[arin-ppml] Draft Policy ARIN-2012-7: Reassignments for Third Party Internet Access (TPIA) over Cable

[ARIN]

Draft Policy ARIN-2012-7
Reassignments for Third Party Internet Access (TPIA) over Cable

On 16 August 2012 the ARIN Advisory Council (AC) selected "Reassignments 
for Third Party Internet Access (TPIA) over Cable" as a  draft policy 
for adoption discussion on the PPML and at the Public Policy Meeting in 
Dallas in October.

The draft was developed by the AC from policy proposal "ARIN-prop-179 
Reassignments for Third Party Internet Access (TPIA) over Cable." Per 
the Policy Development Process, the AC submitted text to ARIN for a 
staff and legal assessment prior to its selection as a draft policy. 
Below the draft policy is the ARIN staff and legal assessment with the 
text that was reviewed. The text did not change after the assessment.

Draft Policy ARIN-2012-7 is below and can be found at:
https://www.arin.net/policy/proposals/2012_7.html

You are encouraged to discuss Draft Policy 2012-7 on the PPML prior to 
the October Public Policy Meeting. Discussion on the list and at ARIN 
XXX will be used by the ARIN Advisory Council to determine community 
consensus for adopting this as policy.

The ARIN Policy Development Process can be found at:
https://www.arin.net/policy/pdp.html

Draft Policies and Proposals under discussion can be found at:
https://www.arin.net/policy/proposals/index.html

Regards,

Member Services
American Registry for Internet Numbers (ARIN)


## * ##


Draft Policy ARIN-2012-7
Reassignments for Third Party Internet Access (TPIA) over Cable

Date: 5 September 2012

Policy statement:

Insert new section to NRPM to read as follows:
4.2.3.8 Reassignments for Third Party Internet Access (TPIA) over Cable
When IP address resources are reassigned by an ISP to an underlying 
cable carrier for use with TPIA, those addresses shall be deemed as 
utilized once they are assigned to equipment by the underlying cable 
carrier.

Rationale:
A unique situation exists particularly, and perhaps only, in the 
Canadian region that is preventing legitimate ISPs from obtaining 
subsequent allocations of IPv4 addresses for use with the Third Party 
Internet Access (TPIA) framework that has been mandated by the CRTC 
(Canada's version of the FCC).  Adding this section to the NRPM will 
allow ISPs that intend to make use of this CRTC mandated framework to 
obtain the number resources that they require but are currently unable 
to obtain.

Timetable for implementation: immediate


##########


ARIN STAFF ASSESSMENT

ARIN-prop-179 Reassignments for Third Party Internet Access (TPIA) over
Cable

Date of Assessment: 3 August 2012

1. Summary (Staff Understanding)

This draft policy would allow TPIA providers to assign addresses to
incumbent cablecos and have ARIN count individual pools as used for the
purposes of reviewing an additional address space request from the TPIA
provider.

2. Comments

A. ARIN Staff Comments

     This policy proposal would solve a problem that the Canadian TPIA
providers are currently facing. There's a math problem they've come up
against which is otherwise unsolvable. Current policy provides no way 
for TPIA providers to put more space where its needed when its needed,
especially when one market area grows disproportionately to other market
areas. If a TPIA deployment goes to 30 market areas, and 7 of those grow
very quickly and use up the space they were assigned, the TPIA provider
has no way of coming back to ARIN successfully to get more space for 
those 7 market areas.  Under the current incumbent cableco rules, they 
cannot re-provision any under-utilized blocks from other market areas.

     The community might also want to examine NRPM 4.2.3.7.3.1 and ask
whether the same principles might be applied to TPIA utilization.  The
required 50% utilization rate serves as a mechanism to ensure ISPs 
achieve a reasonable level of efficiency when provisioning IP addresses 
across their network. Staff would suggest that the following additions 
be considered in order to align this policy proposal with existing 
policy utilization requirements:

         IP addresses reassigned by an ISP to an incumbent cable operator
for use with Third Party Internet Access (TPIA) will be counted as fully
used once they are assigned to equipment by the underlying cable carrier
provided they meet the following requirements:

    * initial assignments to each piece of hardware represent the
smallest subnet reasonably required to deploy service to the customer 
base served by the hardware

    * additional assignments to each piece of hardware are made
only when all previous assignments to that specific piece of hardware 
are at least 80% used and represent a three month supply.

B. ARIN General Counsel

This policy poses a first of its kind and deserves comment from a legal
perspective-this proposal responds to a single sovereign nation's
regulatory ruling (Canada) and regards only a single named service. It 
is valid for ARIN to make a policy that responds to a single country's
regulatory issues, but the community should take care to consider the
circumstances in general to make policy as widely applicable as 
possible. When doing so the authors, community (and counsel) should 
undertake a heightened duty to examine how the policy will impact ARIN 
members operations in other countries.  Counsel is not aware of any 
significant legal issues posed for ARIN members in other countries at 
this juncture.

3. Resource Impact

This policy would have minimal resource impact from an implementation
aspect.  It is estimated that implementation would occur within 3 months
after ratification by the ARIN Board of Trustees. The following would be
needed in order to implement:

Updated guidelines and procedures


4. Proposal Text

ARIN-prop-179 Reassignments for Third Party Internet Access (TPIA) over
Cable

Date: 27 July 27 2012

Policy statement:

Insert new section to NRPM to read as follows:
4.2.3.8 Reassignments for Third Party Internet Access (TPIA) over Cable
When IP address resources are reassigned by an ISP to an underlying cable
carrier for use with TPIA, those addresses shall be deemed as utilized
once they are assigned to equipment by the underlying cable carrier.

Rationale:
A unique situation exists particularly, and perhaps only, in the Canadian
region that is preventing legitimate ISPs from obtaining subsequent
allocations of IPv4 addresses for use with the Third Party Internet Access
(TPIA) framework that has been mandated by the CRTC (Canada's version of
the FCC).  Adding this section to the NRPM will allow ISPs that intend to
make use of this CRTC mandated framework to obtain the number resources
that they require but are currently unable to obtain.

Timetable for implementation: immediate