[arin-ppml] Updated text for ARIN 2014-16: Section 4.10 Austerity Policy Update

Koch, Andrew andrew.koch at tdstelecom.com
Wed Sep 24 17:23:48 EDT 2014

On Sep 18, 2014, at 00:11, Alexander, Daniel <Daniel_Alexander at Cable.Comcast.com> wrote:
> Hello All,
> There has been an update to the text of ARIN2014-16: Section 4.10
> Austerity Policy Update. Based upon previous feedback and suggestions
> there has been substantial changes to the original text. This new text is
> included below and will be discussed at the upcoming meeting in Baltimore.
> Feedback is welcome and encouraged.
> Thanks,
> Dan Alexander
> Proposal Shepherd
> Short summary of proposed changes
> and changes to original text
> =================================
> 1) Adds an additional Austerity option to section 4.10 in addition to the
> transition technology, rather than the original approach of replacing the
> transition technology section.
> 2) Shrinks the minimum transition technology pool from the existing /10 to
> a /11.

I do not agree with this action.  I would like to see the transition technology pool remain a /10, and possibly increase with the IANA returned blocks.

> 3) Defines the new requirements for getting an assignment under the
> proposed Austerity section.
> 4) Directs resources obtained by ARIN under section 10.5 to supply
> assignments for section 4.10 requests.

While this directs 10.5 additional address space to 4.10 generally, it is not proposed on how this is to be divided.  As individual pools are being proposed, I believe there should be detail on how 10.5 allocations from the IANA are handled.  For example "each 10.5 allocation received from the IANA will be divided equally between the pools crated in the sections of 4.10."

> Updated Text
> ==============================
> Policy statement:
> Replace Section 4.10 with the following policy.
> 4.10 Dedicated IPv4 block to facilitate IPv6 Deployment
> When ARIN receives its last /8 IPv4 allocation from IANA, a contiguous /10
> IPv4 block will be set aside and dedicated to facilitate IPv6 deployment
> and continued transition from IPv4 to IPv6.
> Address space received from IANA under the "Global Policy for Post
> Exhaustion IPv4 Allocation Mechanisms by the IANA (NRPM 10.5)" by ARIN
> shall be allocated or assigned under this section.
> Allocations and assignments from this block must be justified by immediate
> IPv6 deployment requirements. ARIN shall use sparse allocation within
> these blocks.
> 4.10.1 Austerity Policy
> Organizations must obtain an IPv6 block to receive a block under section
> 4.10.1 and show documentation on how the IPv6 and IPv4 block will be used
> to facilitate an organization¹s operational needs. These allocations or
> assignments will be subject to a minimum size of /28 and a maximum size of
> /22.
> In order to receive an allocation or assignment under this policy:
> 1. the organization, its parent(s), or subsidiary organizations, may not
> have received IPv4 address resources greater than or equal to a /22 from
> ARIN or any other RIR;

Referring to anything beyond the organization will give concern here.  How many levels of hierarchy are being referred to?  Using the Wikipedia article on Tiered subsidiaries as an example (ignoring the fact that this is a UK subsidiary) (http://en.wikipedia.org/wiki/Subsidiary#Tiered_subsidiaries):
Ford Motor Company - U.S. parent company based in in Dearborn, Michigan
Ford International Capital LLC - First-tier subsidiary (U.S. holding company located in Dearborn, Michigan, but registered in Delaware)
Blue Oval Holdings - Second-tier subsidiary (British holding company, located at the Ford UK head office in Brentwood, Essex, with five employees)
Ford Motor Company Limited - Third-tier subsidiary (the main British Ford company, with head office in Brentwood, with 10,500 employees
Ford Component Sales Limited - Fourth-tier subsidiary (small British specialist component sales company at the UK Ford head office, with some 30 employees)

If Ford Component Sales Limited came for addresses under this section, would ARIN only look at Ford Motor Company Limited, or all the way back up to Ford Motor Company?

Additionally, to root out all parent and subsidiary companies may be troublesome for ARIN to complete.  We may need to wait for the staff report on this policy, but I feel that this is going to be too difficult for them to effectively handle.

> 2. the organization must show immediate use (within 90 days) of 25% of the
> allocation;
> 3. the organization is eligible to receive only one contiguous IPv4 block
> under this section;
> 4. the organization may apply to ARIN for an increase in their allocation
> up to a /22, if the previous allocation under this section shows a
> utilization of at least 80%, increases will only be granted if adjacent
> bit-boundary aligned space is available at the time of request.

I do not agree with this section.  If an organization needs to return for additional space, they may have been unlucky in the draw and the adjoining space may not be available.  I would like to see adjacent bit-boundary space be assigned if available, but the organization should not be excluded if a larger sized block is available and they must renumber (the same as the existing 4.10 language).

I would not be opposed to completely eliminating  This would allow an organization to be eligible for only one single block issued from this section.

One item that is not addressed in 4.10 today, nor in the proposed policy, is transferability of addresses.  Should policy state that addresses in this section be exempt from 8.3 & 8.4 transfers?  While 8.3 and 8.4 have a minimum transfer size of /24, both sections allow up-to or larger than this minimum.  Both 8.3 & 8.4 place a 12 month restriction following address issuance - is this sufficient?


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