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

[Azinger, Marla]

The only way to even attempt having a textual version that all RIR's can agree on would be to actively seek out input from the community of the RIR's and injecting the input before submitting it for Global consideration (non just select members who's names appear on the proposal).  The route this policy took was straight from authors and directly to submission and never took into consideration input from community members.  So the back lash of skipping the community is now being felt. Now community input is coming out after the formal submission to all the RIR's and this basically doubles the difficulty of achieving any consensus on a policy that reads the same in all RIR's.

There may not be a "Global PDP" but it sure would help to post any global idea to the different RIR communities first.  Then incorporate their input into one proposal that includes a rational that explains what regions required particular text in the proposal if its not blatantly clear in the proposal itself. Then proceed to submit the official proposal version to each RIR.

Cheers
Marla Azinger



-----Original Message-----
From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On Behalf Of Heather Schiller
Sent: Monday, March 30, 2009 4:07 PM
To: raul at lacnic.net
Cc: arin-ppml at arin.net
Subject: Re: [arin-ppml] Draft Policy 2009-3 (Global): Allocation of IPv4 Blocks to Regional Internet Registries


raul at lacnic.net wrote:
> Dear all:
>
> This proposal is a proposal for a global policy. It means that the
> same proposal has to be approved in every region. They can be approved
> with some wording differences, but the spirit of the proposal should
> be the same.


Today there is no global or local mechanism to keep the policy text the same as it is discussed across regions.  Every region is entitled to make changes in accordance with their PDP.  The current ARIN PDP gives the AC the flexibility to modify text, with or without input from the authors.  Without a distinction that "Global Policies" should be handled differently the AC is within it's right to act in the best interest of it's community and modify text accordingly.

To be blunt, I think this is a failing across the RIR's - there should be some mechanism to handle "Global Policies" differently.  The other issue is on the flipside - once a "Global Policy" has been passed, there is nothing preventing any one region from changing it.  So any process for handling "Global Policies" should lock the text and require future revisions to go through a "Global PDP".

>
> The proposal was the result of a long collaboration effort of senior
> staff members and board members of all the 5 RIRs and the original
> text is the one that is being considered in every region.
>

APNIC changed the text at their meeting in February:

http://www.apnic.net/policy/proposals/prop-069-v002.html

"Consensus reached at APNIC 27 in Manila, Philippines. See Version 3 for proposal text that incorporates the feedback from APNIC 27."

Would it be fair for other RIR's to complain that the text changed at the APNIC meeting?


> As far as I know the authors of the proposal were not consulted by the
> ARIN-AC and based on exchanges among the authors in the past few days,
> I can say that in general the feeling is that the changes introduced
> by the ARIN-AC are very signficant and so, this is a different proposal.

As far as I know none of the other regions were consulted before the changes that were made from the APNIC meeting.  The results of the changes were distributed to the other RIR's after the fact.  You are already changing the text as it's in progress being discussed throughout the regions.

There was significant feedback against this proposal in the ARIN region.
  The AC took in feedback from the mailing list, and in accordance with the PDP, changed the text in advance, in order for it to stand a better chance vs waiting for the meeting, letting it get pummeled, and either being shelved or being revised and having to go through another policy cycle. The latter would have delayed the entire process, in our region and others, since the revisions would have to go back to APNIC and other RIR's for approval.  The process for getting a "global policy" through all 5 regions is long enough to begin with.

>
> My personal view is that changing the concept of a global policy
> proposal in one RIR means to avoid the approval of the policy. I
> strongly encourage ARIN to put the original proposal under
> consideration of its community as it is being done in the other
> regions. The proposal can be approved or not, That's part of the
> process, but it doesn't make sense to approve a different proposal.
> IMHO, the AC is able to put forward the new proposal for discussion if
> they consider that it is better, and in that way to start the process of discussion of a new global policy proposal.
>
> I have to confess that dealing with 5 different PDPs is not so easy. I
> don't know if a petition process should be started, If yes, please
> take this email as the request for initiating that process.

Here is a link to the ARIN PDP:
https://www.arin.net/policy/pdp.html

Section 2.4 covers the petition process.  You can't say "I don't know if a petition process should be started, If yes, please take this email as the request for initiating that process."  Who are you asking to decide?
  It's up to you (or someone else in the community) to decide whether or not to initiate the petition process, no one is going to do it for you.


>
> Since this announcement was issued last Monday in the afternoon, I am
> not sure how the business days are counted, but I guess that I am
> still within the valid period.
>
> However, I think that as a practices, global policy proposals should
> not be changed by any advisory council or policy chair of one region
> due to the impact that to change the proposal produce in the global process.
>

Our region's current procedure allows us to make such changes.  As you are a member of the EC I would encourage you to work with your fellow RIR's to close this loophole by developing a process to handle Global Policies and to utilize the ASO AC to shepherd policy throughout the 5 regions.



>
> Best Regards,
>
> Raúl
>
>
>
> ---------------
>
>
>
> El 23/03/2009, a las 04:05 p.m., Member Services escribió:
>
> 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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