[arin-ppml] Draft Policy 2009-8: Equitable IPv4 Run-Out

[Member Services]

Correction; there was a typo in the url.

Draft Policy 2009-8 can be found at:
https://www.arin.net/policy/proposals/2009_8.html

Regards,

Member Services
American Registry for Internet Numbers (ARIN)

Member Services wrote:
> Draft Policy 2009-8
> Equitable IPv4 Run-Out
>
> On 20 August 2009 the ARIN Advisory Council (AC) selected "Equitable
> IPv4 Run-Out" as a draft policy for adoption discussion on the PPML and
> at the Public Policy Meeting in Dearborn.
>
> The draft was developed by the AC from Policy Proposals "93: Predicable
> IPv4 Run Out by Prefix Size and 94: Predictable IPv4 Run Out by
> Allocation Window". Per the Policy Development Process the AC submitted
> text to ARIN for a staff and legal assessment prior to its selection as
> a draft policy. After reviewing the assessment the AC made several
> changes to the text.
>
> Draft Policy 2009-8 is below and can be found at:
> https://www.arin.net/policy/proposals/2009_8.htm
>
> Below the draft policy is the ARIN staff and legal assessment, including
> the original proposal text.
>
> You are encouraged to discuss Draft Policy 2009-8 on the PPML prior to
> the October Public Policy Meeting. Both the discussion on the list and
> at the meeting will be used by the ARIN Advisory Council to determine
> the community consensus for adopting this as policy.
>
> The ARIN Policy Development Process can be found at:
> https://www.arin.net/policy/pdp.html
>
> Draft Policies and Proposals under discussion can be found at:
> https://www.arin.net/policy/proposals/index.html
>
> Regards,
>
> Member Services
> American Registry for Internet Numbers (ARIN)
>
>
> ## * ##
>
>
> Draft Policy 2009-8
> Equitable IPv4 Run-Out
>
> Version/Date: 31 August 2009
>
> Policy statement:
>
> Replace NRPM 4.2.4.4 with;
>
> 4.2.4.4 Subscriber Members After One Year
>
> After an organization has been a subscriber member of ARIN for one year,
> they may choose to request up to a 12 month supply of IP addresses.
>
> As the IANA free pool decreases, the length of supply that an
> organization may request will be reduced at the following thresholds.
> This reduction does not apply to resources received via section 8.3. An
> organization receiving a transfer under section 8.3 may continue to
> request up to a 12 month supply of IP addresses.
>
> When IANA reaches 20 or fewer unallocated /8s, an organization may
> choose to request up to a 6 month supply of IP addresses;
>
> When IANA reaches 10 or fewer unallocated /8s, an organization may
> choose to request up to a 3 month supply of IP addresses;
>
> Create a new subsection in section 4 of the NRPM;
>
> 4.X Maximum Allocation or Assignment during and following Run-Out
>
> When ARIN receives its last /8, by IANA implementing section 10.4.2.2, a
> proportionally decreasing maximum allocation, and assignment, size will
> be put into effect. The maximum allocation will be the next whole CIDR
> prefix less than or equal to one quarter (1/4) of the total ARIN free
> pool available at the time of each allocation, but no longer than the
> applicable minimum allocation.
>
> An organization may request additional resources when it can demonstrate
> it has properly utilized all previous allocations per applicable
> policies. However, the total of all allocations received within the last
> three (3) month period and the current request, cannot exceed the
> current maximum allocation size.
>
> This maximum allocation size is applicable to allocations from the ARIN
> free pool only. It is explicitly not applicable to resources received
> via transfer under section 8.3, or any other specially designated 
> resources.
>
> Rationale:
>
> This proposed policy is intended to ensure an equitable distribution of
> IPv4 resources as run-out of the IANA free pool and subsequently the
> ARIN free pool occurs. This is achieved in two parts; first, changing
> section 4.2.4.4 of the NRPM to reduce the length of supply of IPv4
> resources that may be requested in steps as the IANA free pool runs-out.
> This helps accomplish equity by reducing the window that an advantage or
> disadvantage can exist between competitors, that will be created when
> one competitor receives a final allocation just before run-out and
> another competitor does not.
>
> The reductions in the length of supply will be triggered by IANA
> reaching defined levels of unallocated /8s, including the /8s reserved
> as part of section 10.4 of the NRPM. These triggers have been chosen
> base on the current rate of consumption of /8s by the RIRs.
>
> The first part of this policy is similar to ideas in RIPE policy
> proposal 2009-03
> (http://www.ripe.net/ripe/policies/proposals/2009-03.html), and has been
> adapted by discussion and for use within the ARIN region.
