[arin-ppml] Policy Proposal 110: Preservation of minimal IPv4 Resources for New and Small Organizations and for IPv6 Transition

[George, Wes E [NTK]]

I'm opposed to this proposal, and many of my reasons have already been articulated by others, especially Chris.

I think that the existing text of 4.10 stands on its own. When we're down to 1 /8 in the global pool, if any new orgs are attempting to offer services without IPv6 in a way that doesn't qualify them for space under 4.10 already, then we have every right to expect them to fail on account of their own short-sightedness. The lack of IPv4 space is going to be a barrier to entry for all sorts of business plans until IPv6 really has ubiquitous deployment, and I see no reason to try to give people false hope against that reality. As it is, we have 4.10, the pending 2010-1, and the transfer listings all to help cushion runout, as well as the potential of getting PA space from those that still have some.

Thanks,
Wes

-----Original Message-----
From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On Behalf Of Member Services
Sent: Thursday, April 22, 2010 2:47 PM
To: arin-ppml at arin.net
Subject: [arin-ppml] Policy Proposal 110: Preservation of minimal IPv4 Resources for New and Small Organizations and for IPv6 Transition

ARIN received the following policy proposal and is posting it to the
Public Policy Mailing List (PPML) in accordance with Policy Development
Process.

This proposal is in the first stage of the Policy Development Process.
ARIN staff will perform the Clarity and Understanding step. Staff does
not evaluate the proposal at this time, their goal is to make sure that
they understand the proposal and believe the community will as well.
Staff will report their results to the ARIN Advisory Council (AC) within
10 days.

The AC will review the proposal at their next regularly scheduled
meeting (if the period before the next regularly scheduled meeting is
less than 10 days, then the period may be extended to the subsequent
regularly scheduled meeting). The AC will decide how to utilize the
proposal and announce the decision to the PPML.

In the meantime, the AC invites everyone to comment on the proposal on
the PPML, particularly their support or non-support and the reasoning
behind their opinion. Such participation contributes to a thorough
vetting and provides important guidance to the AC in their deliberations.

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

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

Mailing list subscription information can be found
at: https://www.arin.net/mailing_lists/

Regards,

Member Services
American Registry for Internet Numbers (ARIN)


## * ##


Policy Proposal: Preservation of minimal IPv4 Resources for New and
Small Organizations and for IPv6 Transition

1. Proposal Originator: Joe Maimon

3. Proposal Version: 1

4. Date: 22 April 2010

5. Proposal type: New, Modify

6. Policy term: Permanent

7. Policy statement:

[Replace 4.10 in whole with the following.]

4.10 Minimum Allocations or Assignments from Reserved Pools

Upon execution of 10.4.2, ARIN will reserve pools of addresses
unavailable to fulfill any requests except as detailed in this section.
These pools will be utilized only for the minimal sized allocations or
assignments for properly justified requests, regardless of the size of
the request, under the following provisions, and only if ARIN is
otherwise unable to fulfill the request in entirety.

4.10.1 Affiliation of Organizations

To qualify under these sections organizations may be required to
demonstrate to reasonable satisfaction that they are not affiliated with
any other organizations for the intended purpose of qualifying under
these sections where they would not otherwise. All other aspects of
organization affiliations are not of specific concern to section

4.10.

4.10.2 Qualifying Organizations Request Fulfillment

Upon approval of an otherwise unfulfillable request, ARIN will determine
and notify the requester of section 4.10 applicability. Qualifying
organization may receive only one request fulfillment per three month
window from any of the pools defined in this section. Organizations may
decline to receive resources for their requests under these sections
without negating the request. Organizations who do receive resources
under these sections will have their request considered fully fulfilled
and completed.

4.10.3 Additional Efficiency Requirements

Additional to all policy requirements for request justification and
approval, the organization must not have inefficient utilization of
resources equivalent in aggregate to the resource otherwise available to
them via section 4.10 and all prior resources received under section
4.10 must continue to meet justification and initial requirements.

