[ppml] policies at ARIN Re: Proposed Policy: IPv4 Countdown

Edward Lewis Ed.Lewis at neustar.biz
Wed Mar 14 08:22:06 EDT 2007

I want to address the meta-issue here, not arguing with Michael, but 
his valid objections are symptoms of my concern with the policy 
process as we know it.

At 10:05 +0000 3/14/07, <michael.dillon at bt.com> wrote:
>ARIN has long had a problem with ill-thought-out, hastily written policy
>proposals that were shoved into the public arena before they were ready.

Yes, this is true.  Avoiding any comment on the policy at hand, when 
I hear "long had a problem with" I begin to question whether it is 
the massive number of misguided attempts or a process that is ill 
equipped to meet demand.

This is why I have been making comments over the past two years 
asking for a better way to craft policies in smaller groups, 
workshops, with input from experts and from staff to help shape the 

For example, Leo Bicknell's ambitious undertaking to revamp the 
directory services would have benefitted from more time by a few 
experts putting all that together.  Leo did an admirable job but the 
limited time for open discussion at the Public Policy meetings, the 
in frequent nature of them (twice a year is not enough to keep 
something so big rolling), and the relatively low-bandwidth 
communication that email is doom any serious overhaul of how ARIN 
conducts business.

OTOH, maybe slowing and dampening "progress" is a good thing. ;)  My 
time as a government bureaucrat taught me that the last thing I want 
is a quick and efficient government.  But seriously, there are times 
when we do need to bring the ARIN practices up to date.

>In one sense, this is yet another of these. Like other poorly crafted
>proposals it also suffers from the "plain English" problem. What is an
>A-Date or T-Date? Why  can't the authors just say what they mean in
>plain English? How many times did you have to read the proposal, jumping

I think the latter is a symptom of us not wanting to hear "the big 
picture story" but just "what do you want to do?"  I know that 
there's been pressure to formulate a policy proposal to get it 
considered in time for a Public Policy meeting.  If it isn't a 
policy, it isn't considered.  Besides being a policy, it has to be 
something that passes muster with the ARIN AC and it's mission, so, 
it has to be pointed.

When it comes to potential global policies, these are something that 
faca a catch-22.  They have to be approved in all regions, so 
something has to be submitted.

>back and forth in the text, to figure out just what they are saying.
>This is bad. The Rationale section is there to allow authors to explain
>the reasoning behind a policy, not to explain the meaning of the policy

I'm not going to argue over that, as in, you have a point but that is 
not what I am addressing now.

>In addition, the authors suggest that ARIN policy should require ARIN to
>take some action when IANA resources reach a certain level. But IANA is
>not controlled by ARIN. Does IANA even report on the size of their pool
>in /8 equivalents? How is this to be measured?

I see the proposal as having to be something that goes to IANA or be 
global.  To get there it has to be discussed in all regions.  Maybe I 
don't understand the global policy process, maybe there's a check-box 
that was missed.

(I am assuming that this is meant to be a global policy.  I am not 
tied to the origination of the proposal, but the rejection of it was 
brought to my attention which is why I am speaking up now.)

>But that is not all that is undefined. Does ARIN have a clear policy
>definition of "critical infrastructure" as referred in the proposal? The
>proposal refers to "projections" but does ARIN actually make such

Ok, I will make a proposal-specific comment here.  Perhaps the 
confusion is because the APNIC Chief Scientist has done extensive 
work on projecting exhaustion dates.  ARIN has avoided making such 

>And of course, the policy requires ARIN to terminate allocating IPv4
>ranges which is entirely contrary to ARIN's charter. ARIN exists to
>allocate IPv4 addresses and the only reason for this to stop is for the
>supply to be exhausted. As long as IANA gives ARIN IPv4 addresses, ARIN
>should continue to allocate them according to its policy guidelines.

I might disagree with that...but I don't want to open that can o' 
worms in this mail.

>In case you hadn't noticed, this policy proposal was made by people from
>outside the ARIN region. The same proposal was put before APNIC in their
>own region. They are attempting to create a global policy without
>following the global policy process of NRO

"Public Policy" means public.  I am a SIG chair in the APNIC region 
but my desk is near Washington DC.  There is no "they" and "us" when 
it comes to the public discussion of the RIRs.

>Note that in the NRO process, the global policy is ratified by the ICANN
>board of directors before coming into action. Also note that IANA is one
>of the functions of ICANN, in other words if you want to make policies
>based on IANA resources or IANA actions, you should go through the NRO.
>Two of the three existing global policies actually do deal with IANA so
>presumably the process works reasonably well.
>As for anti-trust, well, this policy sounds like somebody making up
>rules just for the sake of making up rules. The real goal seems to be
>publicity of the fact that we are now in the wind-down phase of IPv4 and
>IANA could run out of free /8s as early as 3 years from now. In my
>opinion, ARIN policy is not the way to solve a publicity problem and not
>the way to solve an education problem.

I may have made more proposal-specific comments here than I intended. 
The message I am sending is that the roughness here is another reason 
I have been asking for a more robust, committee-like approach for 
preliminary discussion about ARIN policies and more 
technically-motivated discussion about service levels and the like.

Edward Lewis                                                +1-571-434-5468

Sarcasm doesn't scale.

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