[arin-ppml] Draft Policy 2009-8: Equitable IPv4 Run-Out

[Member Services]

Draft Policy 2009-8
Equitable IPv4 Run-Out

On 20 August 2009 the ARIN Advisory Council (AC) selected "Equitable
IPv4 Run-Out" as a draft policy for adoption discussion on the PPML and
at the Public Policy Meeting in Dearborn.

The draft was developed by the AC from Policy Proposals "93: Predicable
IPv4 Run Out by Prefix Size and 94: Predictable IPv4 Run Out by
Allocation Window". Per the Policy Development Process the AC submitted
text to ARIN for a staff and legal assessment prior to its selection as
a draft policy. After reviewing the assessment the AC made several
changes to the text.

Draft Policy 2009-8 is below and can be found at:
https://www.arin.net/policy/proposals/2009_8.htm

Below the draft policy is the ARIN staff and legal assessment, including
the original proposal text.

You are encouraged to discuss Draft Policy 2009-8 on the PPML prior to
the October Public Policy Meeting. Both the discussion on the list and
at the meeting will be used by the ARIN Advisory Council to determine
the community consensus for adopting this as policy.

The ARIN Policy Development Process can be found at:
https://www.arin.net/policy/pdp.html

Draft Policies and Proposals under discussion can be found at:
https://www.arin.net/policy/proposals/index.html

Regards,

Member Services
American Registry for Internet Numbers (ARIN)


## * ##


Draft Policy 2009-8
Equitable IPv4 Run-Out

Version/Date: 31 August 2009

Policy statement:

Replace NRPM 4.2.4.4 with;

4.2.4.4 Subscriber Members After One Year

After an organization has been a subscriber member of ARIN for one year,
they may choose to request up to a 12 month supply of IP addresses.

As the IANA free pool decreases, the length of supply that an
organization may request will be reduced at the following thresholds.
This reduction does not apply to resources received via section 8.3. An
organization receiving a transfer under section 8.3 may continue to
request up to a 12 month supply of IP addresses.

When IANA reaches 20 or fewer unallocated /8s, an organization may
choose to request up to a 6 month supply of IP addresses;

When IANA reaches 10 or fewer unallocated /8s, an organization may
choose to request up to a 3 month supply of IP addresses;

Create a new subsection in section 4 of the NRPM;

4.X Maximum Allocation or Assignment during and following Run-Out

When ARIN receives its last /8, by IANA implementing section 10.4.2.2, a
proportionally decreasing maximum allocation, and assignment, size will
be put into effect. The maximum allocation will be the next whole CIDR
prefix less than or equal to one quarter (1/4) of the total ARIN free
pool available at the time of each allocation, but no longer than the
applicable minimum allocation.

An organization may request additional resources when it can demonstrate
it has properly utilized all previous allocations per applicable
policies. However, the total of all allocations received within the last
three (3) month period and the current request, cannot exceed the
current maximum allocation size.

This maximum allocation size is applicable to allocations from the ARIN
free pool only. It is explicitly not applicable to resources received
via transfer under section 8.3, or any other specially designated resources.

Rationale:

This proposed policy is intended to ensure an equitable distribution of
IPv4 resources as run-out of the IANA free pool and subsequently the
ARIN free pool occurs. This is achieved in two parts; first, changing
section 4.2.4.4 of the NRPM to reduce the length of supply of IPv4
resources that may be requested in steps as the IANA free pool runs-out.
This helps accomplish equity by reducing the window that an advantage or
disadvantage can exist between competitors, that will be created when
one competitor receives a final allocation just before run-out and
another competitor does not.

The reductions in the length of supply will be triggered by IANA
reaching defined levels of unallocated /8s, including the /8s reserved
as part of section 10.4 of the NRPM. These triggers have been chosen
base on the current rate of consumption of /8s by the RIRs.

The first part of this policy is similar to ideas in RIPE policy
proposal 2009-03
(http://www.ripe.net/ripe/policies/proposals/2009-03.html), and has been
adapted by discussion and for use within the ARIN region.

The second part of this policy, allows a maximum of one quarter (1/4) of
the then current total IPv4 resources to be allocated in a single
request, once ARIN has received its last /8 from IANA. This helps
achieve equity by ensuring the available resources are spread among
multiple organizations and that no single organization may monopolize
all of the resources available through a single request, at least until
the maximum allocation size has been reduced down to the minimum
allocation size.

