[arin-ppml] Draft Policy ARIN-2013-4: RIR Principles
Andrew Dul
andrew.dul at quark.net
Thu May 30 13:25:27 EDT 2013
Hi Jason,
On 5/28/2013 9:04 PM, Jason Schiller wrote:
> Andrew thanks for your feed back.
>
> I want to point out that much of this language comes from either
> RFC-2050 or the current PDP or NRPM. I tired to change the language
> as little as possible, except where we have commonly agreed on new
> language such as "efficient utilization" instead of conservation. I
> thought that might be the most uncontroversial starting point. I am
> not opposed to changing it, especially if it makes the text less
> controversial.
>
I didn't have any of those docs in front of me when reviewing the
proposal, so I didn't specifically note they were "existing policy
text." In general, I'm in favor of reusing text where it makes sense. I
will say that there probably always is room for improvement, and 2050 is
now pretty dated so updating the language to be more relevant to today's
practices & principles is probably a step forward.
> ---
>
> WRT the LIR/ISP I agree, we should adopt whatever we think the
> standard term should be.
>
> ---
>
> WRT using number resources instead of IP address space I would have to
> take a careful look and make sure we are not applying principles that
> make sense with respect IP addressing to ASNs if they don't make
> sense. It is not clear to me if you think these changes should be
> throughout the text, or only in section 0.1.
I probably wasn't totally consistent in my initial comments. Since this
is "RIR Principles" I believe this policy proposal should refer in
general to number resources unless the statements directly apply only to
a subset of Internet number resources.
>
> ---
>
> Andrew writes:
> > I think this section [0.1. Efficient utilization based on need
> (Conservation)]
> > should have an explicit reference to the difference
> > in conservation techniques for IPv4 and IPv6. A proposed sentence might
> > be something like this... "Conservation goals may vary due to the
> > technical differences between IP number resources pools, for example the
> > relatively limited size of the IPv4 address pool causes a desire to see
> > the number space more highly utilized compared to the vast availability
> > of IP numbers within the IPv6 address pool."
>
> I made a conscious effort to keep this text in section 0.4 for clarity.
>
> From the draf policy section 0.4:
> "For example, efficient utilization becomes a more prominent issue
> than aggregation as the IPv4 free pool depletes and IPv4 resource
> availability in any transfer market decreases. Conversely, because the
> IPv6 number space is orders of magnitude larger than the IPv4 number
> space, the scale tips away from efficient utilization towards
> hierarchical aggregation for IPv6 number resources."
>
> Does that text fulfill your suggestion of "Conservation goals may vary
> due to the technical differences between IP number resources pools,
> for example the relatively limited size of the IPv4 address pool
> causes a desire to see the number space more highly utilized compared
> to the vast availability of IP numbers within the IPv6 address pool."
>
> Do you have concerns about where this text is located?
>
I realized later that I inserted similar "IPv4 is different that IPv6"
into multiple sections, since I thought it applied in unique ways to
each section. Perhaps for clarity it should only be in section 0.4
Stewardship, since this is the section that talks about balance between
different elements and goals? I'm also OK with it being only in one
section, but I would want it to somehow illuminate specifically that
conservation varies based on number resource.
Perhaps just add the statement w/o example? "Conservation goals may
vary due to the technical differences between IP number resources pools."
Not a showstopper for me, if it isn't in 0.1.
Building on Bill's comments in his notes, I think there might be room
toward using the term sustainability in these principles. That term is
well known in "corporate speak" and might be closer to the RIR's goals &
principles compared with other words.
> ---
>
> Andrew writes:
> > "Utilization rate of address space will be an important factor in
> > justifying need for IP number resources. However, utilization rates
> > will vary due to the technical differences (e.g. IPv4 vs. IPv6) between
> > number resource pools."
>
> Again, I made a conscious effort to keep this text in section 0.4 for
> clarity, and would quote the same text.
>
> Does that meet your concern about your proposed text?
>
> Do you have concerns about where this text is located?
Perhaps just keeping it all in 0.4 is best.
>
> Should I repeat the paragraph in 0.1, 0.1.1, and 0.4?
>
I wouldn't repeat the paragraph.
