[arin-ppml] Integrating Draft Policy ARIN-2011-1 into NRPM 8.3

Fri May 27 11:11:21 EDT 2011

Mike,

Please don't cherry-pick the guidance of RFC 2050.

It also says, more pertinent and fundamental to the issues of transfers
and efficiency....

1. Introduction
   Internet address space is distributed according to the following
   three goals:

1) Conservation: Fair distribution of globally unique Internet address
space according to the operational needs of the end-users and Internet
Service Providers operating networks using this address space.
Prevention of stockpiling in order to maximize the lifetime of the
Internet address space.
   2) Routability: Distribution of globally unique Internet addresses
   in a hierarchical manner, permitting the routing scalability of
   the addresses. This scalability is necessary to ensure proper
   operation of Internet routing, although it must be stressed that
   routability is in no way guaranteed with the allocation or
   assignment of IPv4 addresses.

   3) Registration: Provision of a public registry documenting address
   space allocation and assignment.  This is necessary to ensure
   uniqueness and to provide information for Internet trouble shooting
   at all levels.

Conservation is the first principle, registration services is a primary
duty of the RIR, to be sure, but its goals are not record keeping 
alone, but for the purposes of achieving the goals otherwise described.

Moreover, 
3.1  Common Registry Requirements

   Because the number of available IP addresses on the Internet is
   limited, the utilization rate of address space will be a key factor
   in network number assignment.  Therefore, in the best interest of the
   Internet as a whole, specific guidelines have been created to govern
   the assignment of addresses based on utilization rates.

   Although topological issues may make exceptions necessary, the basic
   criteria that should be met to receive network numbers are listed
   below:

                25% immediate utilization rate
                50% utilization  rate within 1 year

   The utilization rate above is to be used as a guideline, there may be
   be occasions when the 1 year rate does not fall exactly in this
   range.  Organizations must exhibit a high confidence level in its 1
   year utilization rate and supply documentation to justify the level
   of confidence.

   Organizations will be assigned address space based on immediate
   utilization plus 1 year projected utilization.  A prefix longer than
   /24 may be issued if deemed appropriate.  Organizations with less
   than 128 hosts will not be issued an IP address directly from the
   IRs.  Organizations may be issued a prefix longer than /24 if the
   organization can provide documentation from a registry recognized ISP
   indicating the ISP will accept the long prefix for injection into the
   global routing system.

   Exceptions to the criteria will not be made based on insufficient
   equipment without additional detailed justification.  Organizations
   should implement variable length subnet mask (VLSM) internally to
   maximize the effective utilization of address space.  Address
   assignments will be made under the assumption that VLSM is or will be
   implemented.

   IP addresses are valid as long as the criteria continues to be met.
   The IANA reserves the right to invalidate any IP assignments once it
   is determined the the requirement for the address space no longer
   exists.  In the event of address invalidation, reasonable efforts
   will be made by the appropriate registry to inform the organization
   that the addresses have been returned to the free pool of IPv4
   address space.

4.  Operational Guidelines For Registries
   7.  The transfer of IP addresses from one party to another must be
       approved by the regional registries.  The party trying to obtain
       the IP address must meet the same criteria as if they were
       requesting an IP address directly from the IR.

Clearly, the guidelines call for efficient utilization by entities that
have need and can justtify the need
and transfers would be according to local policies of RIRs....which have
all agreed to conform to these principles.
bd

________________________________

	From: Mike Burns [mailto:mike at nationwideinc.com] 
	Sent: Friday, May 27, 2011 9:16 AM
	To: Bill Darte; Chris Grundemann
	Cc: ARIN-PPML List
	Subject: Re: [arin-ppml] Integrating Draft Policy ARIN-2011-1
into NRPM 8.3

	Hi Bill,

	It's still not clear to me.
	Referencing "values" of an RFC is not terribly clarifying when
attempting to match transfer needs requirements which already are out of
sync with RFC2050's 1 year window.

	And anyway, I say that requiring a needs test is *NOT*
consistent with the values expressed here in RFC2050:

	4.  Operational Guidelines For Registries

	   1.  Regional Registries provide registration services as its
	       primary function.

	By requiring a needs test for inter-RIR transfers, we run the
risk of driving these transfers off the books in contravention of our
PRIMARY function as stewards.

	Just so we all understand. 
	APNIC has a great need, and probably less underutilized
addresses in its market to supply that need.
	A good chunk of available space is likely to be found in the
legacy pools which are overrepresented in our region.
	The majority of this legacy space is not under any RSA with any
RIR.

	You can route legacy space from inside Asia.