4.10.4 (Un)availability of Transfers

Resources granted under section 4.10 will not be available for transfer
under 8.3 and may be subject to additional scrutiny for transfers under
8.2 to ensure that the use of the resources continue to meet initial
policy requirements.

4.10.5 Reserved Pools creation and Replenishment

The following Pools will be created for reserved resources. Upon
complete consumption of any defined pool resources, it will be
replenished, if or when resources to do so become available, at the same
ratio of initial reservation from the resources available via 10.4.2,
but not to exceed the initial sizes. ARIN is encouraged to manage
resources as they become available to anticipate this need and to
attempt for maximum aggregation. Each of the pools, and preferably all,
must be contained within a single prefix.

4.10.5.1 New Entrants Pool

A pool, initially sized at /10, available for organizations who do not
hold any Direct ARIN or Legacy IPv4 resources.

4.10.5.2 Small Organization Growth Pool

A pool, initially sized at /11, available for organizations that are
current holders of Direct ARIN or Legacy IPv4 resources, but no larger
in total than 16 times the minimal allocations size.

4.10.5.3 Pools for IPv6 Migration

These pools, described in 4.10.5.3.1 and 4.10.5.3.2, are for allocations
and assignments which must be justified by immediate IPv6 deployment
requirements.

Allocations and assignments will have a minimal unit of /28 and a
maximum unit of /24 without any concern for prevailing normative routing
policies.

4.10.5.3.1 Small Organization IPv6 Migration Pool

A pool, initially sized at /12, available for organization that are
current holders of  Direct ARIN or Legacy IPv4 resources, but no larger
in total than 64 times the minimal allocation size.

4.10.5.3.2 Multihomed Organization IPv6 Migration Pool

A pool, initially sized at /12, available only for multihomed
organizations who would not otherwise qualify for any resources except
as per 4.10.5.3 and could not otherwise meet their need with any other
PI resources available.

4.10.5.3.3 Examples of Immediate IPv6 Deployment Requirements

Examples of such needs include IPv4 addresses for dual stacking key
servers such as DNS, content load balancers, firewalls, key routers and
gateways, or for translators such as NAT-PT or NAT464 and for similar
published standard purposes.

4.10.5.3.4 Subsequent Allocations from Migration to IPv6 Pools

Organizations receiving resources from these pools must not hold more
than two prefixes from these pools at any time. ARIN should size the
subsequent resource to permit the organization to renumber out of the
previous resources from this pool, if prefix expansion is unavailable.
To minimize the need for renumbering, ARIN should use sparse allocation
strategies for the 4.10.5.3 pools.

4.10.6 Reserved Pools Usage Reporting

Annual statistics and reporting will be available on the utilization of
these pools, including but not limited to, total utilization, requests
fulfilled, declined requests, requests refused by category of rejection
cause and number of organizations who have received multiple allocations
under any portion of this section.

4.10.7 Policy Duration

No part of 4.10 will be active before execution of 10.4.2, after which
time and upon ARIN determination that there is no longer any significant
use of any of the pools for a period of two years,  this section will
cease to be active and may be removed, aside from 4.10.8. ARIN may
remove any pool defined by this section if there is no activity for that
pool for any period of four years following activation. No portion of
Section 4.10, other than 4.10.8,  will apply to allocations from a pool
subsequent to the pool's removal.

4.10.8 Pool Prefix List Publication

ARIN will publish a list of all pool prefixes with active resources,
with the minimum and maximum prefix size allocated from the pool.


##### Rationale: #####

This proposal is intended to apply both to ISP's and to End Users and
only for IPv4 resources. This proposal intends to expand upon the
concepts originally introduced into policy section 4.10 by merging
sections 4.10 requirements and intended uses, with some modifications,
along with additional pool definitions. It can coexist with other
proposals, providing the availability of the requested sizes for the
reserved pools are preserved in combination with any other policy. Other
proposals that modify minimum allocation sizes and justification
requirements will have indirect effects on the clauses of this section.
This is intentional.

