[arin-ppml] ARIN-prop-128: Replacement of Section 4.2.4.4

[David Farmer]

I do not support this proposal.  If there were strong data showing a 
high certainty that ARIN would have significantly more than a years 
supply of resources after IANA run-out, I might be convinced to change 
the trigger point from IANA run-out.  But that is not the argument 
provided in the rationale of this proposal.

Section 4.2.4.4 cannot be looked by itself, it is paired with section 
4.2.4.3. "Subscriber Members Less Than One Year", these subscribers are 
limited to a three month supply and have been for a long time.  I find 
it difficult to justify a continued disparity between these two classes 
of subscribers as we are on the verge of run-out of IPv4 resources.  If 
ARIN has less than a year of resources available, it will be impossible 
for subscribers currently covered by the first policy to ever receive 
resources from the ARIN free pool via the subsequent policy.

Proper stewardship of resources does not allow for a change in section 
4.2.4.3, but that 4.2.4.4 should be changed to rectify the above 
disparity in the face of IPv4 run-out.

In the discussion of Draft Policy 2009-8, it became clear that any 
trigger point before IANA run-out was unacceptable and there was a great 
deal of uncertainty about how long the ARIN free pool would last after 
IANA run-out.  This is why IANA run-out was selected as the trigger 
point for 2009-8.

ARIN has been consuming about three /8s for the last few years, so if 
the proposal's analysis is correct on that amount of resources ARIN will 
have after IANA run-out, one might be lead to believe ARIN could have as 
much as two years of resources available.  However, that does not 
account for any increased demand within the ARIN region as a reaction to 
run-out or any shift in demand that can reasonably be expected as other 
regions run-out, specifically APNIC and RIPE, which most projections 
show running out before ARIN.  Most projections I have seen do not show 
ARIN's post IANA run-out resources lasting significantly more than a year.

Therefore, I do not believe there is sufficient evidence that the basic 
facts of the situation have changed significantly enough to warrant 
changing the trigger point.

On 1/21/11 14:23 CST, ARIN wrote:
...
> ARIN-prop-128: Replacement of Section 4.2.4.4
>
> Proposal Originator: Martin Hannigan, Chris Grundemann
>
> Proposal Version: 1.0
>
> Date: 21 January 2011
>
> Proposal type: Modify, complete replacement of 4.2.4.4
>
> Policy term: Permanent
>
> Policy statement:
>
> 4.2.4.4. Subscriber Members After One Year
>
> After an organization has been a subscriber member of ARIN for one
> year,that organization may choose to request up to a 12 month supply of
> IP addresses.
>
> On the date that ARIN's IPv4 aggregate inventory of IPv4 address
> space drops below the equivalent of 2/8's and after ARIN receives its
> last /8 as a result of the IANA executing section 10.4.2.2 of the NRPM
> and in accordance with the Global Policy for the Allocation of the
> Remaining IPv4 Address Space, the length of supply that any organization
> may request from ARIN from that moment forward will be reduced to three
> months.
>
> Inventory is defined as all unused IPv4 addresses held by ARIN. This
> includes legacy address space which will be added to the available
> inventory and used after no longer than a one month hold period. Any
> addresses that the organization declares unavailable will be detailed
> publicly on a monthly basis that includes a detailed justification.
> Unavailable IPv4 addresses shall be considered to be an exception, not
> a rule.
>
> This reduction does not apply to resources received through the
> utilization of NRPM Section 8.3 of the NRPM. An organization receiving a
> transfer under NRPM Section 8.3 may continue to request up to a 12-month
> supply of IP addresses.
>
> Rationale:
>
> ARIN's pending operational practice is that if an organization has a
> request in the ARIN hostmaster queue for IPv4 resources when the IANA
> declares the exhaustion phase (10.4.2.2), their request will be
> automatically truncated from a twelve month supply to a three month
> supply since policy in effect at the time of exhaustion will apply. 8.3
> and 4.2.4.4 are currently "in effect".
>
> Example: If an entity is asking for 4 x /24 for a 12 month period and
> IANA exhaustion occurs, a requester will receive, if justified, 1 x /24.
> If an entity is asking for 120 x /24 at the time that exhaustion occurs,
> they would only receive 30 x /24 if justified. If ARIN determines that
> this same entity would only qualify for 90 of the 120 x /24 requested,
> then that entity would only receive 22 x /24.
>
> ARIN has the equivalent of approximately 7 /8's in their current
> inventory of address space equaling roughly 117M addresses. This
> includes addresses churning (revocations, returned), legacy addresses
> returned and the final /8 ARIN has received as a result of the execution
> of policy directing the IANA to exhaust inventory when it reaches 5 /8s.
>
> The intention of this proposal is simple. To define how as a community
> we will wind-down IPv4 inventory in an fair, orderly and predictable
> manner and to prevent the organization from being in a state of
> unreasonably stockpiling IPv4 addresses. It is also intends to insure
> that any confusion around legacy address utilization is clear; in the
> absence of a global policy dealing with this issue and need exists in
> the ARIN region any unused address in ARIN's inventory must be used.
>
> The ARIN AC should review and determine what action if any should be
> taken at their next available opportunity, or sooner if they deem
> warranted.

-- 
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David Farmer               Email:farmer at umn.edu
Networking & Telecommunication Services
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