet address needs in the future, and ARIN's possible role in easing the transition. Over the past few years the AC has spent a great deal of time reflecting on these issues ? as a group, as individuals, and in consultation with the community. One outcome of this process is this policy proposal, which the AC is submitting for consideration at the next meeting. We are proposing some changes to existing ARIN policy regarding the transfer of IP address block registrations between subscribers, which will allow for the emergence of trade in IPv4 address space, with ARIN to provide a listing service for address blocks available for transfer under the liberalized policy. We are aware that this proposal, if adopted, will mark a major change in ARIN's role in the community and the Internet. This policy proposal would create a transfer mechanism for IPv4 number resources between those who have excess resources and those who have a need, thereby allowing ARIN to continue to serve its mission after IANA free pool exhaustion. This proposal would also set conditions on such transfers intended to preserve as much as possible the existing policy related to efficient, needs-based resource issuance, and would leverage ARIN's extensive control systems, audit trails, and recognized position as a trusted agent to avoid speculation and hoarding and diminish the likelihood and extent of an uncontrolled 'black market' where the risk and potential for fraud is immeasurably higher. Many of the transfer conditions are self-explanatory, but some worth highlighting are that: ? To discourage speculation, a waiting period (proposed at 24 months) is required before a transferee (or ordinary resource recipient) can become a transferor, or vice versa. ? Transferees must qualify for IPv4 space (just as they do today when getting it from ARIN) before they can receive address space by transfer, or solicit space on a listing service. ? To discourage unnecessarily rapid growth of routing tables, an allocation or assignment may not be arbitrarily deaggregated. To allow a transferor to downsize within their existing space, they may split off a contiguous address range, once every 12 months, and transfer the resulting netblock(s), which are subject to ARIN?s minimum allocation size, to one or more transferee(s). ? A transferee may receive one transfer every 6 months, so they?ll be incented to transfer a block appropriately sized for their needs, which will further discourage deaggregation and keep smaller blocks available for smaller organizations. The proposal would also have ARIN develop and operate a listing service to facilitate transfers and provide an authoritative central source of information on space available and requested for transfer. It would not prohibit private party transactions, but would require that potential transferors and transferees be pre-qualified first, so that neither party will encounter any unexpected surprises when they ask ARIN to process the transfer. Timetable for implementation: Immediately, with most aspects of policy taking effect upon IANA exhaustion, per the policy text. From info at arin.net Tue Mar 11 11:44:18 2008 From: info at arin.net (Member Services) Date: Tue, 11 Mar 2008 11:44:18 -0400 Subject: Policy Proposal 2007-21: PIv6 for legacy holders with RSA and efficient use - Revised Text Message-ID: <47D6A8D2.50405@arin.net> Policy Proposal 2007-21, PIv6 for legacy holders with RSA and efficient use, has been revised. After ARIN XX this proposal was remanded to the ARIN Advisory Council by the ARIN Board of Trustees. The AC asked the author to revise the text and present the propsal again. The proposal is open for discussion on this mailing list and is on the agenda at the upcoming Public Policy Meeting in Denver. The current policy proposal text is provided below and is also available at: http://www.arin.net/policy/proposals/2007_21.html Regards, Member Services American Registry for Internet Numbers (ARIN) ### * ### Policy Proposal 2007-21 PIv6 for legacy holders with RSA and efficient use Author: Scott Leibrand Proposal Version: 2.0 Date: 11 March 2008 Proposal type: modify Policy term: permanent Policy statement: Modify NRPM section 6.5.8.1 (Direct assignments from ARIN to end-user organizations: Criteria), to read: To qualify for a direct assignment, an organization must: 1. not be an IPv6 LIR; and 2. qualify for an IPv4 assignment or allocation from ARIN under the IPv4 policy currently in effect, or demonstrate efficient utilization of all direct IPv4 assignments and allocations, each of which must be covered by a current ARIN RSA. Rationale: Current policy allows direct IPv6 allocations and assignments to nearly all organizations with IPv4 allocations or assignments from ARIN. As a result, such organizations can get IPv6 space just as easily as they can get IPv4 space, making it easy for them to transition to IPv6 as soon as they're ready to do so. However, there are some organizations who received IPv4 /23's and /24's prior to the formation of ARIN, and use that space in a multihomed, provider-independent fashion. Under current policy, such organizations cannot get IPv6 PI space without artificially inflating host counts, and are therefore discouraged from adopting IPv6. This policy proposal aims to remove this disincentive, and allow such organizations to easily adopt IPv6. In addition, pre-ARIN assignments were issued through an informal process, and many legacy resource holders have not yet entered into a formal agreement with ARIN, the manager of many such IP numbering resources. This policy proposal would require that such assignments be brought under a current ARIN Registration Services Agreement, thereby formalizing the relationship. Some pre-ARIN assignments may not be used efficiently. As unallocated IPv4 numbering resources are approaching exhaustion, it is important to ensure efficient utilization of IPv4 assignments, and to arrange for reclamation of unused space. Therefore, this policy would require that the organization wishing to receive IPv6 PI space demonstrate efficient utilization of their IPv4 assignment. (Efficient utilization is already defined elsewhere in policy, and the exact mechanism for achieving and determining efficient use is a matter of procedure, not of policy, so detailed procedures are not included in the policy statement above. The intent is that any organization with an assignment of /23 or larger which is less than 50% utilized would renumber and return whole unused CIDR blocks as necessary to bring the remaining CIDR block to 50% utilization or higher. A /24 should be considered efficiently utilized as long as it is in use for multihoming, as /25's and smaller are not routable for that purpose.) It has been suggested that this policy would be useful only until the growth of IPv6 exceeds the growth of IPv4. I would agree with this, and would further posit that the existing "qualify ... under the IPv4 policy currently in effect" language should also be modified at that time. I have therefore proposed this policy with a policy term of "permanent", with the expectation that this section of policy (6.5.8.1) will be rewritten at the appropriate time to entirely remove all IPv4 dependencies. Timetable for implementation: immediate From info at arin.net Tue Mar 11 12:31:01 2008 From: info at arin.net (Member Services) Date: Tue, 11 Mar 2008 12:31:01 -0400 Subject: ARIN XXI - Policy Proposals and Draft Agenda Message-ID: <47D6B3C5.7030601@arin.net> The following policy proposals have been under discussion on the ARIN Public Policy Mailing List and will be presented for consideration at the upcoming ARIN XXI Public Policy Meeting in Denver on 7-8 April 2008. 2008-3: Community Networks IPv6 Allocation 2008-2: IPv4 Transfer Policy Proposal 2008-1: SWIP support for smaller than /29 assignments 2007-27: Cooperative distribution of the end of the IPv4 free pool 2007-23: End Policy for IANA IPv4 allocations to RIRs 2007-21: PIv6 for legacy holders with RSA and efficient use 2007-17: Legacy Outreach and Partial Reclamation 2007-14: Resource Review Process The full text for each proposal can be found at: http://www.arin.net/policy/proposal_archive.html Agenda information has been updated. Find the draft agenda as well as hotel information at: http://www.arin.net/ARIN-XXI/ ARIN XXI attendees are eligible for a special room rate of $189 (USD), based on availability, if reservations are made before THIS Friday, 14 March. So make your hotel reservation and register for the meeting today! Regards, Member Services American Registry for Internet Numbers (ARIN) From info at arin.net Tue Mar 18 10:45:09 2008 From: info at arin.net (Member Services) Date: Tue, 18 Mar 2008 10:45:09 -0400 Subject: ARIN XXI Remote Participation and Webcast Message-ID: <47DFD575.2070207@arin.net> Are you unable to join us in Denver for ARIN XXI? We have a solution! To facilitate community participation, ARIN offers free remote participation to any individual. Registered remote participants may post questions or comments, via e-mail, which will be moderated and presented during normal question and answer periods throughout the agenda. All ARIN XXI activities involving public participation and comment, including the Sunday sessions on the Legacy RSA, Introduction to IRPEP and the Open Policy Hour, as well as the ARIN Public Policy and Members Meetings will be webcast, but only remote registrants will be able to submit questions and comments. All remote participants are subject to the Remote Participation Acceptable Use Policy (AUP). Registration for remote participation is available through our online meeting registration system. To register, please visit the ARIN XXI home page: http://www.arin.net/ARIN-XXI/, click the "Register for the Meeting" button at the top of the page, choose "ARIN XXI Remote Participant" from the drop-down box, and complete the subsequent form. The live meeting webcast is available without registering as a remote participant. Additional information about remote participation and the webcast, including the Remote Participation AUP, is available at: http://www.arin.net/ARIN-XXI/webcast.html Webcast access details will be posted through the link above before the meeting. The webcast will begin Sunday, 6 April 2008 at 3:00 PM MDT (UTC/GMT -6 hours). Regards, Member Services American Registry for Internet Numbers (ARIN) From info at arin.net Fri Mar 21 14:46:13 2008 From: info at arin.net (Member Services) Date: Fri, 21 Mar 2008 14:46:13 -0400 Subject: Policy Proposal 2008-2 - Staff Assessment Message-ID: <47E40275.3000601@arin.net> Policy Proposal 2008-2 Title: IPv4 Transfer Policy (authors ARIN AC) Revision Submitted: Mar 7, 2008 Date of Assessment: March 21, 2008 ARIN Staff Assessment The assessment of this proposal includes comments from ARIN staff and the ARIN General Counsel. It contains analysis of procedural, legal, and resource concerns regarding the implementation of this policy proposal as it is currently stated. Any changes to the language of the proposal may necessitate further analysis by staff and Counsel. I. Proposal Policy Proposal is available as Annex A below and at: http://www.arin.net/policy/proposals/2008_2.html II. Understanding of the proposal: ARIN staff understands that this proposal introduces a new set of criteria to justify transfers of the available IANA IPv4 unicast address pool following the depletion of this space. Specifically, the existing Transfer Policy sections are consolidated from three sections to two (8.1 and 8.2) and a new section 8.3 is added that defines criteria for ?Simple Transfers?, which allow an organization with excess IPv4 addresses to transfer those addresses to an organization with a need for additional IPv4 addresses, and creates a listing service to bring the two parties together. III. Issues and Concerns A. ARIN Staff Comments: 8.0 Transfers General Observations ? Policy language and stated criteria are generally broad and subjective (most criteria contain words like ?may? and ?should? vs concrete words like ?will? and ?must?). This leads requestors to believe that they are not obligated to provide documentation and justification for their transfer. The author should consider using a reference such as RFC 2119 to define how these words are generally interpreted. 