[arin-ppml] Revised - Draft Policy ARIN-2022-8: Streamlining Section 11 Policy Language

[Nick Nugent]

Thanks, Anita. Perhaps it would help to hear more about experimental
activities like yours.

What would - and this is a question addressed to the broader PPML - an
exemplary experimental activity under Section 11 look like? Are there any
real-world past examples that ARIN could share?

Nick Nugent

On Sat, Oct 29, 2022 at 10:13 AM A N <anita.nikolich at gmail.com> wrote:

> Nick -
> That's a great catch. "technically sound within the meaning of ARIN’s
> Policy Development Process" is hard to decipher. I think the sentence
> should end after "technically sound". However "technically sound" is
> different from "technically coordinated" and I believe they should both be
> in there as requirements. Technically sound is a lightweight way to ensure
> that an experiment (or set of experiments) needs a resource space and that
> there is a reasoning behind the construction of the experiment.
> Coordination ensures that if goes awry, the experimenter has thought of how
> to mitigate damage.
>
> (I'm part of a group that runs a very large network testbed, and our
> general process is similar: justify what you're doing, and tell us how
> you'll mitigate effects on others.)
>
> Anita Nikolich
> (wearing non AC hat)
>
>
>
> On Thu, Oct 27, 2022 at 8:23 PM Nugent, Nick via ARIN-PPML <
> arin-ppml at arin.net> wrote:
>
>> Thanks, Andrew.
>>
>>
>>
>> Question: Do we need the following eligibility criterion?
>>
>>
>>
>> * Demonstration to ARIN that the experimental activity is technically
>> sound within the meaning of ARIN’s Policy Development Process;
>>
>>
>>
>> A few thoughts on it:
>>
>>
>>
>> (1) It represents a new requirement (it’s not currently in Section 11)
>>
>>
>>
>> (2) I’m not sure it makes sense to define “technically sound” by
>> reference to the Policy Development Process. Section 4.2 of the PDP defines
>> “technically sound” in a very narrow fashion that’s highly specific to
>> public number administration—namely:
>>
>>
>>
>> - Support both conservation and efficient utilization of Internet number
>> resources to the extent feasible. Policy should maximize number resource
>> availability to parties with operational need.
>>
>>
>>
>> - Support the aggregation of Internet number resources in a hierarchical
>> manner to the extent feasible. Policy should permit the routing scalability
>> that is necessary for continued Internet growth. (Note that neither ARIN,
>> nor its policies, can guarantee routability of any particular Internet
>> number resource as that is dependent on the actions of the individual
>> Internet operators.)
>>
>>
>>
>> - Support the unique registration of Internet number resources. Policy
>> should prevent to the extent feasible any unknown or duplicate use of
>> Internet number resources that could disrupt Internet communications.
>>
>>
>>
>> Presumably, these criteria would be irrelevant to many experimental
>> activities. And in any event, these criteria seem more fitting for how ARIN
>> administers public numbers than for how a private experiment is conducted.
>>
>>
>>
>> (3) To the extent “technically sound” means that the experimental
>> activity wouldn’t harm the operation of the internet, that requirement is
>> already covered by the following criterion:
>>
>>
>>
>> * Demonstration to ARIN that the experimental activity is technically
>> coordinated in that consideration of any potential negative impact of the
>> proposed experiment on the operation of the Internet and its deployed
>> services has been considered, and a description of experimenter mitigation
>> plans to contain any negative impacts has been provided.
>>
>>
>>
>> Or am I thinking of experimental activities too broadly (or narrowly)?
>>
>>
>>
>> Thanks,
>>
>> *Nick Nugent* | *Amazon.com*
>> Senior Corporate Counsel, Amazon Web Services
>> Email: nicknu at amazon.com
>>
>>
>>
>> *From:* ARIN-PPML <arin-ppml-bounces at arin.net> *On Behalf Of *Andrew Dul
>> *Sent:* Thursday, October 27, 2022 8:07 AM
>> *To:* arin-ppml at arin.net
>> *Subject:* RE: [EXTERNAL][arin-ppml] Revised - Draft Policy ARIN-2022-8:
>> Streamlining Section 11 Policy Language
>>
>>
>>
>> *CAUTION*: This email originated from outside of the organization. Do
>> not click links or open attachments unless you can confirm the sender and
>> know the content is safe.
>>
>>
>>
>> Updated markup and new version can be found here for your review.
>>
>>
>> https://www.arin.net/participate/policy/drafts/pdf/NRPM-Section11-update-20221021.pdf
>>
>> https://www.arin.net/participate/policy/drafts/pdf/NRPM-Section11-update-20221021-clean.pdf
>>
>> Thanks,
>> Andrew
>>
>> On 10/26/22 10:44 AM, ARIN wrote:
>>
>> The following Draft Policy has been revised:
>>
>>
>>
>> * ARIN-2022-8: Streamlining Section 11 Policy Language