The rationale has a short and long version.

Short Version:

As per data currently available, a /9 would fuel current burn rate for
approximately two months which is ridiculously short. This burn time
could be exchanged as a reasonable and small price to pay to receive in
return a number of years of access for new organizations and lifeblood
for organizations on their way to migration to IPv6.

This proposal believes it is incumbent on ARIN and its community, as an
integral portion of its stewardship duties, to make its best good faith
effort to lessen the impact depletion will have on all, but especially
on the under-served.

Long Version:

The long version is divided into two sections. One section will provide
rationale for the entire proposal as a whole. The other will provide
rationale for each individual sub-section.

The rationale is intentionally overly verbose.

A) Rationale for the Proposal as a Whole:

This proposal is founded on the belief that there is a strong likelihood
that IPv4 service and interoperability will remain of critical
importance for new or growing small organizations, as well as large
established organizations, for quite some time after IANA free pool
depletion.

It is expected that those who believe otherwise should have no
objections to this proposal, since it would effectively be a no-op.

The pools in total will comprise /9, which is half of the /8 allocated
under 10.4.2, which represents the end of IPv4 availability based solely
on need.

A /9 burn rate is less than two months according to current statistics.
This proposal believes we can make better use of a /9 other than two
months additional burn.

With a minimal allocation of /22 or /20 this proposal should provide
some years of space available for the organizations described under 4.10

A /9 would not suffice the needs of organizations not described under
4.10 and it is expected that the minimal resources available under 4.10
are easily obtainable by the categories of organizations who do not
qualify under 4.10, either from existing resources or from transfers
allowed under section 8.3 These resources are not intended for use by an
organization attempting to grow any existing IPv4 customer base to the
exclusion of IPv6. It is unlikely that they will get very far by
attempting to do so.

These resources are not intended for use by an organization with sizable
direct allocations or legacy IPv4 resources. Non ARIN RIR resources are
not addressed by policy, but perhaps should be excluded as well.

The proposal is structured in such a way as to reduce some potential
unfair advantages larger incumbents will have post IANA free pool
runout, while not subjecting them to overly unfair unavailability of
resources.

This proposal is not specifically targeted as to address any historical
imbalance, perceived or otherwise, between large and small organizations.

ARIN staff is requested to provide some estimated projections numbers,
with the intention being to be able to answer questions of this nature
in order to obtain a clear view as to the alternatives to the proposal
and the effect the proposal may have.

- How many Xlarge member organizations not qualifying under section 4.10
would have their requests satisfied by a /9 and for how long?

- How many Large member organizations not qualifying under section 4.10
would have their requests satisfied by a /9 and for how long?

- How many Medium member organizations not qualifying under section 4.10
would have their requests satisfied by a /9 and for how long?

- How many Small member organizations not qualifying under section 4.10
would have their requests satisfied by a /9 and for how long?

- To how many organizations and for how long could section 4.10.5.1 apply?

- To how many organizations and for how long could section 4.10.5.2 apply?

- To how many organizations and for how long could section 4.10.5.3.1 apply?

- To how many organizations and for how long could section 4.10.5.3.2 apply?

The size of the pools, the three month window and the size of existing
resource relative to the requested resources are semi-arbitrarily
chosen, the goal is to obtain 5 years or more of resources under these
policies, while not consuming more than a /9. ARIN staff
projections/estimated would be very helpful in refining those numbers.

Other than the 4.10.5.3 pools, these numbers are also very dependent on
the governing minimal allocation sizes, which can be as small as /22.
For example, that would provide for 4000 new organizations under 4.10.5.1

It is expected that opposition to this proposal can fall into one of
many categories, indication of which category opposition falls into will
be welcome, such as the following.

- Opposition to size of pools, length of windows, size of existing
resources.

- Opposition to the number of pools or any of the specific pools purposes.

- Opposition towards any of the specific details and restrictions of
this proposed policy.