8.1 Transfers ? This policy does not cover those Internet Number Resources that are neither covered the ARIN Registration Services Agreement or the ARIN Legacy Registration Services Agreement. ? The stated purpose for the original allocation may be difficult for an organization to provide given the requester may not be the original holder of the number resources. ? It is unclear from the text whether all resources being transferred have to be re-justified according to current ARIN policy. 8.2 Transfers as an Artifact of Change in Resource Holder Ownership It is difficult if not impossible for a new requestor to provide ?evidence that the new entity has acquired the assets which had, as of the date of the acquisition or proposed reorganization, justified the current entity's use of the number resource." Again, the requestor may not be the original holder of the number resources. 8.2.1 Documentation Requirements ? It maybe difficult for some requestors to obtain the legal instrument that effected the transfer ? Legal documents may be unavailable, particularly when the transactions occurred years before ? Transactions between small private entities are often difficult to authenticate or verify due to lack of support documentation. Some are based on an anecdotal ?gentleman?s agreement. ? Legal documents are often difficult to authenticate because parties to maybe unreachable. 8.3. Simple Transfer of IPv4 Addresses ? 8.3.2 "business failure" is a nebulous term and could represent an avenue of abuse. Staff recommends removal of this term from the policy text. ? 8.3.6 puts a great deal of responsibility into ARIN staff hands to control the supply in the listing service. This will require a significant amount of work to develop procedures, communication practices, and staff training. This will take approximately 3 to 6 months for this to occur. ? 8.3.7 provides for an audit exemption. Under the current RSA, ARIN has the right to audit a block at any given time. B. ARIN General Counsel This policy is a major departure from existing ARIN policy which has generally prohibited transfers except in specific, limited circumstances. We therefore address the overall intent of the policy from a legal perspective. No matter what policy ARIN implements, it seems likely that there will be more disputes, and hence more legal risk, once ARIN can no longer satisfy requests for v4 resources. But if ARIN attempted to continue its existing policy to prohibit most transfers, counsel anticipates that widespread transfers would nonetheless occur -- imposing significant future legal costs including the costs of investigation, arbitration, and litigation. By providing a realistic mechanism for transfers to occur, a broader and more permissive transfer policy would likely relieve ARIN of many such costs. We therefore consider risks under the proposed policy compared to the risks of retaining the current policy. We now turn to more specific concerns. The first legal concern in evaluating the specifics of any transfer policy is whether it is consistent with antitrust law. Currently, this policy does not create concerns. By creating a white market for transfer of v4 resources, the policy arguably advances competition. Second, a serious risk implicit in the creation of a transfer policy is that it will lead to additional litigation if ARIN, for example, refuses to permit a transfer it finds inconsistent with any policy eventually adopted. However, we believe this risk is adequately managed in the current draft, particularly because concern over this issue must be seen the context of the likelihood of expensive litigation to enforce the current policy if a new transfer policy is not adopted in some form. Third, the new policy will have to be carefully reviewed to ensure it supports to the legal theory of the Internet community that numbers are not "owned." In particular, ARIN will continue to claim that it does not grant "ownership," and that what is being transferred is the right to make beneficial use of number resources consistent with applicable policy. Poorly drafted transfer policies could undercut this current clear understanding. However, we currently have no serious concerns about the language of this proposal. IV. Resource Impact ? Moderate The resource impact of implementing this policy is moderate. Barring any unforeseen resource requirements, this policy could be implemented within 180 days from the date of the ratification of the policy by the ARIN Board of Trustees. It will require the following: ? Updates to guidelines will be required ? Staff training will be required ? A new template will be required ? Software will be needed ? New hardware may be required ? Details of the systems to implement the request, pre-qualification certification, transfer and listing service would need to be identified. This would require additional information about the form of the document to certify the pre-qualification and the mechanism and access restrictions for the listing service. Respectfully submitted, Member Services American Registry for Internet Numbers (ARIN) #### Annex A Policy Proposal 2008-2 IPv4 Transfer Policy Proposal Author: ARIN Advisory Council Proposal Version: 1.1 Date: 7 March 2008 Proposal type: modify Policy term: permanent Policy statement: Replace the current NRPM section 8 with the following -- 8. Transfers [8.1. Transfers ? retain as is: Number resources are non-transferable and are not assignable to any other organization unless ARIN has expressly and in writing approved a request for transfer. ARIN is tasked with making prudent decisions on whether to approve the transfer of number resources. It should be understood that number resources are not "sold" under ARIN administration. Rather, number resources are assigned to an organization for its exclusive use for the purpose stated in the request, provided the terms of the Registration Services Agreement continue to be met and the stated purpose for the number resources remains the same. Number resources are administered and assigned according to ARIN's published policies. Number resources are issued, based on justified need, to organizations, not to individuals representing those organizations. Thus, if a company goes out of business, regardless of the reason, the point of contact (POC) listed for the number resource does not have the authority to sell, transfer, assign, or give the number resource to any other person or organization. The POC must notify ARIN if a business fails so the assigned number resources can be returned to the available pool of number resources if a transfer is not requested and justified.] [8.2 ? remove the word ?only?, and retitle to ?Transfers as an Artifact of Change in Resource Holder Ownership?: 8.2. Transfers as an Artifact of Change in Resource Holder Ownership ARIN will consider requests for the transfer of number resources upon receipt of evidence that the new entity has acquired the assets which had, as of the date of the acquisition or proposed reorganization, justified the current entity's use of the number resource. Examples of assets that justify use of the number resource include, but are not limited to: ? Existing customer base ? Qualified hardware inventory ? Specific software requirements.] [Renumber existing 8.3 to 8.2.1 and retitle to ?Documentation Requirements for Transfers as an Artifact of Change in Resource Holder Ownership?: 8.2.1. Documentation Requirements for Transfers as an Artifact of Change in Resource Holder Ownership In evaluating a request for transfer, ARIN may require the requesting organization to provide any of the following documents, as applicable, plus any other documents deemed appropriate: ? An authenticated copy of the instrument(s) effecting the transfer of assets, e.g., bill of sale, certificate of merger, contract, deed, or court decree ? A detailed inventory of all assets utilized by the requesting party in maintaining and using the number resource ? A list of the requesting party's customers using the number resource. If further justification is required, the requesting party may be asked to provide any of the following, or other supporting documentation, as applicable: ? A general listing of the assets or components acquired ? A specific description of acquisitions, including: o Type and quantity of equipment o Customer base ? A description of how number resources are being utilized ? Network engineering plans, including: o Host counts o Subnet masking o Network diagrams o Reassignments to customers] 8.3. Simple Transfer of IPv4 Addresses After the exhaustion of the IANA IPv4 free pool (when IANA allocates its last unallocated unicast IPv4 address block), ARIN will also process IPv4 address transfer requests subject to the following conditions. These conditions apply only to Simple IPv4 transfers, not to transfers performed according to section 8.2. 8.3.1 Conditions on the transferor (the organization providing addresses for transfer): ? The transferor resides in the ARIN service area. ? The transferor has signed an RSA and/or a legacy RSA covering the IPv4 addresses transferred. ? The transferor has no outstanding balances with ARIN. ? The transferor has not received any IPv4 allocations or assignments from ARIN (through ordinary allocations or assignments, or through this Simple Transfer policy) within the preceding 24 months. ? The transferor may not request any IPv4 allocations or assignments from ARIN (through ordinary allocations or assignments, or through this Simple Transfer policy) within the subsequent 24 months. 8.3.2 Conditions on the transferee (the organization receiving the transferred addresses): ? The transferee resides in the ARIN service area and intends to use the transferred IPv4 addresses within the ARIN service area. ? The transferee has no outstanding balances with ARIN. ? The transferee?s need is confirmed by ARIN, according to current ARIN policies, including but not limited to confirmation of utilization rate of any prior IPv4 allocations, assignments, or previously transferred IPv4 addresses held by the transferee. ? The transferee signs (or has previously signed) an RSA covering the IPv4 addresses transferred. ? The transferee has not provided any IPv4 addresses for transfer through this Simple Transfer process within the preceding 24 months. ? The transferee may not provide any IPv4 addresses for transfer through this Simple Transfer process within the subsequent 24 months, except in the case of business failure. ? The transferee may request and receive a contiguous CIDR block large enough to provide a 12 month supply of IPv4 addresses. ? The transferee may only receive one IPv4 address transfer through this Simple Transfer process every 6 months. 8.3.3 Conditions on the IPv4 address block to be transferred: ? The IPv4 block must comply with applicable ARIN requirements, including minimum allocation size (i.e. NRPM 4.2.2., 4.2.4., 4.3.2., 4.3.6.). However, an IPv4 allocation or assignment of /24 or larger, but smaller than the current minimum allocation size, may be transferred as a whole resource, but may not be subdivided. ? The IPv4 block must currently be registered for use within the ARIN service area, either as part of an address block assigned by IANA to ARIN, or as part of a legacy address block allocated within the ARIN service area. ? There must exist no dispute as to the status of the IPv4 block or regarding the allocation or assignment of such block to the transferor. ? The transferor may retain one contiguous address range out of their original allocation or assignment for their own use, and transfer the other contiguous address range. If the address range to be transferred consists of multiple non-aggregatable CIDR blocks, each may be transferred to a different transferee. The retained address range may not be further subdivided or transferred for a period of 12 months. Notwithstanding the preceding, the block may be subdivided as provided in section 8.3.6. 