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

[Owen DeLong]

On Aug 7, 2010, at 5:14 PM, Scott Leibrand wrote:

> 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.
> 
Noted... Will incorporate that in the next rev.

>> 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?
> 
I think it is infeasible to put a 90% requirement on pre-4.10 allocations and
assignments unless we changed some of the mechanisms for counting
utilization. I think this could place an undue burden on some providers as
it would represent a radical ex-post-facto shift in the way they've allocated
addresses to their customers prior to runout.

I'm not opposed to this change personally, but, I would expect some
opposition from the community and wouldn't want such opposition to reduce
the consensus on the rest of this proposal.

I encourage others to provide feedback (positive or negative on this idea).

>> 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?
> 
I would consider those to be covered under "other transitional DNS enablers", but, I can easily add that to the list if you feel it's helpful.
I've basically tried to write this section such that it gives staff the clearest possible statement of the intent of the policy and will of the
community while not preventing innovation in this area or creating unnecessary limits on legitimate uses of the space for actual
transitional technologies.

More community guidance here would be very useful.

Did you intentionally cut e off below your signature? (Note it is an important part of the intent of this section).

> 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.

Owen