[arin-ppml] LAST CALL - Recommended Draft Policy ARIN-2021-2: Special Use IPv4 Space Out of Scope for Purposes of Determining Waitlist Eligibility

[Martin Hannigan]

No opinion either way other than to add that its not certain that IXPs or
TLD's need "special" address space. These carve-outs were created in
consideration of exhaustion. They guaranteed that the classes would not be
caught in the crossfire of expected transition to IPv6 and lack of supply.
The reality is there's nothing special about it. It's IPv4. In the case of
IXPs there is some history and religious argument around ease of filtering.
Ok. Nothing wrong with the change overall. Better wording would future
proof this policy and simply say resources assigned to IXP's or TLD's for
the "special" use might be excluded. $0.02  At some point we may want to
reclaim those "special pools".

I also realize this is late to the game. Day job.

Warm regards,

-M<





On Tue, Dec 21, 2021 at 2:04 PM ARIN <info at arin.net> wrote:

> On 16 December 2021, the ARIN Advisory Council (AC) sent the following
> Recommended Draft Policy to Last Call:
>
>
>
> * ARIN-2021-2: Special Use IPv4 Space Out of Scope for Purposes of
> Determining Waitlist Eligibility
>
>
>
> Feedback is encouraged during the Last Call period. All comments should be
> provided to the Public Policy Mailing List. Last Call will expire on 6
> January 2022, taking into account two US federal holidays.
>
>
>
> The Recommended Draft Policy text is below and available at:
>
> https://www.arin.net/participate/policy/drafts/2021_2/
>
>
>
> The ARIN Policy Development Process is available at:
>
> https://www.arin.net/participate/policy/pdp/
>
>
>
> Regards,
>
>
>
> Sean Hopkins
>
> Senior Policy Analyst
>
> American Registry for Internet Numbers (ARIN)
>
>
>
>
>
>
>
> Recommended Draft Policy ARIN-2021-2: Clarify and Update 4.2.1.2 Annual
> Renewal Fee
>
>
>
> AC Assessment of Conformance with the Principles of Internet Number
> Resource Policy:
>
>
>
> This Recommended Draft Policy is technically sound and is fair and
> impartial number policy. The intent of the policy is to revise section
> 4.1.8 of the NRPM to explicitly exclude space issued under 4.4 and
> 4.10frombeing considered when staff are weighing the total holdings of an
> org from the v4 wait list.
>
>
>
> Problem Statement:
>
>
>
> Eligibility for number resources is based on demonstrated need. In NRPM
> Section 4, IPv4 demonstrated need is furcated into three categories:
> ordinary use addresses for ISPs and end users (sections 4.2 and 4.3),
> special use addresses for critical infrastructure (section 4.4). and
> special use addresses for facilitation of IPv6 deployment (section 4.10).
>
>
>
> Documentation of need for each category of addresses has always been
> evaluated without respect for address holdings and utilization of other
> address categories. For instance a TLD operator could get more section 4.4
> space for new TLD customers by showing an MOU with ICANN without having to
> speak to efficient use of its back office section 4.3 space. Likewise, an
> organization that operated multiple internet exchanges each with a
> comparatively small number of participants could show efficient use of its
> section 4.3 back office space and get more under the standard demonstrated
> need policy despite the fact that its internet exchanges were nowhere near
> full, thus driving their host density ratio sufficiently low across all
> their holdings that if they were taken in aggregate they could not possibly
> meet the requirements to justify more space. Furthermore, an organization
> that needed address space for IPv6 transition under section 4.10 had those
> requirements evaluated irrespective of its current holdings and/or
> efficient utilization.
>
>
>
> The current wording of section 4.1.8 (ARIN Waitlist) begins “ARIN will
> only issue future IPv4 assignments/allocations (excluding 4.4 and 4.10
> space) from the ARIN Waitlist.”, a nod to the fact that there is space held
> in reserve for this type of special use. However a couple of sentences
> later, “Organizations which hold more than a /20 equivalent of IPv4 space
> in aggregate are not eligible to apply.” suggests that special use space
> might count against an organization wishing to apply for waitlist space
> despite the fact that based on the terms of its issuance 4.4 and 4.10 space
> is not to be used for general purposes. Either of the types of
> organizations described above could easily fall into the corner case of
> having enough special use space to preclude getting ordinary use space via
> the waitlist.
>
>
>
> In the Staff and Legal Assessment (1 May 2019) for ARIN-2019-20, Staff
> noted:
>
>
>
> “… ARIN staff would immediately perform an audit of the current waitlist
> and remove and inform any organization that holds more than a /20 in IPv4
> space excluding 4.4 and 4.10…” indicating a clear intent to treat these
> blocks specially. Failure to either incorporate this policy nuance into the
> NRPM or explicitly contradict it has resulted in confusion; a recent Policy
> Experience Report cited three occurrences in as many weeks.
>
>
>
> Policy statement:
>
>
>
> Replace the sentence “Organizations which hold more than a /20 equivalent
> of IPv4 space in aggregate are not eligible to apply.” in section 4.1.8
> with “Organizations which hold more than a /20 equivalent of IPv4 space in
> aggregate (exclusive of special use space received under section 4.4 or
> 4.10) are not eligible to apply.”
>
>
>
> Timetable for implementation: Immediate
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