8.3.4 Fees ? Completion of a transfer requires payment of a transfer fee according to ARIN?s schedule of fees. ? The transferee will be subject to all future ARIN membership and service fees according to the transferee?s total address holdings. 8.3.5 Pre-qualification ? An interested transferee must seek pre-qualification from ARIN to confirm its eligibility to receive a transfer (including satisfaction of need according to current ARIN policies) before making any solicitation for transfer. Upon pre-qualification, ARIN will provide the transferee with documentation of the pre-qualification, including the size (CIDR prefix length) of the largest IPv4 address block the transferee is eligible to receive, and the expiration date of the pre-qualification. ? An interested transferor must seek pre-qualification from ARIN to confirm its eligibility to offer a transfer (including lack of outstanding balances and having signed an RSA) before offering IPv4 address resources for transfer. Upon pre-qualification, ARIN will provide the transferor with documentation of the pre-qualification, including the network block and the expiration date of the pre-qualification. 8.3.6 Deaggregation when Permitted by ARIN If ARIN determines that there is an inadequate supply of small blocks, ARIN may allow transferors to subdivide network blocks beyond the limited subdivision permitted under 8.3.3. ARIN will attempt to ensure an adequate supply of small blocks while minimizing deaggregation. 8.3.7. Safe Harbor for IPv4 Transfers through this Simple Transfer Process When an IPv4 address resource is made available for transfer, it shall be deemed exempt from ARIN utilization audit until 90 days after its transfer pre-qualification or until the transfer is completed, whichever comes first. In the event that a transfer is not consummated within the prequalification time period, the block may be immediately re-prequalified for transfer. Notwithstanding the current offered state of the address resource, however, the audit exemption period shall expire untolled 90 days after the expiration of the first pre-qualification period. After the expiration of any utilization audit exemption period, ARIN shall have 90 days in which to initiate a utilization audit. In no event shall non-exempt time be construed to extend the end of the next exemption period. 8.3.8. Simple IPv4 Transfers to or from Organizations Under Common Ownership or Control If an IPv4 transferor or transferee is under common ownership or control with any other organization that holds one or more IPv4 blocks, the IPv4 transfer request must report all such organizations under common ownership or control. When evaluating compliance with IPv4 Simple Transfer conditions, ARIN may consider a transferor?s transfer request in light of requests from other organizations under common ownership or control with the transferor. Similarly, ARIN may consider a transferee?s request in light of requests from other organizations under common ownership or control with the transferee. In evaluating requests from other organizations under common ownership or control, ARIN staff will consider the relationship between the organizations, the degree of coordination between the organizations, and the bona fide use of the addresses at issue to determine whether all appropriate conditions are met. 8.3.9. Record-keeping and Publication of Simple Transfers of IPv4 Addresses ARIN will develop and operate a listing service to assist interested transferors and transferees by providing them a centralized location to post information about IPv4 blocks available from prequalified transferors and IPv4 blocks needed by prequalified transferees. Participation in the listing service is voluntary. After completion of the transfer, ARIN will update the registration records pertaining to the IPv4 block at issue. ARIN will adjust its records as to the holdings of the transferor and transferee. After the transfer, ARIN will publish WHOIS data that reflects the current allocation or assignment of the transferred block. ARIN will also make available information about any prior recipient(s) of such block. ARIN will also publish a log of all transfers, including block, transferor, transferee, and date. Rationale: The ARIN Board of Trustees asked the Advisory Council to consider a set of questions around the depletion of the free pool of IPv4 addresses, the transition to IPv6 for Internet address needs in the future, and ARIN's possible role in easing the transition. Over the past few years the AC has spent a great deal of time reflecting on these issues ? as a group, as individuals, and in consultation with the community. One outcome of this process is this policy proposal, which the AC is submitting for consideration at the next meeting. We are proposing some changes to existing ARIN policy regarding the transfer of IP address block registrations between subscribers, which will allow for the emergence of trade in IPv4 address space, with ARIN to provide a listing service for address blocks available for transfer under the liberalized policy. We are aware that this proposal, if adopted, will mark a major change in ARIN's role in the community and the Internet. This policy proposal would create a transfer mechanism for IPv4 number resources between those who have excess resources and those who have a need, thereby allowing ARIN to continue to serve its mission after IANA free pool exhaustion. This proposal would also set conditions on such transfers intended to preserve as much as possible the existing policy related to efficient, needs-based resource issuance, and would leverage ARIN's extensive control systems, audit trails, and recognized position as a trusted agent to avoid speculation and hoarding and diminish the likelihood and extent of an uncontrolled 'black market' where the risk and potential for fraud is immeasurably higher. Many of the transfer conditions are self-explanatory, but some worth highlighting are that: ? To discourage speculation, a waiting period (proposed at 24 months) is required before a transferee (or ordinary resource recipient) can become a transferor, or vice versa. ? Transferees must qualify for IPv4 space (just as they do today when getting it from ARIN) before they can receive address space by transfer, or solicit space on a listing service. ? To discourage unnecessarily rapid growth of routing tables, an allocation or assignment may not be arbitrarily deaggregated. To allow a transferor to downsize within their existing space, they may split off a contiguous address range, once every 12 months, and transfer the resulting netblock(s), which are subject to ARIN?s minimum allocation size, to one or more transferee(s). ? A transferee may receive one transfer every 6 months, so they?ll be incented to transfer a block appropriately sized for their needs, which will further discourage deaggregation and keep smaller blocks available for smaller organizations. The proposal would also have ARIN develop and operate a listing service to facilitate transfers and provide an authoritative central source of information on space available and requested for transfer. It would not prohibit private party transactions, but would require that potential transferors and transferees be pre-qualified first, so that neither party will encounter any unexpected surprises when they ask ARIN to process the transfer. Timetable for implementation: Immediately, with most aspects of policy taking effect upon IANA exhaustion, per the policy text. From info at arin.net Fri Mar 21 14:46:27 2008 From: info at arin.net (Member Services) Date: Fri, 21 Mar 2008 14:46:27 -0400 Subject: Policy Proposal 2008-1 - Staff Assessment Message-ID: <47E40283.6010707@arin.net> Policy Proposal 2008-1 Title: SWIP Support for smaller than /29 Assignments Proposal Submitted: Feb 26, 2008 Date of Assessment: Mar 21, 2008 ARIN Staff Assessment The assessment of this proposal includes comments from ARIN staff and the ARIN General Counsel. It contains analysis of procedural, legal, and resource concerns regarding the implementation of this policy proposal as it is currently stated. Any changes to the language of the proposal may necessitate further analysis by staff and Counsel. I. Proposal Policy Proposal is available as Annex A below and at: http://www.arin.net/policy/proposals/2008_1.html II. Understanding of the proposal Staff understands that this policy will allow upstream ISPs to report utilization to ARIN by submitting their customer and/or internal assignments of /29 or smaller via SWIP and RWHOIS server in addition to the current accepted method which is a flat file in the form of an excel spreadsheet of similar. This will allow customers to use SWIP or RWHOIS server as a single source for reporting their utilization data back to ARIN. III. Issues and concerns A. ARIN Staff Comments Staff foresees no problems with the implementation of this policy and no conflicts with current policy. B. ARIN General Counsel Counsel sees no significant legal or litigation issues related to this policy. IV. Resource Impact ? Minimal The resource impact of implementing this policy is minimal. Barring any unforeseen resource requirements, this policy could be implemented within 90 days from the date of the ratification of the policy by the ARIN Board of Trustees. It will require the following: ? Changes to the registration software to accept the submission of /29s and smaller via the various reassignment templates. ? Changes to Guidelines ? Minor template changes ? May increase RSD?s workload if an overwhelming number of people choose to swip allocations smaller than /29 ? Staff anticipates no major issues with Whois (performance, storage, gen, etc.) Respectfully submitted, Member Services American Registry for Internet Numbers (ARIN) ##*## Annex A Policy Proposal 2008-1 SWIP Support for smaller than /29 Assignments Author: Joe Maimon Proposal Version: 1 Submission Date: 26 February 2008 Proposal type: modify Policy term: permanent Policy statement: 4.2.2.1.2.) " ISPs must provide reassignment information on the entire previously allocated block(s) via SWIP or RWHOIS server for /29 or larger blocks. For blocks smaller than /29 and for internal space, ISPs should provide utilization data using the table format described in Section 4.2.3.7.5. " Replace with " ISPs must provide reassignment information on the entire previously allocated block(s) via SWIP or RWHOIS server for /29 or larger blocks. For blocks smaller than /29 and for internal space, ISPs should provide utilization data either via SWIP or RWHOIS server or by using the table format described in Section 4.2.3.7.5. " 4.2.2.2.1.) " Utilization for blocks smaller than /29 can be documented using the format described in Section 4.2.3.7.5. " Replace with " Utilization for blocks smaller than /29 can be documented via SWIP or RWHOIS server or by using the format described in Section 4.2.3.7.5. " 4.2.3.7.2.) " For blocks smaller than /29 and for internal space, ISPs should provide utilization data using the format described in Section 4.2.3.7.5. " Replace with " For blocks smaller than /29 and for internal space, ISPs should provide utilization data via SWIP or RWHOIS server or by using the format described in Section 4.2.3.7.5. " 4.2.3.7.5.) Accounting for additional utilization " The following format should be used to provide the required information for utilization of blocks smaller than /29 and for describing internal networks: " Replace with " The following format should be used to provide the required information for utilization of blocks smaller than /29 and for describing internal networks when either SWIP or RWHOIS server is not used: " Rationale: With increasing frequency of smaller than /29 assignements to customers, the ability for ISP's to utilize SWIP or RWHOIS as a single comprehensive source of their utilization data should be supported. To implement this policy change, ARIN SWIP would need to no longer reject SWIP templates smaller then /29. Timetable for implementation: Immediate From info at arin.net Fri Mar 21 14:47:08 2008 From: info at arin.net (Member Services) Date: Fri, 21 Mar 2008 14:47:08 -0400 Subject: Policy Proposal 2007-21 - Staff Assessment Message-ID: <47E402AC.3080009@arin.net> Policy Proposal 2007-21 Title: PIv6 for legacy holders with RSA and efficient use Revision Submitted: Mar 11, 2008 Date of Assessment: Mar 21, 2008 ARIN Staff Assessment The assessment of this proposal includes comments from ARIN staff and the ARIN General Counsel. It contains analysis of procedural, legal, and resource concerns regarding the implementation of this policy proposal as it is currently stated. Any changes to the language of the proposal may necessitate further analysis by staff and Counsel. I. Proposal Policy Proposal is available as Annex A below and at: http://www.arin.net/policy/proposals/2007_21.html II. Understanding of the proposal ARIN staff understands that this proposal would make direct assignments of IPv6 space available to any organization with an efficiently utilized v4 assignment or allocation covered under an RSA. III. Issues and concerns A. ARIN Staff ? General Comment The revised policy text is clear and could be implemented as written. B. ARIN General Counsel This policy does not create any significant legal or litigation concerns. IV. Resource Impact ? Minimal The resource impact of implementing this policy is viewed as minimum. Barring any unforeseen resource requirements, this policy could be implemented within 30 ? 