[ppml] Policy Proposal 2007-23 - Staff Assessment

[Member Services]

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