[arin-ppml] Is Emergency action warranted for Policy Proposal 123: Reserved Pool for Critical Infrastructure?

Eric Brunner-Williams ebw at abenaki.wabanaki.net
Wed Dec 22 19:33:35 EST 2010

On 12/22/10 7:14 PM, David Farmer wrote:
> As several others have already done, I want to thank you for bringing
> your perspective to this discussion. I have a few comments and
> questions in-line below.
> On 12/21/10 18:55 CST, Eric Brunner-Williams wrote:
>> Colleagues,
>> I'd like this proposal to be approved. I've discussed it with Marty at
>> the Cartegena ICANN meeting two weeks ago.
> I take your comments as supporting the policy proposal in general, and
> note that the AC accepted this proposal on to its docket and I expect
> we will follow ARIN's normal policy development process and have a
> draft policy for discussion at the April Public Policy Meeting in San
> Juan. However the subject line for your email "Is Emergency action
> warranted for Policy Proposal 123: Reserved Pool for Critical
> Infrastructure?" could suggest you support emergency action beyond
> this. So, my question is do you believe emergency actions is necessary
> for this proposal? If so, what and why?

I should have made my comments prior to the 16th. The subject line was 
simply the subject line that existed prior to the 16th. My comments 
are supporting the policy proposal in general, and are intended only 
to inform the AC of a use case for which 123 meets a specific "new", 
but apparently recurring, CI need.

>> My concern is that new registry proposants who meet the criteria for
>> assistance under the current JAS WG Milestone [1], or future work
>> product of the JAS WG, are, under the current ICANN Draft Applicant
>> Guidebook, required to be v6 capable. This is a cost that can be
>> deferred, if 123 becomes ARIN policy, at least for the ARIN region, and
>> if imitated by the other RIR's, more broadly.
> The issue of post run-out CI has come up on some of other RIR's policy
> mailing lists and I would like to suggest that those discussion could
> equally benefit from your perspective. So, I encourage you to
> participate those discussion or raise the issue within the other RIR's
> policy processes and mailing lists too.

Thank you.

>> The v6 capability is independent of the regional addressing
>> infrastructure availability local to the registry infrastructure,
>> registrars, or registrants.
>> The case for exempting applicants meeting the Milestone et seq.
>> criteria
>> for assistance, or any larger class of new, or new and existing,
>> registry operators, from a near-term v6 capability requirement could be
>> supported by the existence of a critical infrastructure address pool,
>> allowing transition over a multi-quarter period, with address recovery
>> for subsequent transitional allocation.
> As others have commented, I don't think IPv6 is that much of an
> additional technical burden for a CI deployment, and should be fairly
> easy. However, I have experience with IPv6 and little if any
> experience with CI deployments. Also, I imagine there are many other
> things that such a new registry would probably need/want to focus on
> before IPv6. Therefore, I wouldn't want to ICANN to eliminate any IPv6
> requirements, but maybe they shouldn't be primary decision factors
> either.

There are more important issues for new registry operators, yet all of 
the laundry list of issues, as contractual compliance issues, are, at 
the moment, of equal value, and no rational applicant could afford to 
act on operational issue priority before acting on contractual 
compliance issues.

There are several "requirements" in the current Draft Applicant 
Guidebook that may be made less restrictive, or more restrictive, 
through the public comments process. This is only one, and not the 
most onerous, but it is one in which the merits of the requirement are 
a policy issue of a distinct policy making body.

Eric Brunner-Williams
member, JAS WG

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