>>
>>
>>
>> Revised text is below and can be found at:
>>
>>
>>
>> https://www.arin.net/participate/policy/drafts/2022_8/
>>
>>
>>
>> You are encouraged to discuss all Draft Policies on PPML. The AC will
>> evaluate the discussion 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/
>>
>>
>>
>> Draft Policies and Proposals under discussion can be found at:
>>
>> https://www.arin.net/participate/policy/drafts/
>>
>>
>>
>> Regards,
>>
>>
>>
>> Sean Hopkins
>>
>> Senior Policy Analyst
>>
>> American Registry for Internet Numbers (ARIN)
>>
>>
>>
>>
>>
>>
>>
>> Draft Policy ARIN-2022-8: Streamlining Section 11 Policy Language
>>
>>
>>
>> Problem Statement:
>>
>>
>>
>> Section 11 of the NRPM contains a great deal of language that is either
>> explicitly not policy, or is not impactful on ARIN's administration of
>> Internet number resources for experimental allocations, or to the customers
>> requesting said resources. A revision to transform Section 11 into a
>> collection of policies for experimental allocations serves to make the
>> Section more easily digested by the reader, and a more functional reference
>> for customers and ARIN staff during experimental allocation requests.
>>
>>
>>
>> Policy Statement:
>>
>>
>>
>> Section 11 Overview
>>
>>
>>
>> Current text:
>>
>>
>>
>> 11. Experimental Internet Resource Allocations
>>
>>
>>
>> ARIN will allocate Numbering Resources to entities requiring temporary
>> Numbering Resources for a fixed period of time under the terms of
>> recognized experimental activity.
>>
>>
>>
>> "Numbering Resources" refers to unicast IPv4 or IPv6 address space and
>> Autonomous System numbers.
>> The following are the criteria for this policy:
>>
>>
>>
>> Proposed text:
>>
>>
>>
>> 11. Experimental Internet Resource Allocations
>>
>>
>>
>> ARIN will allocate Number Resources to organizations requiring temporary
>> Number Resources for a fixed period of time under the terms of a recognized
>> experimental activity.
>>
>>
>>
>> Section 11.1
>>
>>
>>
>> Current text:
>>
>>
>>
>> 11.1. Documentation of Recognized Experimental Activity
>>
>>
>>
>> A Recognized Experimental Activity is one where the experiment's
>> objectives and practices are described in a publicly accessible document.
>> It is a normal requirement that a Recognized Experimental Activity also
>> includes the undertaking that the experiment's outcomes be published in a
>> publicly accessible document at the end of the experiment. The conditions
>> for determining the end of the experiment are to be included in the
>> document. Applicants for an experimental allocation are expected to
>> demonstrate an understanding that when the experiment ends, the allocation
>> will be returned; a successful experiment may need a new allocation under
>> normal policies in order to continue in production or commercial use, but
>> will not retain the experimental allocation.
>>
>>
>>
>> A "publicly accessible document" is a document that is publicly and
>> openly available free of charges and free of any constraints of disclosure.
>>
>>
>>
>> ARIN will not recognize an experimental activity under this policy if the
>> entire research experiment cannot be publicly disclosed.
>>
>>
>>
>> ARIN has a strong preference for the recognition of experimental activity
>> documentation in the form of a document which has been approved for
>> publication by the IESG or by a similar mechanism as implemented by the
>> IETF.
>>
>>
>>
>> Proposed text:
>>
>>
>>
>> 11.1. Eligibility Criteria for Recognized Experimental Activity
>>
>>
>>
>> The eligibility criteria for a recognized experimental activity under
>> this policy are:
>>
>>
>>
>> The experiment’s description and objectives are published in a publicly
>> accessible document, which for the purpose of this policy means that the
>> document is readily available free of charges to the public, and free of
>> any constraints of disclosure within one year after the end of the
>> experiment;
>>
>>
>>
>> The experiment’s outcomes must also be published in a publicly accessible
>> document;
>>
>>
>>
>> * Demonstration to ARIN that the experimental activity is technically
>> sound within the meaning of ARIN’s Policy Development Process;
>>
>>
>>
>> * Demonstration to ARIN that the experimental activity is technically
>> coordinated in that consideration of any potential negative impact of the
>> proposed experiment on the operation of the Internet and its deployed
>> services has been considered, and a description of experimenter mitigation
>> plans to contain any negative impacts has been provided.
>>
>>
>>
>> Retire Sections 11.2 and 11.3
>>
>>
>>
>> Section 11.4
>>
>>
>>
>> Current text:
>>
>>
>>
>> 11.4. Resource Allocation Term and Renewal
>>
>>
>>
>> The Numbering Resources are allocated for a period of one year. The
