[arin-ppml] Revised - Draft Policy ARIN-2024-5: Rewrite of NRPM Section 4.4 Micro-Allocation

[John Santos]

Maybe I'm just being persnickety, but is "Use of this policy for CII is 
voluntary." unambiguous?  To me, it means a user can implement CII using any 
addresses that are allocated to them, i.e. they are not required to apply for 
and use 4.4 space for CII, *BUT* might someone argue that this clause means that 
if they have 4.4 space, or acquire it somehow, then using it for CII is 
voluntary and they can use it for anything they want?  Should we add an explicit 
provision that 4.4 space may *ONLY* be used for CII?

Also, does section 4.4.2 create a chicken and egg problem: A TLD operator must 
be "a currently active zone operator" to apply for 4.4 space, but they can't 
become an active zone operator until they have acquired the IP addresses to do 
so?  It would complicate the situation if we added "or plans to become one 
within <reasonable time period>", and another sentence that the allocation would 
be subject to revocation if they did not do so.

Or is this just too pedantic to worry about?


On 3/18/2025 2:44 PM, ARIN wrote:
> The following Draft Policy has been revised:
>   
> *ARIN-2024-5: Rewrite of NRPM Section 4.4 Micro-Allocation
>   
> Revised text is below and can be found at:
>   
> 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/
>   
> Draft Policies and Proposals under discussion can be found at:
>   
> 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. The growth and use of Internet Exchanges have 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 allocated prefixes as required.
> 
> Policy Statement:
> 
> 4.4 Critical Internet Infrastructure (CII) Allocations
> 
> 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. Sparse allocation will be used whenever practical. CII includes Internet Exchanges, IANA-authorized root servers, TLD operators that offer domain-level DNS services to outside parties, ARIN, and IANA.
> 
> Previous allocations under this policy must continue to meet the justification requirements of this policy. Use of this policy for CII is voluntary. ARIN will publish all 4.4 allocated addresses for research purposes.
> 
> 4.4.1 Internet Exchange Allocations
> 
> Internet Exchange operators must justify their need by providing a minimum of three initial participants not under common control connected to a shared, physical switching fabric to be used for the purpose of the exchange of data destined for and between the respective networks. This justification must include participant names, ASNs and contact information for each named participant. The applicant’s Internet Exchange affiliated ASNs are not eligible to be included in meeting the participant requirement.
> 
> Allocated addresses may be publicly reachable at the operator’s discretion, but must be assigned only to resources required to operate the IXP.
> 
> 4.4.2 TLD Allocations
> 
> TLD operators will provide justification of their need and certification of their status as currently active zone operators.
> 
> 4.4.3 Additional Requests
> 
> A recipient may request up to a 24-month supply of IPv4 resources under this section. Requests for additional resources under this section will be evaluated using Section 4.2.4.1’s usage requirements.
> 
> Timetable for Implementation: Immediate
> 
> 
> 
> 
> _______________________________________________
> 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.

-- 
John Santos
Evans Griffiths & Hart, Inc.
781-861-0670 ext 539