90 days from the date of the ratification of the policy by the ARIN Board of Trustees. It will require the following: ? Updates to Guidelines will be required ? Staff training will be required ? New process to manually add RSA coverage will be required Respectfully submitted, Member Services American Registry for Internet Numbers (ARIN) ##*## Annex A Policy Proposal 2007-21 PIv6 for legacy holders with RSA and efficient use Author: Scott Leibrand Proposal Version: 2.0 Date: 11 March 2008 Proposal type: modify Policy term: permanent Policy statement: Modify NRPM section 6.5.8.1 (Direct assignments from ARIN to end-user organizations: Criteria), to read: To qualify for a direct assignment, an organization must: 1. not be an IPv6 LIR; and 2. qualify for an IPv4 assignment or allocation from ARIN under the IPv4 policy currently in effect, or demonstrate efficient utilization of all direct IPv4 assignments and allocations, each of which must be covered by a current ARIN RSA. Rationale: Current policy allows direct IPv6 allocations and assignments to nearly all organizations with IPv4 allocations or assignments from ARIN. As a result, such organizations can get IPv6 space just as easily as they can get IPv4 space, making it easy for them to transition to IPv6 as soon as they're ready to do so. However, there are some organizations who received IPv4 /23's and /24's prior to the formation of ARIN, and use that space in a multihomed, provider-independent fashion. Under current policy, such organizations cannot get IPv6 PI space without artificially inflating host counts, and are therefore discouraged from adopting IPv6. This policy proposal aims to remove this disincentive, and allow such organizations to easily adopt IPv6. In addition, pre-ARIN assignments were issued through an informal process, and many legacy resource holders have not yet entered into a formal agreement with ARIN, the manager of many such IP numbering resources. This policy proposal would require that such assignments be brought under a current ARIN Registration Services Agreement, thereby formalizing the relationship. Some pre-ARIN assignments may not be used efficiently. As unallocated IPv4 numbering resources are approaching exhaustion, it is important to ensure efficient utilization of IPv4 assignments, and to arrange for reclamation of unused space. Therefore, this policy would require that the organization wishing to receive IPv6 PI space demonstrate efficient utilization of their IPv4 assignment. (Efficient utilization is already defined elsewhere in policy, and the exact mechanism for achieving and determining efficient use is a matter of procedure, not of policy, so detailed procedures are not included in the policy statement above. The intent is that any organization with an assignment of /23 or larger which is less than 50% utilized would renumber and return whole unused CIDR blocks as necessary to bring the remaining CIDR block to 50% utilization or higher. A /24 should be considered efficiently utilized as long as it is in use for multihoming, as /25's and smaller are not routable for that purpose.) It has been suggested that this policy would be useful only until the growth of IPv6 exceeds the growth of IPv4. I would agree with this, and would further posit that the existing "qualify ... under the IPv4 policy currently in effect" language should also be modified at that time. I have therefore proposed this policy with a policy term of "permanent", with the expectation that this section of policy (6.5.8.1) will be rewritten at the appropriate time to entirely remove all IPv4 dependencies. Timetable for implementation: immediate From info at arin.net Fri Mar 21 14:47:38 2008 From: info at arin.net (Member Services) Date: Fri, 21 Mar 2008 14:47:38 -0400 Subject: Policy Proposal 2007-23 - Staff Assessment Message-ID: <47E402CA.6030308@arin.net> Policy Proposal 2007-23 (Global) Title: End Policy for IANA IPv4 allocations to RIRs Revision Submitted: Feb 8, 2008 Date of Assessment: Mar 21, 2008 ARIN Staff Assessment The assessment of this proposal includes comments from ARIN staff and the ARIN General Counsel. It contains analysis of procedural, legal, and resource concerns regarding the implementation of this policy proposal as it is currently stated. Any changes to the language of the proposal may necessitate further analysis by staff and Counsel. I. Proposal Policy Proposal is available as Annex A below and at: http://www.arin.net/policy/proposals/2007_23.html II. Understanding of the proposal ARIN staff understands that this policy would have IANA allocate a single /8 to each of the 5 RIRs ?at the point when the IANA free pool is more than 5 /8s, but too small to fulfill a request from an RIR without using part of the final 5 /8s? or the point of imminent exhaustion. III. Comments A. ARIN Staff 1. The policy conflicts with the spirit of RFC 2050 in which fairness and efficiency of allocation by IANA to the RIRs is cited. 2. Author did not indicate placement in the NRPM. It would go in to Section 10. B. ARIN General Counsel This policy presents no significant legal issues. It seeks to substitute a different mechanism than actual utilization to allocate the last 5 unallocated blocs of IPV4 resources, one each to each RIR. It might be arguably discriminatory against ARIN, or any other RIR which has a high 'burn rate' for a slash 8, compared to those RIRs with a slower burn rate; it also could be more discriminatory if the low burn rate RIR's are provided a slash 8 just before the trigger event and consequently end up with 2 slash 8's, with a lower burn rate. However, Counsel sees these as political/policy considerations and not legal issues. IV. Resource Impact ? Minimal The resource impact of implementing this policy is viewed as minimum. Barring any unforeseen resource requirements, this policy could be implemented within 30 -90 days from the date of the ratification of the policy by the ARIN Board of Trustees. It will require the following: ? Updates to Guidelines will be required ? Staff training will be required Respectfully submitted, Member Services American Registry for Internet Numbers (ARIN) ##*## Annex A Policy Proposal 2007-23 (Global) End Policy for IANA IPv4 allocations to RIRs Proposal Version: Version 2 Date: 8 February 2008 Author: Roque Gagliano, ANTEL; Francisco Obispo, CENIT; Haitham EL Nakhal, MCIT; Didier Allain Kla, ISOC Cote d'Ivoire; JPNIC IPv4 countdown policy team: - Akinori Maemura - Akira Nakagawa - Izumi Okutani - Kosuke Ito - Kuniaki Kondo - Shuji Nakamura - Susumu Sato - Takashi Arano - Tomohiro Fujisaki - Tomoya Yoshida - Toshiyuki Hosaka Proposal type: new Policy term: temporary Policy statement: This is a revised version of; prop-046: IPv4 countdown policy proposal prop-051: Global policy for the allocation of the remaining IPv4 address space This policy describes the process for the allocation of the remaining IPv4 space from IANA to the RIRs. When a minimum amount of available space is reached, one /8 will be allocated from IANA to each RIR, replacing the current IPv4 allocation policy. In order to fulfill the requirements of this policy, at the time it is adopted, one /8 will be reserved by IANA for each RIR. The reserved allocation units will no longer be part of the available space at the IANA pool. IANA will also reserve one /8 to any new RIR at the time it is recognized. The process for the allocation of the remaining IPv4 space is divided in two consecutive phases: 4.1. Existing Policy Phase: During this phase IANA will continue allocating IPv4 addresses to the RIRs using the existing allocation policy. This phase will continue until a request for IPv4 address space from any RIR to IANA either cannot be fulfilled with the remaining IPv4 space available at the IANA pool or can be fulfilled but leaving the IANA remaining IPv4 pool empty. This will be the last IPv4 address space request that IANA will accept from any RIR. At this point the next phase of the process will be initiated. 4.2. Exhaustion Phase: IANA will automatically allocate the reserved IPv4 allocation units to each RIR (one /8 to each one) and respond to the last request with the remaining available allocation units at the IANA pool (M units). 4.2.1. Size of the final IPv4 allocations: During this phase IANA will automatically allocate one /8 to each RIR from the reserved space defined in this policy. IANA will also allocate M allocation units to the RIR that submitted the last request for IPv4 addresses. 4.2.2. Allocation of the remaining IPv4 Address space: After the completion of the evaluation of the final request for IPv4 addresses, IANA MUST: A) Immediately notify the NRO about the activation of the second phase of this policy. B) Proceed to allocate M allocation units to the RIR that submitted the last request for IPv4 address space. C) Proceed to allocate one /8 to each RIR from the reserved space. Rationale: The exhaustion of IPv4 address space is projected to take place within the next few years. This proposal seeks to focus on measures that should be taken globally in the address management area in order to prepare for the situation in all RIR regions. To continue applying a global coordinated policy for distribution of the last piece(s) of each RIR's unallocated address block does not match the reality of the situation in each RIR region. Issues each RIR region will face during the exhaustion period vary by region as the level of development of IPv4 and IPv6 are widely different. As a result, applying a global co-ordinated policy may not adequately address issues in a certain region while it could be work for the others. For example, in a region where late comers desperately need even small blocks of IPv4 addresses to access to the IPv4 Internet, a policy that defines the target of allocations/assignments of IPv4 address space to be late comers would be appropriate in such region. This would allow availablilty of IPv4 address space for such requirements for more years. Another example comes from difference in IPv6 deployment rate. For a region where IPv6 deployment rate is low, measures may be necessary to prolong IPv4 address life for the existing business as well as for new businesses until networks are IPv6 ready. Some regions may have strong needs to secure IPv4 address space for translators. A globally coordinated policy which addresses all the issues listed above to meet the needs for all RIR regions may result in not solving issues in any of the regions. Timetable for implementation: after approval by ICANN board From info at arin.net Fri Mar 21 14:48:01 2008 From: info at arin.net (Member Services) Date: Fri, 21 Mar 2008 14:48:01 -0400 Subject: Policy Proposal 2007-14 - Staff Assessment Message-ID: <47E402E1.6080903@arin.net> Policy Proposal 2007-14 Title: Resource Review Process Proposal Submitted: Feb 21, 2008 Date of Assessment: Mar 21, 2008 ARIN Staff Assessment The assessment of this proposal includes comments from ARIN staff and the ARIN General Counsel. It contains analysis of procedural, legal, and resource concerns regarding the implementation of this policy proposal as it is currently stated. Any changes to the language of the proposal may necessitate further analysis by staff and Counsel. I. Proposal Policy Proposal is available as Annex A below and at: http://www.arin.net/policy/proposals/2007_14.html II. Understanding of the proposal This policy proposal provides clear policy authority to audit or reclaim resources, guidelines for how it shall be done, and a guarantee of a (minimum) six-month grace period so that the current user shall have time to stop using any resources to be reclaimed. III. Comments A. ARIN Staff 1. 