[arin-ppml] Draft Policy 2009-3 (Global): Allocation of IPv4 Blocks to Regional Internet Registries

[Member Services]

Draft Policy 2009-3 (Global)
Allocation of IPv4 Blocks to Regional Internet Registries

The following draft policy text is being posted for feedback and
discussion on the Public Policy Mailing List (PPML).

This draft policy was developed by the ARIN Advisory Council (AC) from
Policy Proposal 82: Allocation of IPv4 Blocks to Regional Internet
Registries. The AC has taken the proposal and developed it into a draft
policy. The AC was required to submit text to ARIN for staff and legal
assessment prior to selecting it as a draft policy. The assessment,
along with the text that was assessed, is located below the draft policy.

On 20 March 2009 the ARIN Advisory Council (AC) selected Draft Policy
2009-3: Allocation of IPv4 Blocks to Regional Internet Registries for
adoption discussion on the PPML and at the upcoming Public Policy Meeting.

Draft Policy 2009-3 is below and can be found at:
https://www.arin.net/policy/proposals/2009_3.html

We encourage you to discuss Draft Policy 2009-3 on the PPML prior to the
ARIN XXIII Public Policy Meeting. Both the discussion on the PPML and at
the Public Policy Meeting will be used by the AC to determine the
community consensus regarding adopting this as policy.

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

All of the Draft Policies 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 2009-3 (Global)
Allocation of IPv4 Blocks to Regional Internet Registries

Date: 23 March 2009

Policy statement:

This document describes the policy governing the allocation of IPv4
address space from the IANA to the Regional Internet Registries (RIRs).
This document does not stipulate performance requirements in the
provision of services by IANA to an RIR in accordance with this policy.
Such requirements should be specified by appropriate agreements among
the RIRs and ICANN.

This policy is to be implemented in two phases.

A. Phase I: Recovery of IPv4 Address Space

Upon ratification of this policy by the ICANN Board of Directors the
IANA shall establish a mechanism to receive IPv4 address space which is
returned to it by the RIRs, and hold that address space in a 'recovered
IPv4 pool'.

Each RIR through their respective chosen policies and strategies may
recover IPv4 address space which is under their administration. At
quarterly intervals, each RIR shall return to the IANA any legacy
address space recovered, and may return to the IANA any non-legacy
address space recovered, in aggregated blocks of /24 or larger, for
inclusion in the recovered IPv4 pool.

During Phase I, no allocations will be made from the recovered IPv4
pool. Return of recovered address space (as described above) will
continue throughout Phase II.

B. Phase II: Allocation of Recovered IPv4 address space by the IANA

Upon ratification of this policy by the ICANN Board of Directors and a
declaration by the IANA that its existing free pool of unallocated IPv4
address space is depleted; Global Addressing Policy ASO-001-2 (adopted
by ICANN Board 8 April 2005) is rescinded. IANA will then commence to
allocate the IPv4 address space from the recovered IPv4 pool.

1. The following definitions apply to this policy:

a. Recovered Address Space. Recovered address space is that address
space that is returned to an RIR as a result of any activity that seeks
to reclaim unused address space or is voluntarily returned to the RIR or
is reclaimed by the RIR as a result of legal action or abuse
determination. Recovered address space does not include that address
space that is reclaimed because of non-payment of contractual fees whose
reclamation date is less than 1 year at the time of the report.

b. IPv4 Address Holdings. IPv4 address holdings are all unallocated IPv4
address space held by an RIR to include recovered address space not yet
returned less that address space that is committed in accordance with
the RIR's reservation policy and practices.

c. Aggregated address blocks. Aggregated address blocks are contiguous
prefixes that can be aggregated on natural bit boundaries. 10.0.0.0/24
and 10.0.1.0/24 are two contiguous prefixes that can be combined to form
an aggregated address block. 10.0.0.0/24 and 10.0.1.0/25 are two
contiguous prefixes that cannot be combined on a natural bit boundary to
form an aggregated block.

d. Legacy address space. IPv4 address space allocated or assigned prior
to the creation of the RIR.

2. Allocation of IPv4 Address Space

a. For the purposes of this policy, an 'IPv4 allocation period' is
defined as a 6-month period following 1 March or 1 September in each year.

b. At the beginning of each IPv4 allocation period, the IANA will
determine the 'IPv4 allocation unit' for that period, as 1/10 of its
IPv4 address pool, rounded down to the next CIDR (power-of-2) boundary.
The minimum 'IPv4 allocation unit' size will be a /24.

c. In each allocation period, each RIR may issue one IPv4 request to the
IANA. Providing that the RIR satisfies the allocation criteria described
in paragraph B.2, the IANA will allocate a single allocation unit,
composed of the smallest possible number of blocks available in its IPv4
address pool.