>
> The second part of this policy, allows a maximum of one quarter (1/4) of
> the then current total IPv4 resources to be allocated in a single
> request, once ARIN has received its last /8 from IANA. This helps
> achieve equity by ensuring the available resources are spread among
> multiple organizations and that no single organization may monopolize
> all of the resources available through a single request, at least until
> the maximum allocation size has been reduced down to the minimum
> allocation size.
>
> Incrementally reducing the length of supply and then reducing the
> maximum allocation size in proportion to the amount of resources
> available should minimize, or possibly eliminate, the need to fulfill
> requests with multiple smaller blocks.
>
> As in the current NRPM, the length of supply only applies to ISP
> allocations. However, the maximum allocation size is intended to apply
> to both ISP allocations and End-user assignments.
>
> This policy is intended to be independent of other policies or proposals
> to reserve address space for IPv6 transition or other purposes. Neither
> part is intended to limit Transfers to Specified Recipients per section
> 8.3 of the NRPM.
>
> The current maximum allocation size should be published on the ARIN
> website, preferably in real-time, as it may change rapidly as the ARIN
> free pool resources are exhausted. In the worst-case the maximum
> allocation size will decrease every forth allocation, when all four are
> the then current maximum allocation size. However, in the beginning
> there will likely be many smaller allocations before the maximum
> allocation size is decreased, accelerating as the resources are 
> exhausted.
>
> Following the run-out phase, this policy provides an equitable means of
> distribution of resources if or when additional resources become
> available after ARIN has initially exhausted such resources. Such as if
> resources are returned, recovered by other means, or additional
> resources are obtained from IANA. Further, whenever ARIN receives a
> sufficiently large amount of additional resources, this policy intends
> for the maximum allocation size to be increased accordingly.
>
> After ARIN receives its last /8, the intent is to normally limit an
> organization to a single maximum allocation within a three month period.
> However, saying it that simply opens this policy to gamesmanship in
> requesting less than a maximum allocation. Requiring a maximum
> allocation to cover new requests and all allocations received in the
> previous three month period, should eliminate this kind of gamesmanship.
>
> There is a beneficial side effect of stating it this way, in the special
> situation when the maximum allocation size is increased, due to ARIN
> obtaining a sufficiently large amount of additional resources, an
> organization may receive additional resources earlier than the normal
> three month period. But, only in this special situation and when an
> organization properly utilizes a previous maximum allocation in less
> than three months, may an organization receive additional resources in
> less than the normal three month period.
>
> Other ratios, such as one half (1/2) or one eighth (1/8) could be
> considered. One eighth (1/8) would provide greater assurance of
> eliminating the need to use multiple blocks to fulfill requests and
> ensure a greater number of organizations receive resources. However, one
> eighth (1/8) is more likely to be seen as rationing and an attempt to
> artificially extend the lifetime of IPv4. During the ARIN XXIII policy
> discussion there seemed to be a consensus that attempts to extend the
> lifetime of IPv4 resources would be undesirable. While on the other
> hand, one half (1/2) is even less likely to ration resources, but it
> would likely result in the resource being spread across significantly
> fewer organizations and increase the need to use multiple blocks to
> fulfill requests.
>
> In conclusion, combining the final 3 month length of supply with the one
> quarter (1/4) ratio provides roughly an annualized equivalent of the
> whole ARIN free pool being made available to a single organization.
> While it is not possible for a single organization to receive the whole
> ARIN free pool within one year under this policy, it is a virtual
> certainty that multiple organization will be requesting resources, and
> that the ARIN free pool will not likely last a full year following the
> exhaustion of the IANA free pool anyway. Therefore, the ratio one
> quarter (1/4) seems to strike a balance between making resources
> available with as little restriction as possible and ensuring an
> equitable distribution of those resources during and following the
> run-out phase.
>
> EDITORIAL NOTE: This Draft Policy 2009-8 merges ideas from two separate
> policy proposals, 93. Predicable IPv4 Run Out by Prefix Size and 94.
> Predictable IPv4 Run Out by Allocation Window.
>
> Timetable for implementation: Immediate
>
> #####
> #####
>
> Proposal: Equitable IPv4 Run-Out
>
> Proposal Version (Date): 3 August 2009
>
> Date of Assessment:  18 August 2009
>
> 1. Proposal Summary (Staff Understanding)
> Staff understands the policy applies to ISPs who have been ARIN members
> for more than a year. When IANA reaches 20 /8s, the supply period for
> IPv4 address space will decrease from a 12 months to 6 months. When the
> IANA reaches 10 or less /8s,  the supply period is reduced to 3 months.
