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

Tue Mar 23 17:48:51 EDT 2021

Given that the impetus for implementing the /20 limit on waitlist eligibility was primarily to prevent fraudulent and/or speculative monetization of space allocated from the waitlist, I see no reason to oppose this carve-ou, given that 4.4 and 4.10 space is ineligible for transfer under Section 8.3. As such, I see no loosening of loopholes by adopting this policy.

As a side note, I’d be interested in knowing which allocations have been made under these policies, particularly 4.4; given the availability of otherwise-unavailable IPv4 space under these policies, the community should have an interest in being able to independently verify that resources allocated via these policies are, in fact, being used for the purposes stated, which should be reasonably simple for an interested community member to determine. Is there a method by which these allocations are noted in WHOIS? 

Section 4.10 appears to call for a contiguous /10 to be set aside for its purpose, but the actual network number that was reserved does not seem to be noted or otherwise easily determined. Can this be published?

Thanks,

-Chris

> On Mar 23, 2021, at 7:59 AM, ARIN <info at arin.net> wrote:
> 
> On 18 March 2021, the ARIN Advisory Council (AC) accepted "ARIN-prop-297: Special Use IPv4 Space Out of Scope for Purposes of Determining Waitlist Eligibility" as a Draft Policy.
>  
> Draft Policy ARIN-2021-2 is below and can be found at:
>  
> https://www.arin.net/participate/policy/drafts/2021_2/ <https://www.arin.net/participate/policy/drafts/2021_2/>
>  
> You are encouraged to discuss all Draft Policies on PPML. The AC will evaluate the discussion in order to assess the conformance of this draft policy with ARIN's Principles of Internet number resource policy as stated in the Policy Development Process (PDP). Specifically, these principles are:
>  
> * Enabling Fair and Impartial Number Resource Administration
> * Technically Sound
> * Supported by the Community
>  
> The PDP can be found at:
> https://www.arin.net/participate/policy/pdp/ <https://www.arin.net/participate/policy/pdp/>
>  
> Draft Policies and Proposals under discussion can be found at:
> https://www.arin.net/participate/policy/drafts/ <https://www.arin.net/participate/policy/drafts/>
>  
> Regards,
>  
> Sean Hopkins
> Senior Policy Analyst
> American Registry for Internet Numbers (ARIN)
>  
> Draft Policy ARIN-2021-2: Special Use IPv4 Space Out of Scope for Purposes of Determining Waitlist Eligibility
>  
> 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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