Incrementally reducing the length of supply and then reducing the
maximum allocation size in proportion to the amount of resources
available should minimize, or possibly eliminate, the need to fulfill
requests with multiple smaller blocks.

As in the current NRPM, the length of supply only applies to ISP
allocations. However, the maximum allocation size is intended to apply
to both ISP allocations and End-user assignments.

This policy is intended to be independent of other policies or proposals
to reserve address space for IPv6 transition or other purposes. Neither
part is intended to limit Transfers to Specified Recipients per section
8.3 of the NRPM.

The current maximum allocation size should be published on the ARIN
website, preferably in real-time, as it may change rapidly as the ARIN
free pool resources are exhausted. In the worst-case the maximum
allocation size will decrease every forth allocation, when all four are
the then current maximum allocation size. However, in the beginning
there will likely be many smaller allocations before the maximum
allocation size is decreased, accelerating as the resources are exhausted.

Following the run-out phase, this policy provides an equitable means of
distribution of resources if or when additional resources become
available after ARIN has initially exhausted such resources. Such as if
resources are returned, recovered by other means, or additional
resources are obtained from IANA. Further, whenever ARIN receives a
sufficiently large amount of additional resources, this policy intends
for the maximum allocation size to be increased accordingly.

After ARIN receives its last /8, the intent is to normally limit an
organization to a single maximum allocation within a three month period.
However, saying it that simply opens this policy to gamesmanship in
requesting less than a maximum allocation. Requiring a maximum
allocation to cover new requests and all allocations received in the
previous three month period, should eliminate this kind of gamesmanship.

There is a beneficial side effect of stating it this way, in the special
situation when the maximum allocation size is increased, due to ARIN
obtaining a sufficiently large amount of additional resources, an
organization may receive additional resources earlier than the normal
three month period. But, only in this special situation and when an
organization properly utilizes a previous maximum allocation in less
than three months, may an organization receive additional resources in
less than the normal three month period.

Other ratios, such as one half (1/2) or one eighth (1/8) could be
considered. One eighth (1/8) would provide greater assurance of
eliminating the need to use multiple blocks to fulfill requests and
ensure a greater number of organizations receive resources. However, one
eighth (1/8) is more likely to be seen as rationing and an attempt to
artificially extend the lifetime of IPv4. During the ARIN XXIII policy
discussion there seemed to be a consensus that attempts to extend the
lifetime of IPv4 resources would be undesirable. While on the other
hand, one half (1/2) is even less likely to ration resources, but it
would likely result in the resource being spread across significantly
fewer organizations and increase the need to use multiple blocks to
fulfill requests.

In conclusion, combining the final 3 month length of supply with the one
quarter (1/4) ratio provides roughly an annualized equivalent of the
whole ARIN free pool being made available to a single organization.
While it is not possible for a single organization to receive the whole
ARIN free pool within one year under this policy, it is a virtual
certainty that multiple organization will be requesting resources, and
that the ARIN free pool will not likely last a full year following the
exhaustion of the IANA free pool anyway. Therefore, the ratio one
quarter (1/4) seems to strike a balance between making resources
available with as little restriction as possible and ensuring an
equitable distribution of those resources during and following the
run-out phase.

EDITORIAL NOTE: This Draft Policy 2009-8 merges ideas from two separate
policy proposals, 93. Predicable IPv4 Run Out by Prefix Size and 94.
Predictable IPv4 Run Out by Allocation Window.

Timetable for implementation: Immediate

#####
#####

Proposal: Equitable IPv4 Run-Out

Proposal Version (Date): 3 August 2009

Date of Assessment:  18 August 2009

1. Proposal Summary (Staff Understanding)
Staff understands the policy applies to ISPs who have been ARIN members
for more than a year. When IANA reaches 20 /8s, the supply period for
IPv4 address space will decrease from a 12 months to 6 months. When the
IANA reaches 10 or less /8s,  the supply period is reduced to 3 months.
The second part of the proposal triggers upon receipt of ARIN’s last /8
from the IANA (per NRPM 10.4.2.2). The policy would establish a new
maximum prefix size for all requests and place a limit on the amount of
space an organization can receive  within any three month period. The
maximum prefix size would be on a sliding  scale relative to the total
amount of free IPv4 addresses in ARIN's inventory (one  fourth of the
total rounded down to the nearest smallest CIDR prefix). These polices
do not apply to Transfers to Specified Recipients (NRPM 8.3).