> ---
> Andrew writes:
> >> In order to promote increased usage of Internet number resources,
> >> resource holders will be required to provide an accounting of
> >> resources currently held demonstrating efficient utilization. Internet
> >> number resources are valid as long as the criteria continues to be
> >> met. The transfer of Internet number resources from one party to
> >> another must be approved by the regional registries. The party trying
> >> to obtain the resources must meet the same criteria as if they were
> >> requesting resources directly from the IR.
> >>
> >> All Internet number resource requests are subject to audit and
> >> verification by any means deemed appropriate by the regional registry.
> >>
> >
> > I suspect the above two paragraphs may be lightning rods against the
> > policy proposal. May I suggest the following single paragraph in lieu
> > of the above two paragraphs.
> >
> > In order meet the Principles and Goals of the Internet Registry System,
> > resource holders may be required from time to time to provide an
> > accounting and current usage of resources currently held. The RIRs
> > shall set policies to define these accounting mythologies as part of
> > their community driven policy process.
>
> I'm not sure why you think these two paragraphs are lightening rods.
>
> RFC-2050 3.3 says:
> "To promote increased usage of address space, the registries will
> require an accounting of address space previously assigned to the
> enterprise, if any."
I believe including text that says orgs must keep records of how the use
address space is totally appropriate. Record keeping doesn't
necessarily "proposed increased usage" but does provide accountability
and transparency which I believe should be one of the goals of the
registry system.
>
> RFC-2050 3.1 says:
>
> "IP addresses are valid as long as the criteria continues to be met."
One might construe this statement to directly invalidate existing legacy
allocations which would now be in ARIN's policy through this policy.
Others might be worried that this opens the door wider to changing
policy to retroactively revoke allocations or assignments by changing
"criteria". Furthermore, I believe this idea is already handled by
existing NRPM text and the RSA.
> RFC-2050 4.7 says
>
>
> "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."
>
I believe this "policy" element is best handled in the details section
of the NRPM rather than the principles section. ARIN's policies already
define transfers. Having a generic "RIRs shall determine IP number
resources transfer policies through their community drive policy
development process." might be a good addition to this proposal.
> RFC-2050 4.4 says:
> "All IP address requests are subject to audit and verification
> by any means deemed appropriate by the regional registry."
>
I just remember for multiple years discussing policy 2007-14 & others
when we put into policy existing auditing and review practices. Since
ARIN's policies and RSA already talk about audit procedures, I also
thought this was not necessary. The language "by any means deemed
appropriate by the regional registry" is a wide open door that many I
believe won't like. By using text to say auditing is done by the
community through adopted policy you limit an RIR's auditing to
specifically what the community wants the registry to do.
> And there is lots of text about conservation in RFC-2050 and
> efficient utilization in the NRPM.
>
> Can you elaborate on the lightening rod potin?
>
See above comments.
> I can only guess you are suggesting that the community wants
> to depart from the principles in RFC-2050, but think you must
> mean something else.
>
> What am I missing here?
>
Hopefully my comments above illuminate the concerns I had about the
text. Basically it comes down to "modernizing" the 2050
text/principles, and keeping principles in the principles section and
not putting specific policy in the principles section.
>
> Andrew writes:
> >> 0.2. Hierarchical aggregation (Routability)
> >>
> >> Policies for managing Internet number resources must support
> >> distribution of globally unique Internet addresses in a hierarchical
> >> manner, permitting the routing scalability of the addresses.
> >
> > Should the RIR's goals be "LISP agnostic"? That is if LISP becomes the
> > predominant routing methodology in the future, one would not necessarily
> > expect the goals of the RIRs to change.
> >
> > Suggested change to end of first sentence.
> >
> > ... permitting the routing scalability of the addresses as required by
> > the current technical limitations of global routing protocols.
>
> I think this change is good even w/o considering LISP.
> Imagine we have new holographic memory that can hold orders of
> magnitude more data and decrease read time
>
> ---
>
> Andrew writes:
> >
> >> 0.3. Uniqueness (Registration)
> >>
> >> c) to ensure that a provider has exhausted a majority of
> >> its current CIDR allocation, thereby justifying an additional
> >> allocation d) to assist in IP allocation studies.
> >
> > Suggested revision for "C"
> >
> > to allow a LIR to demonstrate and disclose reassignment of IP number
> > resources to third-parties
>
> I think the point is to demonstrate reassignment data to
> demonstrate efficient utilization.