> The second part of the proposal triggers upon receipt of ARIN’s last /8
> from the IANA (per NRPM 10.4.2.2). The policy would establish a new
> maximum prefix size for all requests and place a limit on the amount of
> space an organization can receive  within any three month period. The
> maximum prefix size would be on a sliding  scale relative to the total
> amount of free IPv4 addresses in ARIN's inventory (one  fourth of the
> total rounded down to the nearest smallest CIDR prefix). These polices
> do not apply to Transfers to Specified Recipients (NRPM 8.3).
>
> 2. Comments
>
> A.  ARIN Staff Comments
>
>   The policy can be implemented as written.
>
>   The title of section 4.2.4.4 needs to change from “Twelve Months” to
> “Subscriber Members After One Year”.
>
>   Note that the maximum prefix size in effect at any given time (e.g.
> /16) may be larger than the largest available contiguous address block
> in ARIN’s inventory (e.g. /18). In order to fulfill a request in this
> scenario, ARIN would have to issue several discontiguous address blocks.
>
>   There is a suggestion in the rationale to display the maximum prefix
> size in real time. But that prefix size might not be available upon
> completion of a request. Example, on Friday we display /18. By the time
> the request is finalized, the maximum is a /19, and that’s what is
> issued to the customer.  We could put a disclaimer that the actual
> prefix issued to a customer could be  smaller. Also, we see value in
> keeping track of the maximum prefix size over time.
>
>   The third sentence of the proposed 4.2.4.4 (starting with "This
> reduction") is a run-on sentence and contains grammatical errors. ARIN
> staff suggests the  following replacement text: “This reduction does not
> apply to resources received via section 8.3. Organizations requesting
> transfers under 8.3 may choose to request up to a 12-month supply of IP
> addresses.”
>
> B. ARIN General Counsel
>
>   ARIN has the legal duty and authority to establish more restrictive
> rules to “ration” the issuance of IPv4 resources as the scarcity of such
> resources increases.  However, such rules must make clear rational sense
> given current circumstances, and may be tested in litigation by
> disappointed parties at the time they come fully into effect, not when
> adopted.  Therefore, the proposed policy here will need to be carefully
> reviewed and if passed, carefully implemented, for example, to prevent
> any “side effect” that would inadvertently favor one set of ISPs over
> another.
>
> 3. Resource Impact
>
> This policy would have minimal resource impact.  It is estimated that
> implementation would occur within 3 months after ratification by the
> ARIN Board of Trustees. The following would be needed in order to
> implement:
>   Updates to software
>   Updated guidelines
>   Staff training
>
> 4. Proposal Text
>
> Equitable IPv4 Run-Out
>
> Date: 3 August 2009
>
> Policy statement:
>
> Replace the text in NRPM 4.2.4.4 with;
>
> After an organization has been a subscriber member of ARIN for one year,
> they may choose to request up to a 12 month supply of IP addresses. As
> the IANA free pool decreases, the length of supply that an organization
> may request will be reduced at the following thresholds. This reduction
> does not apply to  resources received via Transfers to Specified
> Recipients per section 8.3, in this case  an organization may continue
> choose to request up to a 12 month supply of IP addresses.
>
> When IANA reaches 20 or fewer unallocated /8s , an organization may
> choose to request up to a 6 month supply of IP addresses;
>
> When IANA reaches 10 or fewer unallocated /8s , an organization may
> choose to request up to a 3 month supply of IP addresses;
>
> Create a new subsection in section 4 of the NRPM;
>
> 4.X Maximum Allocation or Assignment during and following Run-Out
>
> When ARIN receives its last /8, by IANA implementing section 10.4.2.2, a
> proportionally decreasing maximum allocation, and assignment, size will
> be put into effect. The maximum allocation will be the next whole CIDR
> prefix less than or equal to one quarter (1/4) of the total ARIN free
> pool available at the time of each  allocation, but no longer than the
> applicable minimum allocation. An OrgID may request additional resources
> when it can demonstrate it has properly  utilized all previous
> allocations per applicable policies. However, the total of all
> allocations received within the last three (3) month period and the
> current request, cannot exceed the current maximum allocation size.
> This maximum allocation size is applicable to allocations from the ARIN
> free pool only, and is explicitly not applicable to resources received
> through Transfers to Specified Recipients per section 8.3, or any other
> specially designated resources.
>
> Rationale:
>
> This proposed policy is intended to ensure an equitable distribution of
> IPv4 resources as run-out of the IANA free pool and subsequently the
> ARIN free pool occurs. This is achieved in two parts; first, changing
> section 4.2.4.4 of the NRPM to reduce the length of supply of IPv4
> resources that may be requested in steps as the IANA free pool runs-out.
> This helps accomplish equity by reducing the window that an advantage or
> disadvantage can exist between competitors, that will be created
> when one competitor receives a final allocation just before run-out and
> another competitor does not.
