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

Nugent, Nick nicknu at amazon.com
Thu Oct 27 21:22:54 EDT 2022


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<mailto: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


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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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