[arin-ppml] Draft Policy ARIN-2024-5: Rewrite of NRPM Section 4.4 Micro-Allocation
John Santos
john at egh.com
Thu May 23 12:01:17 EDT 2024
If some business running some form of critical non-network infrastructure (like
a nuclear power plant) tried to argue it was entitled to a 4.4 allocation
because of that, it would be good to have "critical INTERNET infrastructure"
explicit in the NRPM.
On 5/23/2024 11:56 AM, Martin Hannigan wrote:
>
> I'm torn.
>
> On one hand, it doesn't matter. The purpose of the NRPM is to regulate
> *Internet* networks so it's not a hard leap of faith to understand (legally or
> otherwise) what 4.4 serves especially with the two specific subsections for
> exchanges and root ops.
>
> On the other hand, some room for staff to maneuver this small piece might be wise.
>
> If someone has a use case, all ears. The usual suspects, nuclear power plants,
> traffic lights, DHS CSI networks, SOSUS, SS7/SS8, etc. don't seem to fly.
>
> + / - overall.
>
> Thanks,
>
> -M<
>
>
>
>
>
>
> On Thu, May 23, 2024 at 10:48 AM A N <anita.nikolich at gmail.com
> <mailto:anita.nikolich at gmail.com>> wrote:
>
> I also like the suggested change to "Critical Internet Infrastructure".
>
> (There has been a lot of discussion regarding the FCCs use of the term
> "Critical Infrastructure" being too broad. I think using "critical internet
> infrastructure" is a good way to be specific about what the policy is
> addressing.)
>
> On Wed, May 22, 2024 at 4:31 PM Chris Woodfield <chris at semihuman.com
> <mailto:chris at semihuman.com>> wrote:
>
> In general, I support this proposal.
>
> Replying to selected points:
>
> > On May 22, 2024, at 14:22, Tyler O'Meara via ARIN-PPML
> <arin-ppml at arin.net <mailto:arin-ppml at arin.net>> wrote:
> >
> > I support this change, but have a few suggestions:
> >
> > 1) I'd use Critical Internet Infrastructure (CII) as the official
> term for this
> > section; Critical Infrastructure seems a bit too vague.
>
> I like this change. +1
>
> > 2) Instead of "ARIN will reserve", should we change it to "ARIN has
> reserved",
> > since the reservation has already occurred and there's no intention
> in the
> > policy to keep the reserved block at a /15 equivalent?
>
> note that section 4.1.7.1 includes a mechanism by which the reserved
> block will be replenished (presumably via reclaimed resources), so we
> can’t assume that it will only be a /15 going forward. See
> https://www.arin.net/participate/policy/nrpm/#4-1-7-2-precedence-for-replenishment <https://www.arin.net/participate/policy/nrpm/#4-1-7-2-precedence-for-replenishment>
>
> > 3) Add the following sentence to the 2nd paragraph: "IP Addresses
> allocated
> > under this section must only be used for the operation of CII".
> > The current wording permits an operator of CII to use 4.4 space
> for any
> > purpose, which is likely not the intent.
>
> I’m not going to speak for the authors, but I’d be in support of this
> language change. Usage of CII space outside the operation of CII does
> not likely fit with the communities expectations for this space (The
> community is welcome to disagree with me on this, of course).
>
> > 4) In "Assigned addresses may be publicly reachable at the operators
> discretion
> > and be used to operate all of the Internet Exchange's infrastructure"
> replace
> > "operators" with "operator's".
>
> Likely a typo, in support of fixing of course.
>
> Thanks,
>
> -Chris
>
>
> >
> >
> > On Tue, 2024-05-21 at 12:26 -0400, ARIN wrote:
> >> On 16 May 2024, the ARIN Advisory Council (AC) accepted “ARIN-prop-333:
> >> Rewrite of NRPM Section 4.4 Micro-Allocation” as a Draft Policy.
> >>
> >> Draft Policy ARIN-2024-5 is below and can be found at:
> >>
> >> https://www.arin.net/participate/policy/drafts/2024_5
> <https://www.arin.net/participate/policy/drafts/2024_5>
> >>
> >> 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/
> <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,
> >>
> >> Eddie Diego
> >> Policy Analyst
> >> American Registry for Internet Numbers (ARIN)
> >>
> >>
> >> Draft Policy ARIN-2024-5: Rewrite of NRPM Section 4.4 Micro-Allocation
> >>
> >> Problem Statement:
> >>
> >> The current NRPM Section 4.4 language hasn’t aged well. As the ARIN
> 53 policy
> >> experience report demonstrated, 4.4 has also become difficult to
> implement by
> >> ARIN staff. Growth and use of Internet Exchanges has also changed. The
> >> overhaul seeks to improve technical soundness, respect the privilege
> of a
> >> dedicated pool and to more closely observe conservation principles using
> >> clear, minimum and enforceable requirements and underscoring the
> value of
> >> routability of assigned prefixes as required.
> >>
> >> ARIN 4.4 CI Assignments
> >>
> >> The intent of this policy is not to unreasonably preclude the use of an
> >> allocated or assigned prefix in servicing the needs of critical
> infrastructure
> >> of the Internet.
> >>
> >> ARIN will reserve a /15 equivalent of IPv4 address space for Critical
> >> Infrastructure (CI) of the Internet within the ARIN RIR service area.
> >> Assignments from this pool will be no smaller than a /24. Sparse
> allocation
> >> will be used whenever practical. CI includes Internet Exchanges, IANA
> >> authorized root servers, ccTLD operators, ARIN, and IANA. Addresses
> assigned
> >> from this pool may be revoked if no longer in use or not used for
> approved
> >> purposes. Only Section 8.2 transfers are allowed. Use of this policy
> for CI is
> >> voluntary. ARIN will publish all 4.4 allocated addresses for research
> >> purposes.
> >>
> >> 4.4.1 Internet Exchange Assignments
> >>
> >> • Internet Exchange operators must justify their need by providing the
> >> following:
> >>
> >> • A minimum of three initial participants connected to a physically
> present
> >> ethernet switch fabric to be used for the purpose of Internet Exchange
> >> facilitated peering
> >>
> >> • Justification must include:
> >> - Three unique participant names and ASNs not under common control
> >> - Direct contact information for each participant
> >>
> >> • Staff can reasonably validate hardware existence and participants
> intent
> >>
> >> • Applicant Internet Exchange affiliated ASNs are not eligible to be
> included
> >> in meeting the participant requirement
> >>
> >> • Assigned addresses may be publicly reachable at the operators
> discretion and
> >> be used to operate all of the Internet Exchange's infrastructure
> >>
> >> 4.4.2 Root and ccTLD Assignments
> >>
> >> Root and ccTLD operators will provide justification of their need and
> >> certification of their status as currently active zone operators.
> >>
> >>
> >>
> >> _______________________________________________
> >> ARIN-PPML
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> >
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--
John Santos
Evans Griffiths & Hart, Inc.
781-861-0670 ext 539
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