>
> The reductions in the length of supply will be triggered by IANA
> reaching defined levels of unallocated /8s, including the /8s reserved
> as part of section 10.4 of the NRPM. These triggers have been chosen
> base on the current rate of consumption of /8s by the RIRs.
>
> The first part of this policy is similar to ideas in RIPE policy
> proposal 2009-03
> (http://www.ripe.net/ripe/policies/proposals/2009-03.html), and has been
> adapted by discussion and for use within the ARIN region.
>
> The second part of this policy, allows a maximum of one quarter (1/4) of
> the then current total IPv4 resources to be allocated in a single
> request, once ARIN has  received its last /8 from IANA. This helps
> achieve equity by ensuring the available resources are spread among
> multiple organizations and that no single organization may monopolize
> all of the resources available through a single request, at least
> until the maximum allocation size has been reduced down to the minimum
> allocation size.
>
> Incrementally reducing the length of supply and then reducing the
> maximum allocation size in proportion to the amount of resources
> available should minimize, or possibly eliminate, the need to fulfill
> requests with multiple smaller blocks.
>
> As in the current NRPM, the length of supply only applies to ISP
> allocations. However, the maximum allocation size is intended to apply
> to both ISP allocations and End-user assignments.
>
> This policy is intended to be independent of other policies or proposals
> to reserve address space for IPv6 transition or other purposes. Neither
> part is intended to limit Transfers to Specified Recipients per section
> 8.3 of the NRPM.
>
> The current maximum allocation size should be published on the ARIN
> website, preferably in real-time, as it may change rapidly as the ARIN
> free pool resources are exhausted. In the worst-case the maximum
> allocation size will decrease every forth allocation, when all four are
> the then current maximum allocation size. However, in the beginning
> there will likely be many smaller allocations before the maximum
> allocation size is decreased, accelerating as the resources are 
> exhausted.
>
> Following the run-out phase, this policy provides an equitable means of
> distribution of resources if or when additional resources become
> available after ARIN has  initially exhausted such resources. Such as if
> resources are returned, recovered by other means, or additional
> resources are obtained from IANA. Further, whenever ARIN receives a
> sufficiently large amount of additional resources, this policy
> intends for the maximum allocation size to be increased accordingly.
>
> After ARIN receives its last /8, the intent is to normally limit an
> organization to a single maximum allocation within a three month period.
> However, saying it that simply opens this policy to gamesmanship in
> requesting less than a maximum allocation. Requiring a maximum
> allocation to cover new requests and all allocations received in the
> previous three month period, should eliminate this kind
> of gamesmanship.
>
> There is a beneficial side effect of stating it this way, in the special
> situation when the maximum allocation size is increased, due to ARIN
> obtaining a sufficiently large amount of additional resources, an
> organization may receive additional resources earlier than the normal
> three month period. But, only in this special situation and
> when an organization properly utilizes a previous maximum allocation in
> less than three months, may an organization receive additional resources
> in less than the normal three month period.
>
> Other ratios, such as one half (1/2) or one eighth (1/8) could be
> considered. One eighth (1/8) would provide greater assurance of
> eliminating the need to use multiple blocks to fulfill requests and
> ensure a greater number of organizations receive resources. However, one
> eighth (1/8) is more likely to be seen as rationing and an attempt to
> artificially extend the lifetime of IPv4. During the ARIN XXIII policy
> discussion there seemed to be a consensus that attempts to extend the
> lifetime of IPv4 resources would be undesirable. While on the other
> hand, one half (1/2) is even less likely to ration resources, but it
> would likely result in the resource being spread across significantly
> fewer organizations and increase the need to use multiple blocks
> to fulfill requests.
>
> In conclusion, combining the final 3 month length of supply with the one
> quarter (1/4) ratio provides roughly an annualized equivalent of the
> whole ARIN free pool being made available to a single organization.
> While it is not possible for a single organization to receive the whole
> ARIN free pool within one year under this policy, it is a virtual
> certainty that multiple organization will be requesting resources, and
> that the ARIN free pool will not likely last a full year following the
> exhaustion of the IANA free pool anyway. Therefore, the ratio one
> quarter (1/4) seems to strike a balance between making resources
> available with as little restriction as possible and ensuring an
> equitable distribution of those resources during and following the
> run-out phase.
>
> EDITORIAL NOTE: This Draft Policy 2009-X merges ideas from two separate
> policy proposals, 93. Predicable IPv4 Run Out by Prefix Size and 94.
> Predictable IPv4 Run Out by Allocation Window.
>
> Timetable for implementation: Immediate
>
>
>
>
>
>
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