Draft Policy 2009-3 (Global Proposal): Allocation of IPv4 Blocks to Regional Internet Registries - Last Call

[Member Services]

The ARIN Advisory Council (AC) met on 23 October 2009 and decided to
send a revised version of the following draft policy to last call:

    Draft Policy 2009-3 (Global Proposal): Allocation of IPv4 Blocks to
Regional Internet Registries

The AC met in accordance with the ARIN Policy Development Process which
requires the AC to meet within 30 days of the conclusion of the Public
Policy Meeting to make decisions about the draft policies that had been
presented. The AC revised the draft. The AC removed sections B.1.d and B.4.

B.1. “d. Legacy address space. IPv4 address space allocated or assigned
prior to the creation of the RIR.”

B. “4. Initial Allocation of IPv4 Address Space
Each new RIR shall, at the moment of recognition, be allocated one (1)
allocation unit by the IANA. If an allocation unit is not available,
then the IANA will issue this block as soon as one is available. This
allocation will be made regardless of the newly formed RIR's projected
utilization figures and shall be independent of the IPv4 address space
that may have been transferred to the new RIR by the already existing
RIRs as part of the formal transition process.”

Feedback is encouraged during this last call period. All comments should
be provided to the Public Policy Mailing List. This last call will
expire on 13 November 2009. After last call the AC will conduct their
last call review.

The draft policy text is below and available at:
https://www.arin.net/policy/proposals/

The ARIN Policy Development Process is available at:
https://www.arin.net/policy/pdp.html

Regards,

Member Services
American Registry for Internet Numbers (ARIN)


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Draft Policy 2009-3 (Global Proposal)
Allocation of IPv4 Blocks to Regional Internet Registries

Version/Date: 28 October 2009

Policy statement:

This document describes the policy governing the allocation of IPv4
address space from the IANA to the Regional Internet Registries (RIRs).
This document does not stipulate performance requirements in the
provision of services by IANA to an RIR in accordance with this policy.
Such requirements should be specified by appropriate agreements among
the RIRs and ICANN.

This policy is to be implemented in two phases.

A. Phase I: Recovery of IPv4 Address Space

Upon ratification of this policy by the ICANN Board of Directors the
IANA shall establish a mechanism to receive IPv4 address space which is
returned to it by the RIRs, and hold that address space in a 'recovered
IPv4 pool'.

Each RIR through their respective chosen policies and strategies may
recover IPv4 address space which is under their administration and
designate any such space for return to the IANA. Each RIR shall at
quarterly intervals return any such designated address space to the IANA
in aggregated blocks of /24 or larger, for inclusion in the recovered
IPv4 pool.

During Phase I, no allocations will be made from the recovered IPv4
pool. Return of recovered address space (as described above) will
continue throughout Phase II.

B. Phase II: Allocation of Recovered IPv4 address space by the IANA

Upon ratification of this policy by the ICANN Board of Directors and a
declaration by the IANA that its existing free pool of unallocated IPv4
address space is depleted; Global Addressing Policy ASO-001-2 (adopted
by ICANN Board 8 April 2005) is rescinded. IANA will then commence to
allocate the IPv4 address space from the recovered IPv4 pool.

1. The following definitions apply to this policy:

a. Recovered Address Space. Recovered address space is that address
space that is returned to an RIR as a result of any activity that seeks
to reclaim unused address space or is voluntarily returned to the RIR or
is reclaimed by the RIR as a result of legal action or abuse
determination. Recovered address space does not include that address
space that is reclaimed because of non-payment of contractual fees whose
reclamation date is less than 1 year at the time of the report.

b. IPv4 Address Holdings. IPv4 address holdings are all unallocated IPv4
address space held by an RIR to include recovered address space not yet
returned less that address space that is committed in accordance with
the RIR's reservation policy and practices.

c. Aggregated address blocks. Aggregated address blocks are contiguous
prefixes that can be aggregated on natural bit boundaries. 10.0.0.0/24
and 10.0.1.0/24 are two contiguous prefixes that can be combined to form
an aggregated address block. 10.0.0.0/24 and 10.0.1.0/25 are two
contiguous prefixes that cannot be combined on a natural bit boundary to
form an aggregated block.

2. Allocation of IPv4 Address Space

a. For the purposes of this policy, an 'IPv4 allocation period' is
defined as a 6-month period following 1 March or 1 September in each year.

b. At the beginning of each IPv4 allocation period, the IANA will
determine the 'IPv4 allocation unit' for that period, as 1/10 of its
IPv4 address pool, rounded down to the next CIDR (power-of-2) boundary.
The minimum 'IPv4 allocation unit' size will be a /24.

c. In each allocation period, each RIR may issue one IPv4 request to the
IANA. Providing that the RIR satisfies the allocation criteria described
in paragraph B.2, the IANA will allocate a single allocation unit,
composed of the smallest possible number of blocks available in its IPv4
address pool.

3. IPv4 Address Space Allocation Criteria

A RIR is eligible to receive additional IPv4 address space from the IANA
when the total of its IPv4 address holdings is less than 50% of the
current IPv4 allocation unit, and providing that it has not already
received an IPv4 allocation from the IANA during the current IPv4
allocation period.

