[arin-ppml] Draft Policy 2010-13: Permitted Uses of space reserved under NRPM 4.10

[Scott Leibrand]

On Wed 8/4/2010 2:23 PM, ARIN wrote:
>
> Draft Policy 2010-13
> Permitted Uses of space reserved under NRPM 4.10

I think this proposal is moving in the right direction (and apparently 
toward consensus).  A few questions and discussion points inline below...

> Version/Date: 4 August 2010
>
> Policy statement:
>
> Amend section 4.10 replacing "...a contiguous /10 IPv4 block..." with
> "...that /8..." and replacing "...within that /10 block." with "within
> this /8."
>
> Add the following to section 4.10 of the NRPM
>
> 6. Under this policy, applications must be for one of two types of
> transitional uses, declared at time of application.
>   (a) An ISP/LIR may request a block not less than a /24 nor more than
> a /18 

The /18 maximum conflicts with the second paragraph of the existing 4.10 
(which specifies a /24 maximum).  You should probably update that 
paragraph as well.

> to be used to provide single IPv4 /32s to their customers which
> could justify a /28 or more of IPv4 under ARIN policies in effect at the
> time ARIN received this reserved block from IANA.
>    1. No customer may receive more than a single IPv4 /32 under this
> provision.
>    2. The customer must not have any other IPv4 allocations or
> assignments from the provider at the time of this assignment.
>    3. The customer must not have any direct assignments from ARIN at
> the time of this assignment.
>    4. The customer must not have more than a single IPv4 /32 from any
> other provider at the time of this assignment.
>    5. The customer must have IPv6 space with native IPv6 connectivity
> to the ISP/LIR and must be making use of IPv6 within their network.
>    6. The total of all allocations by ARIN under this provision shall
> not be allowed to consume more than 3/4 of the /8 (the equivalent of a
> /9 + a /10).
>    7. No organization shall receive more than a total of a /16 or
> equivalent under this section.
>
> or (b) An ISP/LIR or End user organization may request not less than a
> /28 and not more than a /24 for purposes relevant to their ability
> to deploy IPv6 as specified in section 4.12.
>    1. No organization shall receive more than a total of a /20 or
> equivalent under this section.
>    2. Space issued under this policy is an assignment, not an
> allocation. An LIR may not distribute this space to their customers.
>
> 7. For purposes of section 4.10.1, separate times shall be considered
> for 4.10.6(a) vs. 4.10.6(b). An organization may make applications for
> both types within 6 months.
>
> 8. Other than transfers under NRPM section 8, all space returned to ARIN
> after IANA depletion shall either be returned to IANA or shall be added
> to the reserved pool created by 4.10.1.
>
> Add the following to section 4 of the NRPM
>
> 4.11 Required utilization for subsequent allocation under section 4.10
>
> No organization shall receive more than one allocation or assignment
> under section 4.10 unless all prior space issued under 4.10 meets the
> utilization requirements of this section:
>
> 1. The most recent 4.10 allocation/assignment must be at least 80% 
> utilized.
> 2. All utilization must be permitted under section 4.12
> 3. All prior 4.10 allocation/assignments must be at least 90% utilized.

Is there any reason to limit this requirement to just 4.10 allocations 
and assignments?  If we struck 4.10 there, and require that "All prior  
allocation/assignments must be at least 90% utilized", would that be better?

> 4. For purposes of this computation, space received under 4.10(a) shall
> be considered separately from space received under 4.10(b) if an
> organization has received resources of both types.
>
> 4.12 Permitted uses of allocations or assignments under section 4.10(b)
>
> No organization shall use space received under section 4.10 for any
> purpose other than as specified in this section
>
> 1. To provide the required public IPv4 address(es) for transitional
> technologies operated by the recipient organization.
> a. Large scale or "Carrier Grade" NAT
> b. NAT-PT
> c. DS-LITE/B4/AFTeR
> d. DNS64 or other transitional DNS enablers

The existing 4.10 language mentions "key dual stack DNS servers", but 
you don't mention that here.  Can you elaborate on what you think should 
be allowed there?

Thanks,
Scott

> e. For other technologies of similar purpose and scope.
>
> 2. For other transitional technologies not envisioned at the time of
> this proposal, but, in no case for general IPv4 addressing provided to
> customers.
>
> 4.13 Quarterly Utilization Monitoring
>
> Allocations and assignments under section 4.10 shall be subject to
> quarterly verification of utilization.
>
> 1. An organization which is not meeting their utilization targets may
> have their allocation or assignment reduced accordingly with the
> reclaimed portions going back to ARIN for distribution to other
> organizations. Space reclaimed in this manner shall be exempt from any
> requirement to return space to the IANA.
> 2. An organization which is using space received under 4.10 in a manner
> contrary to 4.10 et seq. may have their allocation or assignment reduced
> or revoked with reclaimed portions going back to ARIN for distribution
> to other organizations. Space reclaimed in this manner shall be exempt
> from any requirement to return space to the IANA.
>
> Rationale:
>
> The current terminology in section 4.10 is vague and could allow a
> variety of interpretations which could lead to allocations or
> assignments being made to ISPs intending to misuse the space for general
> deployment by using IPv6 overlay technologies as a "IPv6 deployments"
> requiring IPv4 space for transition. For example, the current policy
> could be interpreted to enable an ISP to require IPv4 addresses for all
> IPv6 customers to roll IPv6 out as 6rd to customers who would be
> otherwise unable to get IPv4 space. This is clearly outside of the
> original intent of the proposal which created 4.10 (6rd was not yet
> envisioned at the time that was written). This proposal seeks to clarify
> that intent and tighten up the requirements for organizations seeking to
> get space from this limited final resource so that it truly is available
> to facilitate transitional technologies.
>
> Timetable for implementation: immediate
>
> For reference, here is the current text of 4.10
>
> 4.10 Dedicated IPv4 block to facilitate IPv6 Deployment
>
> When ARIN receives its last /8 IPv4 allocation from IANA, a contiguous
> /10 IPv4 block will be set aside and dedicated to facilitate IPv6
> deployment. Allocations and assignments from this block must be
> justified by immediate IPv6 deployment requirements. Examples of such
> needs include: IPv4 addresses for key dual stack DNS servers, and NAT-PT
> or NAT464 translators. ARIN staff will use their discretion when
> evaluating justifications.
>
> This block will be subject to a minimum size allocation of /28 and a
> maximum size allocation of /24. ARIN should use sparse allocation when
> possible within that /10 block.
>
> In order to receive an allocation or assignment under this policy:
> 1. the applicant may not have received resources under this policy in
> the preceding six months;
> 2. previous allocations/assignments under this policy must continue to
> meet the justification requirements of this policy;
> 3. previous allocations/assignments under this policy must meet the
> utilization requirements of end user assignments;
> 4. the applicant must demonstrate that no other allocations or
> assignments will meet this need;
> 5. on subsequent allocation under this policy, ARIN staff may require
> applicants to renumber out of previously allocated / assigned space
> under this policy in order to minimize non-contiguous allocations.
>
>
>
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