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

[Scott Leibrand]

As the primary AC shepherd for this proposal, I'd like to give a little 
more background on the changes we made to the originators' original 
proposed text.

The main concern expressed with this proposal to date is that it 
requires ARIN to return recovered address space to IANA, thereby 
removing most of the incentive for ARIN to recover that space in the 
first place.  In addition, there were a number of concerns expressed 
about unnecessarily splitting up the blocks allocated to ARIN, when ARIN 
could simply reassign any returned space out to new recipients.

To address these concerns, I see a couple of options.  One would be to 
make the return of recovered space completely optional.  This might be 
best for ARIN, but might also make the policy all but useless.  It would 
also raise global issues of fairness, since ARIN holds most of the 
legacy address space allocated before ARIN existed.  So another option 
would be to require return of recovered legacy address space, while 
making return of non-legacy space optional.  The latter is the option 
reflected in the text below:

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

    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.

In addition, we added the following, which is intended to be a 
clarification, but may reflect a different understanding of the phases:

    Return of recovered address space (as described above) will continue 
throughout Phase II. 

I would love to get feedback from PPML on the following questions:

 - What do you think of the general idea behind this proposal?
 - Do you think returns should be mandatory or optional?  Would you 
distinguish between legacy and non-legacy space?
 - Do you have any other detailed feedback on specific aspects of this 
draft policy?

Thanks,
Scott

Member Services wrote:
> 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.
>
>
>
>
>
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