3. IPv4 Address Space Allocation Criteria

A RIR is eligible to receive additional IPv4 address space from the IANA
when the total of its IPv4 address holdings is less than 50% of the
current IPv4 allocation unit, and providing that it has not already
received an IPv4 allocation from the IANA during the current IPv4
allocation period.

4. Initial Allocation of IPv4 Address Space

Each new RIR shall, at the moment of recognition, be allocated one (1)
allocation unit by the IANA. If an allocation unit is not available,
then the IANA will issue this block as soon as one is available. This
allocation will be made regardless of the newly formed RIR's projected
utilization figures and shall be independent of the IPv4 address space
that may have been transferred to the new RIR by the already existing
RIRs as part of the formal transition process.

5. Reporting

a. All returned space is to be recorded in an IANA-published log of IPv4
address space transactions, with each log entry detailing the returned
address block, the date of the return, and the returning RIR.

b. All allocated space is also to be recorded in this IANA-published log
of IPv4 address space transactions, with each log entry detailing the
address blocks, the date of the allocation and the recipient RIR.

c. The IANA will maintain a public registry of the current disposition
of all IPv4 address space, detailing all reservations and current
allocations and current IANA-held address space that is unallocated.

d) The IANA may make public announcements of IPv4 address block
transactions that occur under this policy. The IANA will make
appropriate modifications to the "Internet Protocol V4 Address Space"
page of the IANA website and may make announcements to its own
appropriate announcement lists. The IANA announcements will be limited
to which address ranges, the time of allocation and to which Registry
they have been allocated.



#####

ARIN Staff Assessment

*Title: Allocation of IPv4 Blocks to the Regional Internet Registries*

*Proposal Submitted: 30 Jan 2009*

*Revision Submitted: 05 March 2009*

*Date of Assessment: 10 March 2009*

* *

I. Understanding of the Policy:

*Staff Understanding of the Proposal:*

Staff understands that this proposal would be implemented in 2 phases.
Phase 1 would require the RIRs to return recovered IPv4 legacy address
space (via policy or procedure) to the IANA and have the option of
returning recovered non-legacy address space to the IANA. Phase 2 would
start after the depletion of the IANA free pool and would nullify the
existing IANA to RIR policy (Global Addressing Policy ASO-001-2). The
new IANA to RIR policy would allow each RIR to receive approximately
1/10th of the recovered IPv4 pool from IANA once every 6 months as long
as it meets the qualification criteria written in paragraph B2. IANA
will be required to keep a log of all returned IPv4 address space and
all issued IPv4 address space from the recovered pool, as well as
maintain a public registry of the current disposition of all IPv4
address space.

II. Comments

A. ARIN Staff Comments

    * The one policy that this impacts is NRPM 4.6 Amnesty and
      Aggregation, which says “Transactions should only be accepted
      under this policy if they are in the interests of the community
      (e.g. they improve aggregation or result in a net reclamation of
      space).” Because the ARIN region holds the majority of the legacy
      address space, and most of the address space returned under this
      policy is legacy space, it would mean that there would be no “net
      return” of address space to ARIN. ARIN would essentially be
      exchanging legacy address space for non-legacy address space, and
      returning the legacy address space it received in the exchange to
      IANA, resulting in a net loss of address space in ARIN’s available
      pool.

B. ARIN General Counsel Comments:

The current basis of allocation of numbers was established in RFC's 2008
and 2050 and is need based. If one region has greater needs than
another, the current policy of IANA does not require equal distribution
to all RIR's s. This proposed policy would establish a different
political and not needs based method for allocating returned space. It
would make each RIR an equal recipient of such space. But the level of
need and economic activity between each RI R is not equal. This policy
will tend to reallocate returned space away from where it is recovered,
in the ARIN region , and move more of it to AFRINIC and LACNIC than
current distribution principles. By equating the smaller economies and
related needs of certain regions to the needs of other regions, like
ARIN, that have greater day to day need, it in effect creates a new
political order of distribution thru equal shares. It is possible
sovereign governments in the regions with greater activity will not
agree to such a revised distribution model. The proposed policy
undermines the legal rationale for distribution.

The policy also creates a powerful disincentive for any RIR, including
ARIN, to undertake any financial expenditure of RIR dollars for programs
intended to obtain returned space for reallocation. Currently ARIN is
working towards policies such as the LRSA and 2008-6, intended to
encourage returns and use of under utilized resources, but which cost
ARIN expenditures other RIRs are not duplicating. Any policy which
creates such a disincentive by leaving expenditures with a single RIR,
who cannot benefit except to receive 20% of the returned space should be
carefully considered.

Finally, it is likely entities with number resources in the ARIN region
may be willing to return those resources for uses in the region but
unwilling to do so if 4/5 of such resources will be sent to other regions.

