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

[Mattapally Technologies]

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On Tuesday, December 21, 2021, 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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