2c does not reconcile with the RSA, which grants ARIN authority to request any data necessary and does not specify any sort of limitation to frequency. 2. Item 3 requires staff to share the results of an audit of an organization?s resources. Staff often reviews an organization?s transaction history and resources during fraud or suspicious activity investigations and feels that it is not always prudent to share those results. 3. Point 4b uses the term ?single aggregate block? Does this refer to a single CIDR prefix, or to ?a contiguous range of addresses?? B. ARIN General Counsel This policy will be looked at very carefully in those instances where ARIN demands data, or seeks to terminate and revoke resources previously granted. It will guide ARIN, and any reviewing adjudication court who may be required to evaluate a dispute, review it because it sets up procedures for revocation, and requires production of data. Writing down such policies may be important support for ARIN's application of such policies. However, the same benefit can become a problem if the language is not carefully constructed. Counsel supports a version of this policy being enacted and believes adoption of this policy could reduce future legal fees. Some language tweaks may help. For this reason I am suggesting the author and AC consider language that tightens the policy from a legal perspective but is consistent with the perceived intent of the author. Some language changes are more important than others. Please note: Outlook doesn't permit redlining to show; it automatically accepts the redlined changes. Therefore, the redlines have been accepted in 1-8 below. 1. ARIN may review the current usage of any resources issued by ARIN to an organization. The organization shall furnish whatever records are believed to be necessary by ARIN to perform this review. 2. ARIN may conduct such reviews: a. when any new resource is requested, b. whenever ARIN has reason to believe that the resources originally were obtained fraudulently, or in contravention of existing policies, c. at any other time, without cause having to be established, unless a prior review has been completed in the preceding 24 months. 3. ARIN shall communicate the results of the review to the organization. 4. Organizations found by ARIN to be substantially out of compliance with current ARIN policy shall be requested or required to return resources to bring them into (or reasonably close to) compliance. 4a. The extent to which an organization may remain out of compliance shall be based on the reasonable judgment of the ARIN staff and shall balance all facts known, including the organizations utilization rate, available address pool, and other factors as appropriate so as to avoid forcing returns which will result in near-term additional requests or unnecessary route de- aggregation. 4b. To the extent possible, entire blocks should be returned. Partial address blocks shall be returned in such a way that the portion retained will comprise a single aggregate block. 5. If the organization does not voluntarily return resources as requested, ARIN may revoke any resources issued by ARIN as required to bring the organization into overall compliance. ARIN shall follow the same guidelines for revocation that are required for voluntary return in the previous paragraph. 6. Except in cases of fraud, or intentional violations of policy, an organization shall be provided a reasonable period of time to effect a return. ARIN shall agree to a longer term with the organization if ARIN believes the organization is working in good faith to restore compliance and has a valid need for additional time to renumber out of the affected blocks. 7. ARIN shall continue to maintain the resource(s) while their return or revocation is pending, except no new maintenance fees shall be assessed for the resource(s). (?) 8. Legacy resources in active use, regardless of utilization, are not subject to revocation by ARIN, pursuant to this subsection. However, the utilization of legacy resources shall be considered during a review to assess overall compliance. Counsel continues not to agree with the first sentence of the rationale which states ARIN "feels that current policy does not give them the power to review or reclaim resources except in cases of fraud...." Counsel requests this be rewritten to reflect that such powers need to be carefully delineated for application and ease of understanding. IV. Resource Impact ? Minimal The resource impact of implementing this policy is viewed as minimal. Barring any unforeseen resource requirements, this policy could be implemented within 30 ? 90 days from the date of the ratification of the policy by the ARIN Board of Trustees. Depending on the impact to RSD this may require additional staff. It will require the following: ? Guidelines Changes ? Registration System Changes ? Staff training ? May increase RSD workload ? May increase turnaround times Respectfully submitted, Member Services American Registry for Internet Numbers (ARIN) ##*## Annex A Policy Proposal 2007-14 Resource Review Process Author: Owen DeLong, Stephen Sprunk Date: 21 February 2008 Proposal type: modify Policy term: permanent Policy statement: Add the following to the NRPM: Resource Review 1. ARIN may review the current usage of any resources issued by ARIN to an organization. The organization shall furnish whatever records are necessary to perform this review. 2. ARIN may conduct such reviews: a. when any new resource is requested, b. whenever ARIN has cause to believe that the resources had originally been obtained fraudulently, or c. at any other time without cause unless a prior review has been completed in the preceding 24 months. 3. ARIN shall communicate the results of the review to the organization. 4. Organizations shown to be substantially out of compliance with current ARIN policy shall return resources as needed to bring them into (or reasonably close to) compliance. 4a. The extent to which an organization may remain out of compliance shall be based on the best judgment of the ARIN staff and shall balance the organizations utilization rate, available address pool, and other factors as appropriate so as to avoid forcing returns which will result in near-term additional requests or unnecessary route de- aggregation. 4b. To the extent possible, entire blocks should be returned. Partial address blocks shall be returned in such a way that the portion retained will comprise a single aggregate block. 5. If the organization does not voluntarily return resources as required, ARIN may revoke any resources issued by ARIN as required to bring the organization into overall compliance. ARIN shall follow the same guidelines for revocation that are required for voluntary return in the previous paragraph. 6. Except in cases of fraud, an organization shall be given a minimum of six months to effect a return. ARIN shall negotiate a longer term with the organization if ARIN believes the organization is working in good faith to substantially restore compliance and has a valid need for additional time to renumber out of the affected blocks. 7. ARIN shall continue to maintain the resource(s) while their return or revocation is pending, except no new maintenance fees shall be assessed for the resource(s). 8. Legacy resources in active use, regardless of utilization, are not subject to revocation by ARIN. However, the utilization of legacy resources shall be considered during a review to assess overall compliance. 9. In considering compliance with policies which allow a timeframe (such as a requirement to assign some number of prefixes within 5 years) failure to comply cannot be measured until after the timeframe specified in the applicable policy has elapsed. Blocks subject to such a policy shall be assumed in compliance with that policy until such time as the specified time since issuance has elapsed. Delete NRPM sections 4.1.2, 4.1.3, 4.1.4 Remove the sentence "In extreme cases, existing allocations may be affected." from NRPM section 4.2.3.1. Rationale: ARIN feels that current policy does not give them the power to review or reclaim resources except in cases of fraud, despite this being mentioned in the Registration Services Agreement. This policy proposal provides clear policy authority to do so, guidelines for how and under what conditions it shall be done, and a guarantee of a (minimum) six- month grace period so that the current user shall have time to renumber out of any resources to be reclaimed. The nature of the "review" is to be of the same form as is currently done when an organization requests new resources, i.e. the documentation required and standards should be the same. The intent of paragraph 2c is to prevent ARIN from doing more than one without-cause review in a 24 month period. The renumbering period does not affect any "hold" period that ARIN may apply after return or revocation of resources is complete. The deleted sections/text would be redundant with the adoption of this proposal. Timetable for implementation: Immediate From info at arin.net Fri Mar 21 14:48:14 2008 From: info at arin.net (Member Services) Date: Fri, 21 Mar 2008 14:48:14 -0400 Subject: Policy Proposal 2007-17 - Staff Assessment Message-ID: <47E402EE.20104@arin.net> Policy Proposal 2007-17 Title: Legacy Outreach and Partial Reclamation Date Submitted: Feb. 21, 2008 Date of Assessment: Mar 21, 2008 ARIN Staff Assessment The assessment of this proposal includes comments from ARIN staff and the ARIN General Counsel. It contains analysis of procedural, legal, and resource concerns regarding the implementation of this policy proposal as it is currently stated. Any changes to the language of the proposal may necessitate further analysis by staff and Counsel. I. Proposal Policy Proposal is available as Annex A below and at: http://www.arin.net/policy/proposals/2007_17.html The proposal was revised, current version dated 21 February 2008. II. Understanding of the proposal ARIN staff understands that this proposal would replace the existing amnesty policy in NRPM Section 4.6. III. Comments A. ARIN Staff 1. There is currently an amnesty policy (NRPM 4.6) and an aggregation policy (NRPM 4.7). Both policies contain clear and concise criteria and have been used successfully by the ARIN community since implementation. 2. This proposal seems to be combining both of these policies into one policy. If that is the case, it needs to explicitly state that. 3. The proposed policy text implies that ARIN will issue new addresses to organizations in exchange for returned addresses, but does not explicitly state that. 4. The proposed policy text removes the 12 month renumbering timeframe, creating significant abuse potential. Since there's no renumbering timeframe, nothing prevents the requestor from keeping both the smaller aggregates and the large aggregate indefinitely. 5. The proposed policy text requires ARIN to accept all amnesty or aggregation returns without prejudice, creating more avenues for abuse. For example, a spammer would be able to use this policy to repeatedly exchange blacklisted space for clean space. 