Next week is the ARIN 37 meeting in Jamaica. Here is my look ahead at the policies being discussed at the meeting. There is one recommended draft that will be discussed along with five other draft policies. If you aren’t going to be there in person check out the remote participation options.
2015-3 Remove 30 day utilization requirement in end-user IPv4 policy (Recommended Draft)
Policy Summary: This draft policy removes the 30 day usage requirement for IPv4 end-users.
Discussion: This policy is intended to remove what has been considered an onerous requirement on end-users. Under current policy an end-users is supposed to put 25% of their block into use with 30 days, based upon a 1 year allocation. This requirement has always been very hard for organizations to meet and has skewed the allocation sizes downward. With end-users now forced to obtain assignments via the transfer market, this policy provision is even more restrictive.
Commentary: There has been some opposition to this policy because a few contributors believe there should be some near-term requirement for organizations which do not have any assignment history with ARIN. However, I believe most people support removing this requirement.
2015-2 Inter-RIR Transfers to Specified Recipients
Policy Summary: This policy allows an organization which receives a transfer in the ARIN region to transfer it to another RIR within 24 months of receiving the transfer.
Discussion: The policy is intended to benefit large organizations which receive a block via transfer in the ARIN region and then want to transfer it to a subsidiary or other entity in another region. This is needed for some organizations which wanted to move address blocks to regions/countries which required the addresses be registered in a local NIR before they can be used. Language was added to the policy requiring the receiving organization be a subsidiary, but despite attempt to finalize the draft language legal issues were raised prevented which the policy from becoming a recommended draft.
2015-7 Simplified requirements for demonstrated need for IPv4 transfers
Policy Summary: Replaces the needs test for transfers with an officer’s attestation to 50% use within 24 months.
Discussion: This policy is intended to loosen the transfer requirements, but leave the other transfer qualification methods intact in case an organization want to use them. This policy has seen limited support on the mailing list. The ARIN AC is looking for if there is sufficient support for the ideas within this policy before proceeding to move this policy to recommended. Issues raised included concern that the 50% utilization level is way to low. In general, this policy and 2015-9 are supported by organizations which believe in lessening the needs-basis requirements for IPv4 transfers, but not supported by those who believe that the current needs-based requirements are still working and providing value so they should be retained.
Commentary: I personally like the idea of loosening the needs-basis requirements toward officer attestations of use as long as there is a requirement that the address blocks be used on an operational network. We could quibble about the utilization levels, but 50% per block seems like the lowest one could go and still have the utilization rate be meaningful. 80% has been the requirement for a long time and retaining that level could be beneficial in bridging the gap for those who would otherwise not support the policy.
2015-9 Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers
Policy Summary: Removes needs-based testing from the transfer policy.
Discussion: This policy has been supported and not supported by the “usual” sides in this debate. This policy was recently proposed for abandonment during the March AC’s meeting, but that motion failed. Most of the issue revolved around the lack of formal support for this policy. The AC will be looking for statements of support at the upcoming meeting to see if there is a path forward for this policy. The text of the policy has not really changed much since the last meeting, other than removing Inter-RIR transfers from the policy as to not upset the interdependent policies between RIRs.
Commentary: I have specifically noted two issues which I believe should be addressed in this policy. 1. I believe there should be a base requirement that address blocks should only be transferred to organizations which intend to use them on an operational network. 2. I don’t like how the policy is constructed from a textual perspective. The policy uses the phrase “excluding any policies related to needs-based justification” While I think I know what that means, there is no definitive definition of what exactly constitutes a “needs-basis policy.” We should be constructing clear text which clearly states any requirements for a transfer.
2016-1 Reserve pool transfer policy
Policy Summary: Restricts the ability to transfer IPv4 blocks which are received from reserved pools including the critical infrastructure pool (4.4) and the IPv6 transition pool (4.10).
Discussion: This is a new policy which grew out of a discussion at the last NANOG meeting in San Diego. It was noted by some of the participants there that these reserved blocks could be transferred and that was perhaps not what the authors of the reserved block policy had intended. The current practice allows an organization to obtain a block for a specific purpose and then transfer it to another organization which can use it without restrictions. The IPv6 transition block was also intended to allow block sizes smaller than /24. Some contributors believe that if blocks are allowed to be transferred some operators won’t lower their filters to allow these smaller blocks to propagate in BGP.