2. Comments

A.  ARIN Staff Comments

   The policy can be implemented as written.

   The title of section 4.2.4.4 needs to change from “Twelve Months” to
“Subscriber Members After One Year”.

   Note that the maximum prefix size in effect at any given time (e.g.
/16) may be larger than the largest available contiguous address block
in ARIN’s inventory (e.g. /18). In order to fulfill a request in this
scenario, ARIN would have to issue several discontiguous address blocks.

   There is a suggestion in the rationale to display the maximum prefix
size in real time. But that prefix size might not be available upon
completion of a request. Example, on Friday we display /18. By the time
the request is finalized, the maximum is a /19, and that’s what is
issued to the customer.  We could put a disclaimer that the actual
prefix issued to a customer could be  smaller. Also, we see value in
keeping track of the maximum prefix size over time.

   The third sentence of the proposed 4.2.4.4 (starting with "This
reduction") is a run-on sentence and contains grammatical errors. ARIN
staff suggests the  following replacement text: “This reduction does not
apply to resources received via section 8.3. Organizations requesting
transfers under 8.3 may choose to request up to a 12-month supply of IP
addresses.”

B. ARIN General Counsel

   ARIN has the legal duty and authority to establish more restrictive
rules to “ration” the issuance of IPv4 resources as the scarcity of such
resources increases.  However, such rules must make clear rational sense
given current circumstances, and may be tested in litigation by
disappointed parties at the time they come fully into effect, not when
adopted.  Therefore, the proposed policy here will need to be carefully
reviewed and if passed, carefully implemented, for example, to prevent
any “side effect” that would inadvertently favor one set of ISPs over
another.

3. Resource Impact

This policy would have minimal resource impact.  It is estimated that
implementation would occur within 3 months after ratification by the
ARIN Board of Trustees. The following would be needed in order to
implement:
   Updates to software
   Updated guidelines
   Staff training

4. Proposal Text

Equitable IPv4 Run-Out

Date: 3 August 2009

Policy statement:

Replace the text in NRPM 4.2.4.4 with;

After an organization has been a subscriber member of ARIN for one year,
they may choose to request up to a 12 month supply of IP addresses. As
the IANA free pool decreases, the length of supply that an organization
may request will be reduced at the following thresholds. This reduction
does not apply to  resources received via Transfers to Specified
Recipients per section 8.3, in this case  an organization may continue
choose to request up to a 12 month supply of IP addresses.

When IANA reaches 20 or fewer unallocated /8s , an organization may
choose to request up to a 6 month supply of IP addresses;

When IANA reaches 10 or fewer unallocated /8s , an organization may
choose to request up to a 3 month supply of IP addresses;

Create a new subsection in section 4 of the NRPM;

4.X Maximum Allocation or Assignment during and following Run-Out

When ARIN receives its last /8, by IANA implementing section 10.4.2.2, a
proportionally decreasing maximum allocation, and assignment, size will
be put into effect. The maximum allocation will be the next whole CIDR
prefix less than or equal to one quarter (1/4) of the total ARIN free
pool available at the time of each  allocation, but no longer than the
applicable minimum allocation. An OrgID may request additional resources
when it can demonstrate it has properly  utilized all previous
allocations per applicable policies. However, the total of all
allocations received within the last three (3) month period and the
current request, cannot exceed the current maximum allocation size.
This maximum allocation size is applicable to allocations from the ARIN
free pool only, and is explicitly not applicable to resources received
through Transfers to Specified Recipients per section 8.3, or any other
specially designated resources.

Rationale:

This proposed policy is intended to ensure an equitable distribution of
IPv4 resources as run-out of the IANA free pool and subsequently the
ARIN free pool occurs. This is achieved in two parts; first, changing
section 4.2.4.4 of the NRPM to reduce the length of supply of IPv4
resources that may be requested in steps as the IANA free pool runs-out.
This helps accomplish equity by reducing the window that an advantage or
disadvantage can exist between competitors, that will be created
when one competitor receives a final allocation just before run-out and
another competitor does not.