6. If anyone is allowed to exchange their space without limitation, this could affect the remaining supply of IPv4 address space. B. ARIN General Counsel The policy creates no significant legal or litigation concerns. Comment for author or AC to consider, but not in a binding way: if ARIN label's some set of resources as in the control of someone 'unreachable' in whois, do we inadvertently encourage hijacking and spamming during the waiting period before revocation? The prior expressed concerns about binding board or inappropriately getting into fee setting of board have been addressed by changes. IV. Resource Impact ? Minimal The resource impact of implementing this policy is viewed as minimum. Barring any unforeseen resource requirements, this policy could be implemented within 30 - 90 days from the date of the ratification of the policy by the ARIN Board of Trustees. It will require the following: ? Updates to Registration Services Guidelines will be required ? Staff training will be required ? Tracking tools for the return of the space and for the yearly contact requirement Respectfully submitted, Member Services American Registry for Internet Numbers (ARIN) ##*## Annex A Policy Proposal 2007-17 Legacy Outreach and Partial Reclamation Author: Owen DeLong Date: 21 February 2008 Proposal type: modify Policy term: permanent Policy statement: Replace section 4.6 as follows: 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. 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 where possible. 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 greater 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 Incentives The Board of Trustees should consider creating incentives for organizations to return addresses under this policy. 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. Rationale: Existing policy supports aggregation (4.7) and provides some amnesty (existing 4.6) for returning blocks. However, a number of resource holders have expressed discomfort with the current section 4.6 believing that they will be forced to return their entire address space and renumber rather than being able to make partial returns and retain some of their existing space. This policy seeks to eliminate those concerns and make the return of unused address space more desirable to the resource holders. A very high percentage of underutilized space is in the hands of legacy holders who currently have no benefit to joining the ARIN process and no way to return any portion of their address space without incurring significant disadvantage as a result. A suggestion to the board would be to adopt benefits along the following lines for people returning space. These benefits would provide additional incentive for resource holders to make appropriate returns and for legacy holders to join the ARIN process: 1. If the organization does not currently pay ARIN fees, they shall remain fee exempt. 2. If the organization currently pays ARIN fees, their fees shall be waived for two years for each /20 returned, with any fractional /20 resulting in a one-time single year waiver. 3. Any organization returning address space under this policy shall continue under their existing RSA or they may choose to sign the current RSA. For organizations which currently do not have an RSA, they may sign the current RSA, or, they may choose to remain without an RSA. 4. All organizations returning space under this policy shall, if they meet other eligibility requirements and so request, obtain an appropriate IPv6 end-user assignment or ISP allocation as applicable, with no fees for the first 5 years. Organizations electing to receive IPv6 allocation/assignment under this provision must sign a current RSA and must agree that their IPv4 resources are henceforth subject to the RSA. Timetable for implementation: Immediate From info at arin.net Fri Mar 21 14:48:33 2008 From: info at arin.net (Member Services) Date: Fri, 21 Mar 2008 14:48:33 -0400 Subject: Policy Proposal 2007-27 - Staff Assessment Message-ID: <47E40301.9070405@arin.net> Policy Proposal 2007-27 Title: Cooperative distribution of the end of the IPv4 free pool Proposal Submitted: Nov 20, 2007 Date of Assessment: Mar 21, 2008 ARIN Staff Assessment The assessment of this proposal includes comments from ARIN staff and the ARIN General Counsel. It contains analysis of procedural, legal, and resource concerns regarding the implementation of this policy proposal as it is currently stated. Any changes to the language of the proposal may necessitate further analysis by staff and Counsel. I. Proposal Policy Proposal is available as Annex A below and at: http://www.arin.net/policy/proposals/2007_27.html II. Understanding of the proposal Staff understands that this policy will establish a mechanism for the allocation of IPv4 address blocks between RIR's once the IANA global pool of addresses has been depleted. III. Issues and concerns A. ARIN Staff 1. This policy would have to adopted as an Inter-RIR policy and would have to remain the same in each region for it to work properly. 2. There is no way of reliably predicting when an RIR is within 30 days of depleting their remaining pool of IPv4 addresses since this is dependent upon the number and size of the resource requests they receive. 3. This policy would require constant monitoring of the available IPv4 inventory of all the RIRs. To be timely, a software tool would need to be developed that monitored all RIR available IPv4 inventory and produced a daily report. This same tool would need to be used by all 5 of the RIRs for consistency and accuracy. 4. When the recipient RIR approaches the source RIR for a 3 month supply of addresses, will fees be charged to the recipient RIR? 5. It is likely that AfriNIC and LACNIC will be the two RIRs who typically would have the largest inventory of IPv4 at any given time since they currently allocate address space at a slow rate and in lessor amounts than the other three RIRs. If the three larger RIRs consistently approach them for address space, it is likely that their remaining supply will quickly dwindle. 6. If one RIR will be required to review requests from another region, all such requests must be made in an agreed upon common language. 7. Process and procedures training may be required for those parties making requests to an RIR in a region other than their own. 8. If the source RIR reviews and approves requests from the recipient RIR?s customers, there are likely to be business, legal, and other administrative issues that arise. For example: - Which RIR would the requestor pay? - In what currency would the fee paid? - Which RIR would have to report the registration fee as income? - Which RIR would the requestor sign a contract with? - Which RIR would maintain the record? - Will the requestor become a member of the source RIR and if so, will they be required to pay an annual fee to the source RIR? B. ARIN General Counsel Counsel sees no significant legal or litigation issues related to this policy. IV. Resource Impact ? Major The resource impact of implementing this policy is viewed as major. Barring any unforeseen resource requirements, this policy could be implemented within 180 days from the date of the ratification of the policy by the ARIN Board of Trustees. It would also be dependent upon the policy being adopted in all other RIRs. ? Tracking tool with built in metrics needed to attempt to estimate the 30 day depletion mark ? Survey needs to be created to ask other RIR to estimate their remaining available space ? Inter RIR coordination process needs to be established for this process of surveying and follow up actions. ? New guidelines ? Staff training Respectfully submitted, Member Services American Registry for Internet Numbers (ARIN) ##*## Annex A Policy Proposal 2007-27 Cooperative distribution of the end of the IPv4 free pool Author: Tony Hain Date: 20 November 2007 Proposal type: new Policy term: permanent Policy summary: This policy will establish a process for RIR-to-RIR redistribution of the tail-end of the IPv4 pool, taking effect after the IANA Reserve is exhausted. Each redistribution Allocation will be triggered by the recipient RIR depleting its reserve to a 30 day supply, and will result in up to a 3 month supply being transferred from the RIR with the longest remaining time before it exhausts its own pool. Policy statement: At the point when any given RIR is within 30 days of depleting its remaining IPv4 pool, a survey will be taken of the other 4 to determine the remaining time before each of them exhausts their pool (including both member use and recent redistribution allocations to other RIRs). The one with the longest window before exhausting its pool will be designated as the source RIR. The recipient RIR will follow procedures for an LIR in the source RIR region to request a block that is expected to be sufficient for up to 3 months, but is no larger than 1/8th of the source RIR's remaining pool. At the point where no RIR can supply a block that is less than 1/8th of their remaining pool that will sustain the recipient RIR for 30 days, the recipient RIR will collect its requests each week, and forward those individual requests to the source RIR designated that week. Rationale: This policy will establish a mechanism for the Allocation of IPv4 address blocks between RIR's, but will not go into effect until the IANA pool has been depleted. It is really bizarre to watch the maneuvering as the global RIR community grapples with 'fairness' of distributing the last few IANA Reserve /8 blocks. On one level this just appears to be petty sibling rivalry, as people are bickering over who gets the last cookie and whimpering about 'fairness'. At the same time, each RIR is chartered to look after the interests of its membership so it is to be expected that they will each want to get as much as possible to meet the needs of their respective membership. Existing practice requires RIR's to acquire blocks from IANA, which leads to the current round of nonsense about optimal distribution of the remaining pool based on elaborate mathematical models. This globally submitted policy proposal attempts to resolve the issue by shifting to an RIR-to-RIR Allocation model after the IANA pool is depleted. This policy would effectively result in each RIR becoming a virtual LIR member of all of the other RIR's for the sole purpose of managing the tail-end of the IPv4 pool. Timetable for implementation: Before 1/1/2009 From info at arin.net Mon Mar 24 11:13:57 2008 From: info at arin.net (Member Services) Date: Mon, 24 Mar 2008 11:13:57 -0400 Subject: [ppml] Revised 2007-14 In-Reply-To: <434C0D36-B948-4226-A5F4-37EFEE29B504@delong.com> References: <434C0D36-B948-4226-A5F4-37EFEE29B504@delong.com> Message-ID: <47E7C535.8070305@arin.net> Policy Proposal 2007-14: Resource Review Process has been revised. This proposal is open for discussion on this mailing list and will be on the agenda at the upcoming ARIN Public Policy Meeting. The current policy proposal text is provided below and is also available at: http://www.arin.net/policy/proposals/2007_14.html Regards, Member Services American Registry for Internet Numbers (ARIN) Owen DeLong wrote: > The following revisions to 2007-14 are being submitted in order > to address some concerns expressed to the authors by ARIN > counsel. The authors do not believe that these changes alter > the meaning or intent of the proposal. > > This is the version that will be presented at the Denver meeting. > > Version: 2.1 > Policy statement: > > Add the following to the NRPM: > > Resource Review > > 1. ARIN may review the current usage of any resources issued by ARIN > to an organization. The organization shall furnish whatever records > are believed to be necessary by ARIN to perform this review. > > 2. ARIN may conduct such reviews: > > a. when any new resource is requested, > b. whenever ARIN has reason to believe that the resources > were originally obtained fraudulently, or > c. at any other time without having to establish cause unless a > prior review has been completed in the preceding 24 months. > > 3. ARIN shall communicate the results of