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

Mon Oct 31 17:47:33 EDT 2022

>The policy has served the community well for a long time. As such, I have
a hard time agreeing that the premise is doubtful.

Is there any data for how often this policy is used? Most educational
institutions have their own IP space that likely still have some unused
holes here and there; why would they not just use their own and have the
entire history (or at least a good deal of history) to further validate
their findings?

Also, are these allocations given priority over the rest of the waiting
list? If not, why would anyone bother being part of this process with so
many restrictions, when they could just get on the regular waiting list and
have the block for as long as they need without Section 11's restrictions
and prerequisites.

I guess what I'm getting at is, if the policy is not being used, or isn't
particularly preferable over normal methods, how do we know it's broken
as-is? Was this edit prompted by an educational institution becoming
confused by its wording? Or is this just speculation that it *could *be
made more clear just in case it is used?

Also, 4 entire sub-sections of the 12 currently in Section 11 are being
retired as part of this draft, is 1/3 of the policy points perhaps a bit
aggressive for classification as an "editorial change". Again, I'm probably
missing a lot of prior context and precedent, but that just seems a little
excessive.

If Section 11 is not preferable to requesting a normal assignment under
Sections 4 or 6, resulting in under-use, perhaps a wider overhaul of the
policy is necessary, rather than an "editorial" change.

-Matt

On Mon, Oct 31, 2022 at 3:25 PM Owen DeLong <owen at delong.com> wrote:

>
>
> On Oct 30, 2022, at 14:06, Matt Erculiani <merculiani at gmail.com> wrote:
>
> First post on the PPML, please be gentle. Direct reply feedback is welcome.
>
> I have a general concern about a dedicated IP allocation for use with
> experiments. If the block has ever been announced in the DFZ, it is likely
> its reputation has been influenced by prior use. If valid results are
> desired, a clean, never announced block would need to be assigned to the
> research organization for each request. While I understand that ensuring
> the validity of any research is "their problem", I don't think that 1 year
> provides nearly enough time to research all bocklists, achieve removal, and
> perform the experiment, particularly considering some blocklist admins are
> difficult to engage.
>
>
> A virgin IPv4 block is a rather laughable concept these days.
>
> I think that experimenters should know and understand the realities of the
> modern IPv4 world and thus design their experiments to take such things
> into account.
>
> Remember, this is a policy which has been on the books for a very long
> time (more than the 20+ years I’ve been involved in ARIN at least).
>
> These are just some tweaks mainly aimed at making it easier to understand
> and more in line with modern realities.
>
> It's a really good idea in theory, but I don't think the practicality is
> actually there. If anyone ever hijacks pieces of the research block, are
> those going to be considered invalid for research purposes because they
> were previously involved in malicious activity and are therefore "tainted"?
>
>
> The process for cleaning “tainted” blocks is reasonably well known. I
> don’t see this as any different from any other entity receiving a
> previously used block which might be tainted.
>
> Basically, if the premise of the policy is doubtful, why would any
> editorial changes be entertained?
>
>
> The policy has served the community well for a long time. As such, I have
> a hard time agreeing that the premise is doubtful.
>
> Owen
>
>
> -Matt
>
>
>
> On Sat, Oct 29, 2022 at 9:09 PM Nick Nugent <nick at nicknugent.com> wrote:
>
>> 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
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>> _______________________________________________
>>>>
>>>> ARIN-PPML
>>>>
>>>> You are receiving this message because you are subscribed to
>>>>
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>>>>
>>>> Unsubscribe or manage your mailing list subscription at:
>>>>
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>>>>
>>>> Please contact info at arin.net if you experience any issues.
>>>>
>>>> _______________________________________________
>>>> ARIN-PPML
>>>> You are receiving this message because you are subscribed to
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>>>> Unsubscribe or manage your mailing list subscription at:
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>>>> Please contact info at arin.net if you experience any issues.
>>>>
>>> _______________________________________________
>>> ARIN-PPML
>>> You are receiving this message because you are subscribed to
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>>> Unsubscribe or manage your mailing list subscription at:
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>>> Please contact info at arin.net if you experience any issues.
>>>
>> _______________________________________________
>> ARIN-PPML
>> You are receiving this message because you are subscribed to
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>> Unsubscribe or manage your mailing list subscription at:
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>>
>
>
> --
> Matt Erculiani
> ERCUL-ARIN
> _______________________________________________
> ARIN-PPML
> You are receiving this message because you are subscribed to
> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
> Unsubscribe or manage your mailing list subscription at:
> https://lists.arin.net/mailman/listinfo/arin-ppml
> Please contact info at arin.net if you experience any issues.
>
>
>

-- 
Matt Erculiani
ERCUL-ARIN
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