> But I also think that point is covered in section 0.1.1, So the
> rewrite here is ok.
>
> ---
>
> Andrew writes:
> > Perhaps add a statement specifically about Stewardship
> >
> > "Stewardship of IP number resources is the balance of overseeing and
> > protecting the interests of all Internet stakeholders to further the
> > development and expansion of the Internet and the Internet Registry
> System."
>
> I do not oppose this text.
>
> Andrew also writes...
> >
> > justified need as a conflicting goal should be explicitly mentioned.
> >
> > "It should be noted that efficient utilization, justified need, and
> >hierarchical aggregation are often conflicting goals."
>
> I'm not sure this parses correctly... This sounds to me like there are
> conflicts between all three:
>
> efficient utilization vs justified need vs hierarchical aggregation.
>
> How about:
> "It should be noted that efficient utilization based on justified
> need, and
> hierarchical aggregation are often conflicting goals."
>
>
>
> -
>
>
> On Tue, May 28, 2013 at 2:19 PM, Andrew Dul <andrew.dul at quark.net
> <mailto:andrew.dul at quark.net>> wrote:
>
> I support adding these guiding principles to the NRPM, furthermore I
> would support efforts to introduce this policy in all RIR regions to
> make this a global policy.
>
> Comments on the proposed text in-line below.
>
> Andrew
>
> On 5/17/2013 9:53 AM, ARIN wrote:
> > Draft Policy ARIN-2013-4
> > RIR Principles
> >
> > On 16 May 2013 the ARIN Advisory Council (AC) accepted
> "ARIN-prop-187
> > RIR Principles" as a Draft Policy.
> >
> > Draft Policy ARIN-2013-4 is below and can be found at:
> > https://www.arin.net/policy/proposals/2013_4.html
> >
> >
> > ## * ##
> >
> >
> > Draft Policy ARIN-2013-4
> > RIR Principles
> >
> > Date: 17 May 2013
> >
> > Problem Statement:
> >
> > The original text in RFC 2050 both "describes the registry
> system for
> > the distribution of globally unique Internet address space and
> > registry operations" and provides "rules and guidelines [principles]
> > governing the distribution of this address space."
> >
> > The currently proposed update (RFC2050bis) "provides information
> about
> > the current Internet Numbers Registry System used in the
> distribution
> > of globally unique Internet Protocol (IP) address space and
> autonomous
> > system (AS) numbers" and "provides information about the
> processes for
> > further evolution of the Internet Numbers Registry System."
> >
> > This means that the guiding principles of stewardship are not
> > currently being carried forward into the new document. The goals of
> > Conservation (efficient utilization based on need), Routability
> > (hierarchical aggregation), and Registration (uniqueness) are as
> > important, if not more so, now that the transition to IPv6 is
> upon us.
> > This can be rectified by documenting these principles in RIR policy.
> >
> > Policy Statement:
> >
> > Section 0: Principles and Goals of the Internet Registry System
> >
> > 0.1. Efficient utilization based on need (Conservation)
> >
> > Policies for managing Internet number resources must support 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. The registry should
> > prevent stockpiling in order to maximize the conservation and
> > efficient utilization of the Internet address space.
>
> This section should use the new proposed convention of "LIR/ISP" as
> being developed in ARIN-2013-5.
>
> s/this address space/IP number resources/r
> s/Internet address space/IP number resources/r
>
> I think this section should have an explicit reference to the
> difference
> in conservation techniques for IPv4 and IPv6. A proposed sentence
> might
> be something like this... "Conservation goals may vary due to the
> technical differences between IP number resources pools, for
> example the
> relatively limited size of the IPv4 address pool causes a desire
> to see
> the number space more highly utilized compared to the vast
> availability
> of IP numbers within the IPv6 address pool."
>
> >
> > 0.1.1. Documented Justified Need (Needs Based)
> >
> > Assignment of Internet number resources is based on documented
> > operational need. Utilization rate of address space will be a key
> > factor in number resource assignment. To this end, registrants
> should
> > have documented justified need available for each assignment.
> > Organizations will be assigned resources based on immediate
> > utilization plus expected utilization.
>
> Utilization rate is much more important for IPv4 than IPv6.