The reductions in the length of supply will be triggered by IANA
reaching defined levels of unallocated /8s, including the /8s reserved
as part of section 10.4 of the NRPM. These triggers have been chosen
base on the current rate of consumption of /8s by the RIRs.

The first part of this policy is similar to ideas in RIPE policy
proposal 2009-03
(http://www.ripe.net/ripe/policies/proposals/2009-03.html), and has been
adapted by discussion and for use within the ARIN region.

The second part of this policy, allows a maximum of one quarter (1/4) of
the then current total IPv4 resources to be allocated in a single
request, once ARIN has  received its last /8 from IANA. This helps
achieve equity by ensuring the available resources are spread among
multiple organizations and that no single organization may monopolize
all of the resources available through a single request, at least
until the maximum allocation size has been reduced down to the minimum
allocation size.

Incrementally reducing the length of supply and then reducing the
maximum allocation size in proportion to the amount of resources
available should minimize, or possibly eliminate, the need to fulfill
requests with multiple smaller blocks.

As in the current NRPM, the length of supply only applies to ISP
allocations. However, the maximum allocation size is intended to apply
to both ISP allocations and End-user assignments.

This policy is intended to be independent of other policies or proposals
to reserve address space for IPv6 transition or other purposes. Neither
part is intended to limit Transfers to Specified Recipients per section
8.3 of the NRPM.

The current maximum allocation size should be published on the ARIN
website, preferably in real-time, as it may change rapidly as the ARIN
free pool resources are exhausted. In the worst-case the maximum
allocation size will decrease every forth allocation, when all four are
the then current maximum allocation size. However, in the beginning
there will likely be many smaller allocations before the maximum
allocation size is decreased, accelerating as the resources are exhausted.

Following the run-out phase, this policy provides an equitable means of
distribution of resources if or when additional resources become
available after ARIN has  initially exhausted such resources. Such as if
resources are returned, recovered by other means, or additional
resources are obtained from IANA. Further, whenever ARIN receives a
sufficiently large amount of additional resources, this policy
intends for the maximum allocation size to be increased accordingly.

After ARIN receives its last /8, the intent is to normally limit an
organization to a single maximum allocation within a three month period.
However, saying it that simply opens this policy to gamesmanship in
requesting less than a maximum allocation. Requiring a maximum
allocation to cover new requests and all allocations received in the
previous three month period, should eliminate this kind
of gamesmanship.

There is a beneficial side effect of stating it this way, in the special
situation when the maximum allocation size is increased, due to ARIN
obtaining a sufficiently large amount of additional resources, an
organization may receive additional resources earlier than the normal
three month period. But, only in this special situation and
when an organization properly utilizes a previous maximum allocation in
less than three months, may an organization receive additional resources
in less than the normal three month period.

Other ratios, such as one half (1/2) or one eighth (1/8) could be
considered. One eighth (1/8) would provide greater assurance of
eliminating the need to use multiple blocks to fulfill requests and
ensure a greater number of organizations receive resources. However, one
eighth (1/8) is more likely to be seen as rationing and an attempt to
artificially extend the lifetime of IPv4. During the ARIN XXIII policy
discussion there seemed to be a consensus that attempts to extend the
lifetime of IPv4 resources would be undesirable. While on the other
hand, one half (1/2) is even less likely to ration resources, but it
would likely result in the resource being spread across significantly
fewer organizations and increase the need to use multiple blocks
to fulfill requests.

In conclusion, combining the final 3 month length of supply with the one
quarter (1/4) ratio provides roughly an annualized equivalent of the
whole ARIN free pool being made available to a single organization.
While it is not possible for a single organization to receive the whole
ARIN free pool within one year under this policy, it is a virtual
certainty that multiple organization will be requesting resources, and
that the ARIN free pool will not likely last a full year following the
exhaustion of the IANA free pool anyway. Therefore, the ratio one
quarter (1/4) seems to strike a balance between making resources
available with as little restriction as possible and ensuring an
equitable distribution of those resources during and following the
run-out phase.

EDITORIAL NOTE: This Draft Policy 2009-X merges ideas from two separate
policy proposals, 93. Predicable IPv4 Run Out by Prefix Size and 94.
Predictable IPv4 Run Out by Allocation Window.

Timetable for implementation: Immediate