the review to the organization. > > 4. Organizations found by ARIN to be substantially out of compliance > with > current ARIN policy shall be requested or required to return resources > as > needed to bring them into (or reasonably close to) compliance. > > 4a. The extent to which an organization may remain out of compliance > shall be based on the reasonable judgment of the ARIN staff and shall > balance all facts known, including the organizations utilization rate, > available address pool, and other factors as appropriate so as to avoid > forcing returns which will result in near-term additional requests or > unnecessary route de-aggregation. > > 4b. To the extent possible, entire blocks should be returned. Partial > address blocks shall be returned in such a way that the portion > retained will comprise a single aggregate block. > > 5. If the organization does not voluntarily return resources as > requested, ARIN may revoke any resources issued by ARIN as required to > bring the organization into overall compliance. ARIN shall follow the > same guidelines for revocation that are required for voluntary return > in the previous paragraph. > > 6. Except in cases of fraud, or intentional violations of policy, an > organization shall be given a minimum of six months to effect a > return. ARIN shall negotiate a longer term with the organization > if ARIN believes the organization is working in good faith to > substantially > restore compliance and has a valid need for additional time to > renumber out of the affected blocks. > > 7. ARIN shall continue to maintain the resource(s) while their return > or revocation is pending, except no any maintenance fees assessed > during that period shall be calculated as if the return or revocation > was complete. > > 8. Legacy resources in active use, regardless of utilization, are not > subject to revocation by ARIN. pursuant to this subsection. However, > the utilization of legacy resources shall be considered during a > review to assess overall compliance. > > 9. In considering compliance with policies which allow a timeframe > (such as a requirement to assign some number of prefixes within 5 > years) failure to comply cannot be measured until after the timeframe > specified in the applicable policy has elapsed. Blocks subject to such > a policy shall be assumed in compliance with that policy until such > time as the specified time since issuance has elapsed. > > > > Delete NRPM sections 4.1.2, 4.1.3, 4.1.4 > > Remove the sentence "In extreme cases, existing allocations may be > affected." from NRPM section 4.2.3.1. > > Rationale: > > The authors have been told that current policy does not clearly give > ARIN the power to review or reclaim resources except in cases of > fraud, despite this being mentioned in the Registration Services > Agreement. This policy proposal provides clear policy authority to > do so, guidelines for how and under what conditions it shall be > done, and a guarantee of a (minimum) six- month grace period > so that the current user shall have time to renumber out of any > resources to be reclaimed. > > The nature of the "review" is to be of the same form as is currently > done when an organization requests new resources, i.e. the > documentation required and standards should be the same. > > The intent of paragraph 2c is to prevent ARIN from doing more than one > without-cause review in a 24 month period. > > The renumbering period does not affect any "hold" period that ARIN may > apply after return or revocation of resources is complete. > > The deleted sections/text would be redundant with the adoption of this > proposal. > > Timetable for implementation: Immediate > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to the ARIN Public Policy > Mailing List (PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/ppml > Please contact the ARIN Member Services Help Desk at info at arin.net if you experience any issues. > From info at arin.net Mon Mar 24 16:54:58 2008 From: info at arin.net (Member Services) Date: Mon, 24 Mar 2008 16:54:58 -0400 Subject: ARIN XXI - Open Policy Hour Message-ID: <47E81522.3080107@arin.net> Questions about the Policy Process: 1. Do you want to know what policy proposals will be discussed at the upcoming ARIN Public Policy Meeting? 2. Do you have an idea about how ARIN should manage Internet Number Resources? 3. Do you think that a current policy should be enhanced or changed, or even retired? 4. Are you hesitant about making a formal proposal on the Public Policy Mail List (PPML)? 5. Are you new to the Policy Development Process? If you answered ?yes? to any of these questions, then you should attend the Open Policy Hour! Come and get a better understanding of what will be discussed during the upcoming Public Policy Meeting, or discuss and receive feedback on your ideas in an open, informal forum. The Open Policy Hour consists of two parts. Part One is the Policy Proposal Background Briefing. ARIN staff will provide an overview of the policy proposals on the meeting agenda. Members of the ARIN Advisory Council will be present to answer general questions about these proposals. The proposal content will not be discussed. This session offers general information on the nature of the proposals. Part Two is the Policy Proposal BoF. This is where you can "test drive" a policy idea. How can you participate? Bring your ideas and questions. If you have a policy suggestion, but would like to receive feedback prior to submitting it to the community on the PPML, here is your opportunity. Preference will be given to individuals with prepared short (3-minute) presentations. To sign up in advance please send an e-mail to policy at arin.net by 2 April 2008 with your name, organization, and a brief description of your policy subject. Walk-up presenters are also welcome. Join your colleagues for this informal session. The Open Policy Hour for ARIN XXI will be held on Sunday, 6 April, from 4:30 - 5:30 PM. If you are not familiar with the way policies are developed in the ARIN region, join ARIN staff a half hour earlier, at 4:00 PM, for a review of the Internet Resource Policy Evaluation Process. Registration and hotel information for ARIN XXI is available at: http://www.arin.net/ARIN-XXI/ Contact Member Services at info at arin.net if you have any questions. Regards, Member Services American Registry for Internet Numbers (ARIN) From info at arin.net Tue Mar 25 10:11:03 2008 From: info at arin.net (Member Services) Date: Tue, 25 Mar 2008 10:11:03 -0400 Subject: ARIN XXI: Check Out The Agenda! Message-ID: <47E907F7.4000903@arin.net> We look forward to your participation at the ARIN XXI Public Policy and Members Meeting, taking place 6-9 April 2008, in Denver, Colorado. The meeting will take place at the Grand Hyatt Denver. Hotel and travel information, meeting registration, and agenda details, are available through http://www.arin.net/ARIN-XXI/. In addition to ARIN policy proposal and member discussions, the meeting will also feature the following: Sunday, 6 April ? First Timer Luncheon ? The IPv6 Pre-Game Show (no registration required) ? A session entitled ?Understanding ARIN?s Legacy Registration Services Agreement? presented by ARIN General Counsel Steven Ryan. ? Introduction to the Internet Resource Policy Evaluation Process and Open Policy Hour ? The 9th Annual Foosball Tournament Monday, 7 April ? The ARIN XXI Social Event. More information is available at: http://www.arin.net/ARIN-XXI/social.html Tuesday, 8 April ? The IPv6 Main Event (no registration required) Select the events you plan to attend on your registration form. If you have already registered, but would like to modify your selections, click on the "Update Existing Registration" link available through http://www.arin.net/ARIN-XXI/. You can always contact ARIN Member Services at info at arin.net with any questions. We look forward to seeing you in Denver! Regards, Member Services American Registry for Internet Numbers (ARIN) From info at arin.net Thu Mar 27 09:55:22 2008 From: info at arin.net (Member Services) Date: Thu, 27 Mar 2008 09:55:22 -0400 Subject: NRPM version 2008.2 - New Policy Implementation Message-ID: <47EBA74A.1020505@arin.net> On 10 March 2008, the ARIN Board of Trustees, acting on the recommendation of the Advisory Council and noting that the Internet Resource Policy Evaluation Process had been followed, adopted the following policy proposal: Policy Proposal 2007-22: Expand timeframe of Additional Requests This policy proposal has been incorporated into version 2008.2 of the ARIN Number Resource Policy Manual (NRPM). The Board also voted to remove the Mailing Lists section from the NRPM (Section 9). This section described the acceptable use policies of ARIN mail lists. The section was an artifact of the creation of the NRPM and was not number resource policy. NRPM version 2008.2 is effective 27 March 2008 and supersedes previous versions. See Appendix A of the NRPM for information regarding changes to the manual. The NRPM can be found at: http://www.arin.net/policy/nrpm.html Appendix A can be found at: http://www.arin.net/policy/nrpm_changelog.html Regards, Member Services American Registry for Internet Numbers (ARIN) From info at arin.net Thu Mar 27 10:31:26 2008 From: info at arin.net (Member Services) Date: Thu, 27 Mar 2008 10:31:26 -0400 Subject: New ARIN Mailing List Acceptable Use Policy Message-ID: <47EBAFBE.3000803@arin.net> This message is being sent to all ARIN mailing lists. If you are subscribed to more than one ARIN managed mailing list, you will receive multiple copies of this announcement. At its 10 March meeting, the ARIN Board of Trustees adopted a new Mailing List Acceptable Use Policy (AUP) for all ARIN public mailing lists. The AUP sets forth general guidelines of acceptable list conduct and calls out a number of specifically prohibited activities. A section on reporting violations and enforcement is included, along with procedures on how both are to be accomplished. The full text is available on the ARIN website as a link off the main mailing list page at: http://www.arin.net/mailing_lists/aup.html Regards, Member Services American Registry for Internet Numbers (ARIN) From info at arin.net Thu Mar 27 14:45:07 2008 From: info at arin.net (Member Services) Date: Thu, 27 Mar 2008 14:45:07 -0400 Subject: Policy Proposal 2008-3 - Staff Assessment Message-ID: <47EBEB33.2060601@arin.net> Policy Proposal 2008-3 Title: Community Networks IPv6 Allocation Proposal Submitted: March 4, 2008 Date of Assessment: March 27, 2008 ARIN Staff Assessment The assessment of this proposal includes comments from ARIN staff and the ARIN General Counsel. It contains analysis of procedural, legal, and resource concerns regarding the implementation of this policy proposal as it is currently stated. Any changes to the language of the proposal may necessitate further analysis by staff and Counsel. I. Proposal Policy Proposal is available as Annex A below and at: http://www.arin.net/policy/proposals/2008_3.html II. Understanding of the proposal ARIN staff understands this policy would provide IPv6 addresses to any organization considered to be a community network. III. Issues and concerns A. ARIN Staff Comments This proposal defines a ?community network? which is a new term in the ARIN region. The community should take a close look at this definition to explore whether its rather broad definition might make it subject to abuse or exploitation by people who may not otherwise qualify for IPv6 address space. This proposal does not state a minimum number of actual or planned customers for the community network. Staff recommends that a minimum number of customers be specified to help determine qualification. There is no minimum allocation size specified in this policy. Staff recommends that a minimum allocation size be specified. In addition, staff recommends that criteria for requests larger than the minimum allocation size and for requests for additional allocations be specified. Staff believes that a community network does not fit either LIR or end-user descriptions exactly and therefore recommends that this policy be