5. Reporting

a. All returned space is to be recorded in an IANA-published log of IPv4
address space transactions, with each log entry detailing the returned
address block, the date of the return, and the returning RIR.

b. All allocated space is also to be recorded in this IANA-published log
of IPv4 address space transactions, with each log entry detailing the
address blocks, the date of the allocation and the recipient RIR.

c. The IANA will maintain a public registry of the current disposition
of all IPv4 address space, detailing all reservations and current
allocations and current IANA-held address space that is unallocated.

d) The IANA may make public announcements of IPv4 address block
transactions that occur under this policy. The IANA will make
appropriate modifications to the "Internet Protocol V4 Address Space"
page of the IANA website and may make announcements to its own
appropriate announcement lists. The IANA announcements will be limited
to which address ranges, the time of allocation and to which Registry
they have been allocated.

Rationale:

With the depletion of the IANA free pool of IPv4 address space, the
current policy regarding the allocation of IPv4 address space to the
RIRs will become obsolete. The RIRs may already, according to their
individual policies and procedures, recover IPv4 address blocks of any
size. However, current policy requires IANA to make allocations to the
RIRs in blocks of /8. If any blocks smaller than /8 are returned to the
IANA, current policy does not provide a way to allocate that space. This
policy provides a mechanism for the RIRs to return recovered IPv4
address space to the IANA and provides the IANA the policy by which it
can allocate it back to the RIRs on a needs basis. This policy creates a
new global pool of IPv4 address space that can be allocated where it is
needed on a global basis without a transfer of address space between the
RIRs.

The original version of Global Policy Proposal for the Allocation of
IPv4 Blocks to Regional Internet Registries (ARIN policy 2009-3) was
proposed in the ARIN region, discussed on the Public Policy Mailing List
(PPML), and by the Advisory Council (AC). A number of concerns were
expressed, mostly related to the mandatory requirement to return
reclaimed space to IANA. In an attempt to alleviate some of these
concerns, the AC modified 2009-3 to make the return of non-legacy space
to IANA optional. This version of the proposal was discussed at the
April 2009 ARIN XXIII meeting in San Antonio. During that discussion,
it became clear that there was not a consensus in the ARIN region for
either the original proposal, or the modified legacy-only version.

As a result of subsequent discussions of the global policy at the spring
AfriNIC and LACNIC meetings, it became clear that one of the reasons
2009-3 is such a difficult policy to get consensus on is that the
original policy, as proposed, is a global policy proposal that has some
local policy aspects, namely that requires each RIR to return reclaimed
space. Ideally, global policies are supposed to maintain a clean
separation from local policies: global policy is supposed to only govern
the relationship between the IANA and the RIRs, and local policy defines
what the RIR can do internally. As a side effect of the blurring of
global and local policy in the current revision of 2009-3, ARIN (and
most of the other RIRs) have been having an interesting debate about
exactly which space should be covered by the policy.

To sidestep this issue, the changes made to the proposal are in the 2nd
paragraph of section A:

"Each RIR through their respective chosen policies and strategies may
recover IPv4 address space which is under their administration and
designate any such space for return to the IANA. Each RIR shall at
quarterly intervals return any such designated address space to the IANA
in aggregated blocks of /24 or larger, for inclusion in the recovered
IPv4 pool."

The original version read:

"Each RIR through their respective chosen policies and strategies may
recover IPv4 address space which is under their administration. Each RIR
shall at quarterly intervals return any such recovered address space to
the IANA in aggregated blocks of /24 or larger, for inclusion in the
recovered IPv4 pool."

The distinction is that under the revised version of 2009-3, recovered
space is returned after it is designated for return under local policies
and strategies. The original text dictated the terms of what must be
returned (everything /24 or larger) as part of the global policy.

Since global policy is supposed to only govern the relationship between
the IANA and the RIRs, and local policy defines what the RIR can do
internally. This change brings the proposal more in line with that
definition of a global policy, and should address a number of other
concerns as well.

As this is a global policy, it will need to be reconciled with the
version passed in the other RIRs. As this appears to be a substantive
change, that most likely means the other RIRs will need to go back and
pass the modified version as well.

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Below are 3 exemplar scenarios of the execution of this policy after
Phase II is in force. These are not part of the rationale but are
provided for illustrative purposes.

Example 1:



On 1 March 2020, IANA has the equivalent of a /17 (32,768 addresses)
worth of IPv4 addresses.

1. IANA calculates that 1/10 of this space is 3,276 addresses.

2. IANA rounds this down to the next bit boundary, which creates a
minimum allocation size of /21 (2,048 addresses).

3. Each RIR can request and receive a single allocation unit equivalent
to a /21 worth of addresses.

4. While IANA may not be able to allocate a contiguous /21 and can
allocate noncontiguous smaller blocks equivalent to a /21 worth of
addresses.

Example 2:

On 1 March 2020, IANA has the equivalent of a /20 (4,096 addresses)
worth of IPv4 addresses.

1. IANA calculates that 1/10 of this space is 409 addresses.

2. IANA rounds this down to the next bit boundary, which creates a
minimum allocation size of /24 (256 addresses).

3. Each RIR can request and receive a single allocation unit equivalent
to a /24 worth of addresses.

4. As the minimum size of address space returned to IANA is /24, IANA
can allocate a contiguous range of addresses that amount to a /24.

Example 3:

On 1 March 2020, IANA has the equivalent of a /21 (2,048 addresses)
worth of IPv4 addresses.

1. IANA calculates that 1/10 of this space is 204 addresses.

2. IANA rounds this down to the next bit boundary, which creates a
minimum allocation size of /25 (128 addresses).

3. A /25 is smaller than the minimum permissible allocation size under
this policy. A /25 is smaller than the minimum permissible allocation
size under this policy. Therefore, IANA is unable to make an allocation
until more address space is received.

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Timetable for implementation:

This policy is to be implemented immediately upon ratification by the
ICANN Board of Directors according to the global policy process
described in the ASO MoU.