	A likely action that will occur is the purchases of address
blocks from legacy holders which will be routed in Asia by network
operators there, but ARIN will not be notified and Whois will not be
updated.

	I have said that I think we are moving into a future with more,
rather than less, conflict over IPv4 address control. This is only to be
expected, as the availability of free pool addresses has always provided
a replacement option for any addresses in conflict. In addition, the
underlying monetary value of address control, once understood, provides
ample motive to drive conflict.

	In an age of conflict, the accuracy of Whois will be related to
the level of trust afforded to it. The absence of a strong trust
authority could open the doors to a private registry.

	Suppose there is conflict between private organizations over
address control.  Then add to that conflict between RIRs over which
registry is the authoritative. What is to stop a real international
trust authority, say Lloyds of London, from using its trust to establish
a pricey but generally recognized registry?

	Or even worse, what if the door is opened to the ITU to claim
the RIR system was failing in a post-exhaust era, and seek to create its
own registry system, or otherwise take control?

	Once again, I make the point that a market in IPv4 addresses,
such as envisaged in 8.3 or in the APNIC transfer policy, meets the
stewardship goal of conservation through natural market forces.
	If we ladle on an extra helping of steward meddling, we are
taking action in contravention of our primary duty to maintain a viable
and trusted registry.

	So I would support the proposal if the requirement was simply
that both RIRs approve, leaving off the "signal" sent by the needs
language, which signal reads like a shot across the bow to me.

	Regards,

	Mike

		----- Original Message ----- 
		From: Bill Darte <mailto:BillD at cait.wustl.edu>  
		To: Mike Burns <mailto:mike at nationwideinc.com>  ; Chris
Grundemann <mailto:cgrundemann at gmail.com>  
		Cc: ARIN-PPML List <mailto:arin-ppml at arin.net>  
		Sent: Friday, May 27, 2011 7:38 AM
		Subject: RE: [arin-ppml] Integrating Draft Policy
ARIN-2011-1 into NRPM 8.3

		The word you say is subjective...'compatible'... in the
DP is interpreted by..
		'that exercise Internet stewardship consistent with the
values expressed in RFC2050'

		-----Original Message-----
		From: arin-ppml-bounces at arin.net on behalf of Mike Burns
		Sent: Thu 5/26/2011 4:28 PM
		To: Chris Grundemann
		Cc: ARIN-PPML List
		Subject: Re: [arin-ppml] Integrating Draft Policy
ARIN-2011-1 into NRPM 8.3

		> What is to be gained by including that language,
except to engender
		> Inter-RIR conflict?
		> The wording already includes both RIRs to approve the
transfer.
		> There is no definition in the policy or elsewhere in
the NRPM of
		> "compatible" needs policies.
		> I don't see the point in including it.

		The point of that statement is to signal the intentions
of the ARIN
		community both to ARIN staff and to other RIRs. It
provides guidance
		to ARIN staff that they should not agree to any transfer
that does not
		include needs-based policy on the recipient end. It also
ensures that
		recipients in other regions will not be surprised when a
transfer is
		denied for lack of said needs-based policies. The point,
in short, is
		clarity and transparency.

		Cheers,
		~Chris

		Hi Chris,

		But how clear is it exactly?
		Do you mean it to signal that *any* needs test is
compatible?
		If that is the intent, then I think the language can be
clearer.
		If you want clarity, then using a subjective word like
"compatible" which is
		undefined in the proposal is sub-optimal.
		Since its definition and application is left to ARIN
staff, and ARIN staff
		is required to decide on transfer approval anyway, I
don't see any great
		clarity or transparency.
		What I do see reads like a political statement added
onto a policy proposal,
		to no real effect except to exacerbate inter-RIR
tensions.
		What better way to incite the APNIC stewards to
unilaterally decide to
		accept transfers into their region of legacy space with
no RSA in place?
		This is currently a lacuna in policy awaiting a test
case, as far as I know.

		It's not like there are hundreds of different transfer
policies, I'm sure
		those requesting inter-RIR transfers will be aware of
the current policies
		without brandishing our disdain for their version of
stewardship in
		additional and functionally inoperative language.

		Regards,
		Mike

		_______________________________________________
		PPML
		You are receiving this message because you are
subscribed to
		the ARIN Public Policy Mailing List
(ARIN-PPML at arin.net).
		Unsubscribe or manage your mailing list subscription at:
		http://lists.arin.net/mailman/listinfo/arin-ppml
		Please contact info at arin.net if you experience any
issues.

-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://lists.arin.net/pipermail/arin-ppml/attachments/20110527/ac12d72c/attachment.htm>