III. Resource Impact

The resource impact of implementing this policy is viewed as minimal. It
is estimated that this policy could require up to 3 person months of
effort to implement following ratification by the ARIN Board of
Trustees. Because this implementation is not planned, it may preempt
ARIN’s current project deployment schedule. It may require the following:

    * Modifications to existing registration procedures to include the
      handling of returned/reclaimed address space and the process of
      requesting additional address space from the IANA.
    * Staff training

Text assessed:

*Allocation of IPv4 Blocks to Regional Internet Registries (Global)*

*Policy statement:*

This document describes the policy governing the allocation of IPv4
address space from the IANA to the Regional Internet Registries (RIRs).
This document does not stipulate performance requirements in the
provision of services by IANA to an RIR in accordance with this policy.
Such requirements should be specified by appropriate agreements among
the RIRs and ICANN.

This policy is to be implemented in two phases.

A. Phase I: Recovery of IPv4 Address Space

Upon ratification of this policy by the ICANN Board of Directors the
IANA shall establish a mechanism to receive IPv4 address space which is
returned to it by the RIRs, and hold that address space in a 'recovered
IPv4 pool'.

Each RIR through their respective chosen policies and strategies may
recover IPv4 address space which is under their administration. At
quarterly intervals, each RIR shall return any legacy address space
recovered, and may return any non-legacy address space recovered, to the
IANA in aggregated blocks of /24 or larger, for inclusion in the
recovered IPv4 pool.

During Phase I, no allocations will be made from the recovered IPv4
pool. Return of recovered address space (as described above) will
continue throughout Phase II.

B. Phase II: Allocation of Recovered IPv4 address space by the IANA

Upon ratification of this policy by the ICANN Board of Directors and a
declaration by the IANA that its existing free pool of unallocated IPv4
address space is depleted; Global Addressing Policy ASO-001-2 (adopted
by ICANN Board 8 April 2005) is rescinded. IANA will then commence to
allocate the IPv4 address space from the recovered IPv4 pool.

1. The following definitions apply to this policy:

a. Recovered Address Space. Recovered address space is that address
space that is returned to an RIR as a result of any activity that seeks
to reclaim unused address space or is voluntarily returned to the RIR or
is reclaimed by the RIR as a result of legal action or abuse
determination. Recovered address space does not include that address
space that is reclaimed because of non-payment of contractual fees whose
reclamation date is less than 1 year at the time of the report.

b. IPv4 Address Holdings. IPv4 address holdings are all unallocated IPv4
address space held by an RIR to include recovered address space not yet
returned less that address space that is committed in accordance with
the RIR's reservation policy and practices.

c. Legacy address space. IPv4 address space allocated or assigned prior
to the creation of the RIR.

2. Allocation of IPv4 Address Space

a. For the purposes of this policy, an 'IPv4 allocation period' is
defined as a 6-month period following 1 March or 1 September in each year.

b. At the beginning of each IPv4 allocation period, the IANA will
determine the 'IPv4 allocation unit' for that period, as 1/10 of its
IPv4 address pool, rounded down to the next CIDR (power-of-2) boundary.

c. In each allocation period, each RIR may issue one IPv4 request to the
IANA. Providing that the RIR satisfies the allocation criteria described
in paragraph B.2, the IANA will allocate a single allocation unit,
composed of the smallest possible number of blocks available in its IPv4
address pool.

3. IPv4 Address Space Allocation Criteria

A RIR is eligible to receive additional IPv4 address space from the IANA
when the total of its IPv4 address holdings is less than 50% of the
current IPv4 allocation unit, and providing that it has not already
received an IPv4 allocation from the IANA during the current IPv4
allocation period.

4. Initial Allocation of IPv4 Address Space

Each new RIR shall, at the moment of recognition, be allocated one (1)
allocation unit by the IANA. If an allocation unit is not available,
then the IANA will issue this block as soon as one is available. This
allocation will be made regardless of the newly formed RIR's projected
utilization figures and shall be independent of the IPv4 address space
that may have been transferred to the new RIR by the already existing
RIRs as part of the formal transition process.

5. Reporting

a. All returned space is to be recorded in an IANA-published log of IPv4
address space transactions, with each log entry detailing the returned
address block, the date of the return, and the returning RIR.

b. All allocated space is also to be recorded in this IANA-published log
of IPv4 address space transactions, with each log entry detailing the
address blocks, the date of the allocation and the recipient RIR.

c. The IANA will maintain a public registry of the current disposition
of all IPv4 address space, detailing all reservations and current
allocations and current IANA-held address space that is unallocated.

d) The IANA may make public announcements of IPv4 address block
transactions that occur under this policy. The IANA will make
appropriate modifications to the "Internet Protocol V4 Address Space"
page of the IANA website and may make announcements to its own
appropriate announcement lists. The IANA announcements will be limited
to which address ranges, the time of allocation and to which Registry
they have been allocated.