>
> Suggested revision for "Utilization rate of address space will be
> a key
> factor in number resource assignment."
>
> "Utilization rate of address space will be an important factor in
> justifying need for IP number resources. However, utilization rates
> will vary due to the technical differences (e.g. IPv4 vs. IPv6)
> between
> number resource pools."
>
> >
> > In order to promote increased usage of Internet number resources,
> > resource holders will be required to provide an accounting of
> > resources currently held demonstrating efficient utilization.
> Internet
> > number resources are valid as long as the criteria continues to be
> > met. The transfer of Internet number resources from one party to
> > another must be approved by the regional registries. The party
> trying
> > to obtain the resources must meet the same criteria as if they were
> > requesting resources directly from the IR.
> >
> > All Internet number resource requests are subject to audit and
> > verification by any means deemed appropriate by the regional
> registry.
> >
>
> I suspect the above two paragraphs may be lightning rods against the
> policy proposal. May I suggest the following single paragraph in
> lieu
> of the above two paragraphs.
>
> In order meet the Principles and Goals of the Internet Registry
> System,
> resource holders may be required from time to time to provide an
> accounting and current usage of resources currently held. The RIRs
> shall set policies to define these accounting mythologies as part of
> their community driven policy process.
>
>
> > 0.2. Hierarchical aggregation (Routability)
> >
> > Policies for managing Internet number resources must support
> > 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.
> >
>
> Should the RIR's goals be "LISP agnostic"? That is if LISP
> becomes the
> predominant routing methodology in the future, one would not
> necessarily
> expect the goals of the RIRs to change.
>
> Suggested change to end of first sentence.
>
> ... permitting the routing scalability of the addresses as required by
> the current technical limitations of global routing protocols.
>
> > 0.3. Uniqueness (Registration)
> >
> > Provision of a public registry documenting Internet number resource
> > allocation, reallocation, assignment, and reassignment is
> necessary to:
> >
> > a) ensure uniqueness and to to provide operational staff with
> > information on who is using the number resource b) to provide a
> > contact in case of operational/security problems (e.g. Law
> > Enforcement) c) to ensure that a provider has exhausted a
> majority of
> > its current CIDR allocation, thereby justifying an additional
> > allocation d) to assist in IP allocation studies.
>
> Suggested revision for "C"
>
> to allow a LIR to demonstrate and disclose reassignment of IP number
> resources to third-parties
>
> >
> > It is imperative that reassignment information be submitted in a
> > prompt and efficient manner to facilitate database maintenance and
> > ensure database integrity.
> >
> > 0.4. Stewardship
> >
> > It should be noted that efficient utilization and hierarchical
> > aggregation are often conflicting goals. All the above goals may
> > sometimes be in conflict with the interests of individual
> end-users or
> > Internet Service Providers. Care must be taken to ensure balance
> with
> > these conflicting goals given the resource availability,
> relative size
> > of the resource, and number resource specific technical
> dynamics, for
> > each type of number resource. For example, efficient utilization
> > becomes a more prominent issue than aggregation as the IPv4 free
> pool
> > depletes and IPv4 resource availability in any transfer market
> > decreases. Conversely, because the IPv6 number space is orders of
> > magnitude larger than the IPv4 number space, the scale tips away
> from
> > efficient utilization towards hierarchical aggregation for IPv6
> number
> > resources.
>
> Perhaps add a statement specifically about Stewardship
>
> "Stewardship of IP number resources is the balance of overseeing and
> protecting the interests of all Internet stakeholders to further the
> development and expansion of the Internet and the Internet
> Registry System."
>
> Also...
>
> justified need as a conflicting goal should be explicitly mentioned.
>
> "It should be noted that efficient utilization, justified need, and
> hierarchical aggregation are often conflicting goals."
>
> Use the new LIR/ISP convention instead of "Internet Service Providers"
>
>
>
> >
> > Comments:
> >
> > a. Timetable for implementation: immediately
> >
> > b. I believe that it would be beneficial for IANA to adopt these
> > principles as well, and encourage the community to consider a global
> > policy proposal.
> > _______________________________________________
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>
> --
> _______________________________________________________
> Jason Schiller|NetOps|jschiller at google.com
> <mailto:jschiller at google.com>|571-266-0006
>
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