- Opposition in general towards changing ARIN policies with regards to
allocation of IPv4 resources in response to IANA free pool depletion.

- Opposition in general towards changing ARIN policies specifically in
this manner.

Any and all feedback is welcome.


B) Rationale per Individual Sub-Section:

4.10 Minimum Allocations or Assignments from Reserved Pools

Free pool runout spells the end of needs based allocation available for
all. This proposal refines the idea of need to include those who need it
more than others, and attempts to preserve needs based allocation
availability for as long as possible for as many organizations with
acute need as possible.

Excluding the possibility of huge returns of IPv4 resources to ARIN,
this is the only way that needs-based allocation remains directly
relevant for any extended degree of time following IANA free pool runout
along with subsequent RIR depletion, and the end of general availability
of IPv4 resources.

The resources described as available under these sections are trivial in
size to any organization not meeting these sections definitions.

As further justification for this proposal, these pools will dissuade
hoarding and artificial scarcity which could otherwise arise if the only
other  availability of any IPv4 resources was under section 8 transfer
mechanisms or other non policy mechanisms.

4.10.1 Affiliation of Organizations

This provision is designed to give ARIN the power to prevent
organizations who otherwise would not qualify, from constructing
relationships with organizations for the purposes of taking advantage of
the resources those organizations would now qualify and receive under
section 4.10

It would be ARIN responsibility to tailor its threshold of reasonable
demonstration of un-affiliation as they see fit to conform with the
intent of this provision.

4.10.2 Qualifying Organizations Request Fulfillment

Organizations will not be forced to accept allocations from these pools,
but instead can take advantage of any other policy mechanism available,
such as waiting lists or transfers. However, if they do accept
fulfillment of the request under 4.10, the request is considered over
and done with and they must create a new one for any further need.

This section makes it ARIN's responsibility to perform a first pass on
the request and to extend the opportunity to the organization to request
fulfillment of their otherwise unfulfillable request from pools defined
under section 4.10

Only at that point will the organization need to show qualifications and
conformance with the provisions of 4.10

The goal here is to minimize the complexity involved in the application
process for organizations, since ARIN should be able to form a decent
impression on the likelihood of successful application of section 4.10
without the organization specifically requesting it.

The window is designed to prevent organizations from collecting from all
pools at once or in rapid succession.

4.10.3 Additional Efficiency Requirements

Organizations are to be prevented from taking advantage of these
sections if their utilization, while otherwise justified,  is
inefficient enough that equivalent resources are internally available.

4.10.4 (Un)availability of Transfers

Transfers of resources obtained under 4.10 without the accompanying
services utilizing them is incompatible with the goals as described, and
should be strongly discouraged.

4.10.5 Reserved Pools creation and Replenishment

If it works well ARIN should do more of it, if it possibly can.

4.10.5.1 New Entrants Pool

It is part of ARIN obligations of  IPv4 stewardship to attempt to
preserve the ability for new organizations to enter the IPv4 marketplace
for as long as it exists. If IPv4 resources are no longer generally
available, either from ARIN or otherwise, existing large resource
holders could be viewed as a cartel or consortium of incumbents
passively or actively preventing entrance to new organizations. ARIN
could also be viewed as a contributing cause for this undesirable situation.

There is no more acute need for IPv4 resources than those of an
organization who has none and still needs to provide critical services
for interoperability with an IPv4 internet even while focusing on the
more available IPv6. This assumes that for the general market, an IPv6
only provider may not be applicable for quite some time.

Inaction on good stewardship objectives creates non technical liabilities.

4.10.5.2 Small Organization Growth Pool

Organizations of very small size will have limited ability to stay in
business long enough to migrate to IPv6 if they cannot meet even a
limited portion of growth of their

IPv4 population. As an example, a minimal allocation under this policy
of /20 to /22 to an organization with a total of /16 to /18 allows them
6 percent growth.

Percentages smaller than that are not likely to be of much benefit.

