[arin-ppml] ARIN-2024-5 Rewrite of NRPM Section 4.4 Micro-Allocation - Community Questions

[Tyler O'Meara]

Responses in line

Tyler

On Tue, 2025-02-18 at 12:07 -0800, Chris Woodfield wrote:
> As AC shepherds for the critical infrastructure draft (2024-5) we'd like to
> get input on the draft policy text and collect some feedback on open issues
> that the shepherds have received from multiple sources. This will help us edit
> the draft for presentation at ARIN 55 and, if there is consensus, advancement
> to the NRPM.
> 
> The current draft text can be found on ARIN’s policy page here:
> https://www.arin.net/participate/policy/drafts/2024_5/
> 
> Below are the points in the current proposed policy text that we’d like to get
> community feedback on.
> 
> ----
> Under 4.4, Critical Internet Infrastructure (CII) Allocations:
> “The intent of this policy is not to unreasonably preclude the use of an
> allocated prefix in servicing the needs of Critical Internet Infrastructure.”
> 
> - We’ve received feedback that text declaring the intent of a policy is
> superfluous, and could lead to ambiguous guidance to ARIN staff when
> evaluating specific address requests under this section. Should this statement
> be removed?
> 

I think this should be removed.

> Also under 4.4:
> “Only Section 8.2 transfers are allowed.”
> 
> - Current policy prohibits 4.4 resources, along with 4.10 resources, from
> being transferred under sections 8.3 and 8.4, making this statement redundant
> under current text, as that leaves 8.2 as the only qualified type of transfer.
> Should this be deleted, or might it make sense to keep it in to disallow any
> additional transfer types that may be added to Section 8 in the future?

This should be deleted, as Section 8.x already specifies the requirements for
the relevant transfers.

> Under 4.4: 
> “ARIN will reserve a /15 equivalent of IPv4 address space for Critical
> Internet Infrastructure (CII) within the ARIN RIR service area. Allocations
> from this pool will be no smaller than a /24.”
> 
> and later under 4.4.2:, Root and ccTLD Allocations:
> “Root and ccTLD operators will provide justification of their need and
> certification of their status as currently active zone operators.”
> 
> - The proposal text (and, to be fair, the text it aims to replace) is silent
> on justification criteria for IX allocations larger than a /24. Our
> understanding is that absent explicit guidance, ARIN staff has used the
> justification language in Section 4.2.2 or 4.2.4 to evaluate these depending
> on the request type. Should the qualification criteria be made explicit in the
> proposed policy text? Should an alternate justification criteria be proposed
> for larger IX allocations under this section?
> 

Rather than adding requirements to 4.4.1 or 4.4.2 I would add the following (or
similar) under 4.4: "Requests under this Section must be justified under either
Section 4.2 or 4.3 in addition to meeting the specific requirements below". This
makes it clear that 4.4 does not exempt a request from needing to meet the usual
ARIN policies, but that it is instead of "add on" you can use to get access to
the reserved pool rather than having to go to the waitlist.

> “[Critical Internet Infrastructure] includes Internet Exchanges, IANA-
> authorized root servers, ccTLD operators, ARIN and IANA”
> 
> - The current text references “core DNS service providers”, while the proposal
> text is more restrictive, only specifying ccTLD operators as eligible to apply
> for CII resources. Should this be expanded to encompass other types of TLD
> operators, such as gTLD, sponsored TLD, and/or possibly others? Or simply
> revert to the more expansive language in existing text?
> ----

I support expanding 4.4 to include gTLD operators for gTLDs that were allocated
prior to 2012 (when the number of limited use gTLDs exploded). Alternatively, we
could restrict it to operators of gTLDs that are generally available to a large
number of registrants and have some minimum number of registered domains.
Regardless of either of these options, considering ccTLDs "Critical Internet
Infrastructure" but not ".com" is rather silly in my opinion.


> Thank you and we look forward to your feedback.
> 
> Regards,
> 
> Chris Woodfield and Bill Herrin
> ARIN Advisory Council
> _______________________________________________
> 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.

-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://lists.arin.net/pipermail/arin-ppml/attachments/20250218/3c136179/attachment.htm>