>> allocation can be renewed on application to ARIN providing information as
>> per Detail One. The identity and details of the applicant and the allocated
>> Numbering Resources will be published under the conditions of ARIN's normal
>> publication policy. At the end of the experiment, resources allocated under
>> this policy will be returned to the available pool.
>>
>>
>>
>> Proposed text:
>>
>>
>>
>> 11.4. Resource Allocation Term and Renewal
>>
>>
>>
>> The Number Resources are allocated for a period of one year under this
>> policy. The allocation can be renewed on application to ARIN by providing
>> information as to why an extension is necessary for a successful
>> experiment. The resources allocated under this policy must be returned to
>> ARIN as soon as the recognized experimental activity has ended.
>>
>>
>>
>> Section 11.5
>>
>>
>>
>> Current text:
>>
>>
>>
>> 11.5. Single Resource Allocation per Experiment
>>
>>
>>
>> ARIN will make one-off allocations only, on an annual basis to any
>> applicant. Additional allocations to an organization already holding
>> experimental activity resources relating to the specified activity outside
>> the annual cycle will not be made unless justified by a subsequent complete
>> application.
>>
>>
>>
>> It's important for the requesting organization to ensure they have
>> sufficient resources requested as part of their initial application for the
>> proposed experimental use.
>>
>>
>>
>> Proposed text:
>>
>>
>>
>> 11.5. Single Resource Allocation per Recognized Experimental Activity
>>
>>
>>
>> ARIN will make only one allocation per recognized experimental activity.
>> An allocation may consist of multiple Number Resources if required to
>> conduct the recognized experimental activity. Additional allocations to an
>> organization already holding experimental Number Resources will not be made
>> under this policy unless justified by a subsequent complete application
>> relating to a different experimental activity.
>>
>>
>>
>> Retire Section 11.6
>>
>>
>>
>> Section 11.7
>>
>>
>>
>> Current text:
>>
>>
>>
>> 11.7. Resource Allocation Guidelines
>>
>>
>>
>> The Numbering Resources requested come from the global Internet Resource
>> space, do not overlap currently assigned space, and are not from private or
>> other non-routable Internet Resource space. The allocation size shall be
>> consistent with the existing ARIN minimum allocation sizes, unless smaller
>> allocations are intended to be explicitly part of the experiment. If an
>> organization requires more resources than stipulated by the minimum
>> allocation size in force at the time of its request, the request must
>> clearly describe and justify why a larger allocation is required. All
>> research allocations must be registered publicly in whois. Each research
>> allocation will be designated as a research allocation with a comment
>> indicating when the allocation will end.
>>
>>
>>
>> Proposed text:
>>
>>
>>
>> 11.7. Resource Allocation Guidelines
>>
>>
>>
>> The Number Resources requested shall come from the global Number Resource
>> space, shall not overlap any currently assigned space, and shall not be
>> from private or other non-routable Number Resource space. The allocation
>> size shall be consistent with the existing ARIN minimum allocation sizes,
>> unless smaller allocations are explicitly required due to the nature of the
>> experiment. If an organization requires more resources than stipulated by
>> the minimum allocation size in force at the time of its request, the
>> request must clearly describe and justify why a larger allocation is
>> required. All research allocations must be registered publicly in ARIN’s
>> directory services. Each research allocation will be designated as a
>> research allocation with a comment indicating when the allocation will end.
>>
>>
>>
>> Section 11.8
>>
>>
>>
>> Current text:
>>
>>
>>
>> 11.8. Commercial Use Prohibited
>>
>>
>>
>> If there is any evidence that the temporary resource is being used for
>> commercial purposes, or is being used for any activities not documented in
>> the original experiment description provided to ARIN, ARIN reserves the
>> right to immediately withdraw the resource and reassign it to the free pool.
>>
>>
>>
>> Proposed text:
>>
>>
>>
>> 11.8. Commercial Use Prohibited
>>
>>
>>
>> If there is any evidence that the temporary resource is being used for
>> commercial purposes or is being used for any activities not documented in
>> the original experiment description provided to ARIN, ARIN reserves the
>> right to immediately withdraw the resource.
>>
>>
>>
>> Retire Section 11.9
>>
>>
>>
>> Timetable for implementation: Immediate
>>
>>
>>
>>
>>
>>
>>
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>>
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