For this size organization, there is very little likelyhood that
internal scavenging or other mechanisms will be practical and available
for them to otherwise continue to survive the migration to IPv6.

These organizations may also not be prepared enough to qualify under
4.10.5.3

Larger sized organizations growth objectives could not be met by ARIN at
this point for any significant percentage point no matter what, and they
would be more likely to have mechanisms available to obtain the
equivalent resources available under this policy, whereas the new or
small organizations may not.

ARIN stewardship responsibilities include all reasonable attempts to
address the upcoming scenario where large organizations can take
advantage of the crunch time between IPv4 and IPv6 wider utilization to
drive smaller competitors out of business by passively denying them
number resources available to the larger organization trivially from
other sources than ARIN, internal or external to the organization.

4.10.5.3 Pools for IPv6 Migration

The needs of an organization for IPv4 resources to migrate to IPv6
should take precedence over the needs of an organization trying to grow
their IPv4 utilization regardless of the industries need to migrate to IPv6.

Smaller organizations may feel particularly unable to proceed with IPv6
migration at any faster pace than the larger incumbent organizations.

This is consistent with ARIN goals of encouraging migration to IPv6 and
it is proper stewardship of IPv4 resources to prefer to satisify the
needs of the organization who are doing this activity than the needs of
the organizations who are not.

The size restriction is based on the assumption that organizations who
are the holders of that much more resources can obtain the limited
resources available via this section through other means . For example
if the minimal allocation is a /22 section this restriction limits
organizations who hold a /16. If the minimum allocation is /20,
organizations with more than /14 are restricted.

With either size allocated space, it should not be all that difficult
for an organization to scavenge up a /22 or /20.

ARIN encouragement of successful migration to IPv6 can result in return
of IPv4 resources available for all, so everybody wins.

As operators insist that ARIN does not set routing policies, applicants
who can only justify the minimum space /28 will get that, and routing it
is up to them. It is expected that no organization will be requesting
/28 unless it is actually routable and unobtainable anyother way, so
this clause is for a doomsday scenario.

4.10.5.3.1 Small Organization IPv6 Migration Pool

This pool is restricted to small organizations who are unlikely to have
the resources available otherwise.

4.10.5.3.2 Multihomed Organization IPv6 Migration Pool

This pool is explicitly available to any multihomed organization who
cannot otherwise qualify for resources. If an organization was only able
to claim that they need IPv4 to migrate and that they had no space, they
would automatically qualify for a minimal allocation of /28, if they
wanted it. The intent is to eliminate any concern that there is barrier
to entry and allows organizations to be able get something no matter how
small.

4.10.5.3.4 Subsequent Allocations from Migration to IPv6 Pools

This contains some examples of migration uses. This is not intended to
be exhaustive. ARIN staff may exercise their discretion. It is not
expected that there should be any need for them to be zealous, the small
size of the resources available should be dissuasive enough.

4.10.5.3.4 Subsequent Allocations from Migration to IPv6 Pools

This sections requires that subsequent allocations from this policy
require a renumber and return.

4.10.6 Reserved Pools Usage Reporting

The reporting that ARIN performs is critically important to help ARIN
members and policy participants to understand the effect of policy and
to identify problematic patterns. The report data may reveal that pools
are being underutilized or overutilized or misutilized and could prompt
policy action to correct the utilization  patterns.

This will allow the community as a whole to perform reviews on this policy.

4.10.7 Policy Duration

This policy is fairly complex and places burden on ARIN staff. If IPv6
transition or other factors combine to cause this pools defined to be
unused for an extended period of time, ARIN should be able to remove it.
If all of them are inactive, then this policy is obsolete and should be
removable. It is intended that pools continue to be documented
historically for route filter assistance.

4.10.8 Pool Prefix List Publication

While ARIN refrains from directly influencing or controlling routing
policy, ARIN should be encouraged to take steps to allow routing
operators to make informed decisions with their routing policies. This
section puts into writing something that ARIN performs normally.


Timetable for implementation: Simultaneously with execution of 10.4.2






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