inserted into NRPM as section 6.5.9 B. ARIN General Counsel Counsel sees no significant legal or litigation risk regarding this policy. IV. Resource Impact - Moderate The resource impact of implementing this policy is moderate. Barring any unforeseen resource requirements, this policy could be implemented within 90 days from the date of the ratification of the policy by the ARIN Board of Trustees. It will require the following: - New template - Registration software changes - New set of guidelines - Staff training Respectfully submitted, Member Services American Registry for Internet Numbers (ARIN) ##*## Annex A Policy Proposal 2008-3 Community Networks IPv6 Allocation Author: Joshua King Proposal Version: 1 Date: 4 March 2008 Proposal type: new Policy term: permanent Policy statement: [Add Section 2.8 to the NRPM.] 2.8 Community Network A community network is a generic reference to any network that is operated by a group of people living in a particular local area organized for the purposes of delivery or provision of network services to the residents of an incorporated or unincorporated regional municipality, city, town, village, rural municipality, township, county, district or other municipality or other such geographic space, however designated. [Modify 6.5.8.1b as follows.] b. qualify for an IPv4 assignment or allocation from ARIN under the IPv4 policy currently in effect or be a Community Network as defined in Section 2.8. Rationale: There are currently a number of projects globally that aim to develop community network infrastructure and related technologies. These are usually coordinated by volunteer-run, grassroots organizations which lack many of the resources of traditional internet service providers and other network operators. They have diverse goals, including public policy, software development, and implementation of community services and resources. Many of them provide services free of charge, and thus lack any paying user base. However, in order to create and maintain community networks that are often composed of hundreds if not thousands of inexpensive, commodity hosts and devices, a significant amount of address space will be required. Current-generation workarounds to this problem, such as NAT, not only make it difficult to develop next-generation decentralized network technology by segmenting the community's architecture from the Internet as a whole, but will cease to be as viable a stopgap as the Internet moves towards IPv6 integration. Even now, common community networking software solutions such as CUWiNware (http://www.cuwin.net) and Freifunk (http://www.freifunk.at) have nascent IPv6 addressing support, but participating organizations lack the address space for widespread testing or adoption. As such, it is necessary to implement an procedure as soon as possible for these segregated networks to acquire address space. These organizations do not meet the criteria traditionally defined for LIR's, and thus cannot acquire address allocations through existing templates. By establishing a procedure by which these organizations can seek to acquire the resources they require for further development, ARIN can reach out to this active community and establish a small but definite space for them in the future of Internet. Timetable for implementation: Immediate. From info at arin.net Fri Mar 28 11:16:50 2008 From: info at arin.net (Member Services) Date: Fri, 28 Mar 2008 11:16:50 -0400 Subject: [ppml] Revision to 2007-17 In-Reply-To: <0A63064A-3AEA-4A0D-BD77-ED16D08E0E75@delong.com> References: <0A63064A-3AEA-4A0D-BD77-ED16D08E0E75@delong.com> Message-ID: <47ED0BE2.7070204@arin.net> Policy Proposal 2007-17, Legacy Outreach and Partial Reclamation, has been revised. This proposal is open for discussion on this mailing list and will be on the agenda at the upcoming ARIN Public Policy Meeting. The current policy proposal text is provided below and is also available at: http://www.arin.net/policy/proposals/2007_17.html Regards, Member Services American Registry for Internet Numbers (ARIN) Owen DeLong wrote: > > The following revised version of 2007-17 is submitted for consideration. > The amendments are being made to address concerns expressed by staff > in the "staff assessment" of the policy proposal. > > I ran these changes by staff prior to submitting them here. The changes > do address the concerns expressed by staff, but, staff may wish to revise > their "impact" statement. Beyond this statement, I'll leave it to staff > to comment further if they wish. > > Apologies for the late date on this amendment. Look forward to upcoming > changes to the IRPEP to improve this situation. > > Owen > > > Modifications: > > Extended 4.6.1 to allow ARIN to reject transactions of no benefit > to the community. (Hopefully this closes most of the abuse loopholes) > > Renumbered 4.6.6 to 4.6.7 Annual contact required > > Renumbered 4.6.5 to 4.6.6 RSA Required if new addresses received > > Inserted new 4.6.5 to spell out requirement for ARIN to work with > resource holders to specify a return timeframe in contract. > > Added text to rationale to clarify overriding intent and > > Policy Proposal 2007-17 > Legacy Outreach and Partial Reclamation > > Author: Owen DeLong > > Date: 21 February 2008 > > Proposal type: modify > > Policy term: permanent > > Policy statement: > > Replace section 4.6 as follows: > > 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. ARIN should reject any transaction which staff judges > is not in the interests of the community. > > 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 th.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 greater 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 Incentives > > The Board of Trustees should consider creating incentives for > organizations to return addresses under this policy. > > 4.6.5 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. > > 4.6.6 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. > > 4.6.7 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. > > Rationale: > > Existing policy supports aggregation (4.7) and provides some amnesty > (existing 4.6) for returning blocks. However, a number of resource > holders have expressed discomfort with the current section 4.6 > believing that they will be forced to return their entire address > space and renumber rather than being able to make partial returns and > retain some of their existing space. > > This policy seeks to eliminate those concerns and make the return of > unused address space more desirable to the resource holders. > > A very high percentage of underutilized space is in the hands of > legacy holders who currently have no benefit to joining the ARIN > process and no way to return any portion of their address space > without incurring significant disadvantage as a result. > > A suggestion to the board would be to adopt benefits along the > following lines for people returning space. These benefits would > provide additional incentive for resource holders to make appropriate > returns and for legacy holders to join the ARIN process: > > 1. If the organization does not currently pay ARIN fees, they shall > remain fee exempt. > > 2. If the organization currently pays ARIN fees, their fees shall be > waived for two years for each /20 returned, with any fractional /20 > resulting in a one-time single year waiver. > > 3. Any organization returning address space under this policy shall > continue under their existing RSA or they may choose to sign the > current RSA. For organizations which currently do not have an RSA, > they may sign the current RSA, or, they may choose to remain without > an RSA. > > 4. All organizations returning space under this policy shall, if they > meet other eligibility requirements and so request, obtain an > appropriate IPv6 end-user assignment or ISP allocation as applicable, > with no fees for the first 5 years. Organizations electing to receive > IPv6 allocation/assignment under this provision must sign a current > RSA and must agree that their IPv4 resources are henceforth subject to > the RSA. > > The overriding intent of this policy proposal is to make it as easy as > possible for both ARIN and resource holders to "do the right thing" > with regard to excess resources or dis-aggregated (fragmented) address > blocks. It is the desire of the author that staff make any judgment > calls necessary under this policy with that ideal clearly in mind. > While the author has made a concerted effort to make the policy as > clear as possible and > as concrete as can be, the reality is that these types of transactions > must rely heavily on the judgment and expertise of the ARIN staff in > determining what is in the best interests of the community. > > > Timetable for implementation: Immediate > > > ------------------------------------------------------------------------ > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to the ARIN Public Policy > Mailing List (PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/ppml > Please contact the ARIN Member Services Help Desk at info at arin.net if you experience any issues. From info at arin.net Mon Mar 31 09:28:23 2008 From: info at arin.net (Member Services) Date: Mon, 31 Mar 2008 09:28:23 -0400 Subject: Reminder: ARIN XXI Open Policy Hour and Remote Participation Message-ID: <47F0E6F7.1060108@arin.net> Sign up today to present your ideas at the ARIN XXI Open Policy Hour, Sunday, 6 April, from 4:30-5:30 PM (MDT). The Open Policy Hour (OPH) is a showcase for your policy ideas. If you have a policy proposal you?d like to debut, prior to formally submitting it, here is your opportunity. Sign up by Wednesday, 2 April to ensure your chance to take the microphone. Send an e-mail to policy at arin.net with your name, organization, and a general description of the policy subject you wish to present. Everyone is invited to attend the session and raise ideas and suggestions. You do not need to have a formal presentation in order to participate. Signing up in advance allows us to confirm your turn to present your policy idea. Information on this and other sessions is available at: http://www.arin.net/ARIN-XXI/agenda.html For the first time ever, the OPH will be available as part of our live meeting webcast and remote participants may submit comments and questions. To register for remote participation, click the ?Meeting Registration? button available at http://www.arin.net/ARIN-XXI/ and choose "ARIN XXI Remote Participant" from the drop-down. Registration is not required to view the webcast. Comments received from remote participants will be moderated and presented during normal question and answer periods. ARIN will use e-mail to provide the interactive portion of the remote participation effort. All remote participants are subject to the Remote Participation Acceptable Use Policy (AUP). Additional information about remote participation, including the Remote Participation AUP, is available at: http://www.arin.net/ARIN-XXI/webcast.html We look forward to your participation in ARIN XXI. Meeting details are available at http://www.arin.net/ARIN-XXI/. Please contact Member Services at info at arin.net if you have any questions. Regards, Member Services Department American Registry for Internet Numbers (ARIN) From info at arin.net Mon Mar 31 11:59:01 2008 From: info at arin.net (Member Services) Date: Mon, 31 Mar 2008 11:59:01 -0400 Subject: Poll - Transfer Policy Message-ID: <47F10A45.70001@arin.net> The ARIN Advisory Council is conducting a poll. The poll contains five questions. You will receive five e-mails, one question per message. Every e-mail address subscribed to the Public Policy Mailing List (PPML) will be e-mailed individually with instructions on how to participate in the poll. If an alias is subscribed to the PPML that is then distributed to several individuals, only the first opinion registered will be counted. Only those who are already subscribed when the poll starts may participate. The poll ends at noon EDT on Thursday, 3 April 2008. The results will be sent to PPML. Regards, Member Services American Registry for Internet Numbers (ARIN)