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ARIN 32 Draft Policy preview and predictions

arin32logoThe joint ARIN 32 & Nanog 59 meeting is coming up next week.  There are a number of substantive public policy items on the scheduled agenda.  If you are unable to come to the meeting please consider the remote participation option to have your opinion heard.

Here is my short commentary on the policy proposals being discussed at the meeting.  In this blog entry, I’ve also attempted to make some predictions on the discussion and outcome…

2013-4 RIR Principles

Policy Summary: This draft policy adds a section to the NRPM which would provide guiding direction for ARIN’s registry functions.  The core of these principles were originally found in RFC 2050, but the new draft 2050bis which was recently published as RFC 7020 removed a majority of these guiding principles.

Issues: The majority of the discussion about this policy has centered on two aspects.  1) Should this type of text be inserted at all into the NRPM or is already overlapping with ARIN’s mission statement and text in the Policy Development Process (PDP)?  2) Does the draft policy accurately reflect today’s guiding principles for the RIRs (specifically ARIN) registry functions?  Important issues that have been raised here center around the issue of “stewardship” & “conservation” and how that aspect should be documented in a IPv4 runout RIR.

Prediction: This policy will reach consensus at this meeting and will be sent to last-call for approval.  I suspect there will perhaps be some minor adjustments to the text to accommodate any issues raised during the policy discussion.

2013-6 Allocation of IPv4 and IPv6 Address Space to Out-of-region Requestors

Policy Summary:   This draft policy inserts text into the NRPM which would restrict future IP allocations and assignments to organizations who have a legal presences and substantially operate their network(s) inside the ARIN service region.

Issues: This policy originated from ARIN staff comment at the ARIN 31 meeting.  ARIN staff reported that they were seeing increasing numbers of requests from organizations where the IP address were likely to be used outside the ARIN service region or be assigned to customers outside the ARIN service region.  Staff comments on this draft policy indicate this proposed text would restrict the disbursement of resources to legal entities operating within the ARIN service region.

The key issue in this draft policy is the statement:

a plurality of new resources requested from ARIN must be justified by technical infrastructure or customers located within the ARIN service region

Staff comments reveal that this policy as currently written would “create a scenario where a network can’t get IPv4/IPv6 addresses from any RIR.”  Legal review also made note of this issue with this comment: “points of policy to avoid … adopting an overly prescriptive guidance or standard that fails to permit multinational business entities to obtain number resources.”  This is certainly not a desired outcome of the draft policy and I believe must be rectified.

While I believe ARIN staff would benefit from the additional clarity in this draft policy, I doubt this issue will be of as substantial importance after IPv4 exhaustion occurs in the ARIN region.

Prediction: I believe this policy will not achieve consensus at this meeting.  I think there will be significant dissent from the meeting participants to move forward with the current text.  I suspect if the “plurality” statement was removed from the policy it would likely achieve consensus or near consensus such that the policy would continue to move forward through the PDP.

2013-7 Merge IPv4 ISP and End-User Requirements

Policy Summary:   This draft policy makes numerous changes to the existing IPv4 policy which attempts to merge the differences between the ISP and End-User allocation & assignment policies.

Issues: The changes made in this draft policy are complex and intertwined.  It is easiest to see the proposed changes in this red-line version.

https://www.arin.net/policy/proposals/ARIN-prop-190%20proposed_text_changes.pdf

While I believe the general plan to attempt cleanup and streamlining of the IPv4 policy are headed in the right direction, I suspect the changes will not necessarily be well understood by the ARIN community and some skepticism will come about that the changes don’t necessarily all move in the right direction.  In general, this policy seems to loosen the requirements on organizations receiving IPv4 addresses, however these two changes are substantially different.

The utilization requirements on an initial end-user assignment changes from 25% immediate, 50% within one year to 80% within three months. This is offset by the lowering of the minimum block size requirement for single-homed networks.

This change seems to go against the idea of making it easier for initial end-user assignments, but this text changes the initial host count for single subnet from 1024 hosts immediately (25% of a /20) to 819 hosts in 3 months (80% of /22).

The timeframe for additional ISP allocations is changed from three months back to one year.

This change has been suggested a number of times, including 2012-4, since the 2009-8 policy put this into place.  In each instance, consensus generally has been toward not to keep changing the IPv4 requirements as IPv4 exhaustion occurs.

Prediction: I believe this policy will not achieve consensus at this meeting due to the large number of changes being proposed.  I suspect the draft policy will continue to be worked on by the AC and that the text will be updated subsequently and be presented at the next Public Policy Consultation (PPC).

 

ARIN 31 Draft Policy preview and predictions

ARIN 31The spring ARIN 31 meeting is fast approaching.    The final meeting agenda has recently been published. There are also opportunities to participate remotely for those who are unable to make the meeting in person.

Here is my short commentary on the policy proposals being discussed at the meeting.  In this blog entry, I’ve also attempted to make some predictions on the discussion and outcome…

2012-2 IPv6 subsequent allocations

Policy Summary: Changes the way utilization is determined for ISPs who return to ARIN for additional IPv6 allocations.

Issues: Since the initial IPv6 policy was implemented, it has been  understood that the IPv6 policy would need to be modified as implementation experience was gained.  Since the idea of hierarchy is important in IPv6 networks, this policy allows a network’s regions which grow at different speeds to retain the hierarchy structure and still allow fast growing regions to obtain the needed additional IPv6 address space.  Since the draft policy’s introduction there was strong consensus that the existing policy needed to change, the challenge has always been the details of policy text.

Prediction: This policy will finally reach consensus at this meeting and will be sent to last-call for approval.

2013-1 Inter-RIR transfers of ASNs

Policy Summary: Allows organizations to request to transfer an autonomous system number (ASN) from one RIR to another.

Issues: ARIN recently adopted policies which both allow the directed transfer of IPv4 between regions and also allowed the directed transfer of ASNs within the ARIN region. This policy extends this trend to allow ASNs to transfer between RIRs.  Some stakeholders in general disagree with the idea of allowing IP resources to trade and will likely oppose this policy.  On the other side are those who will argue that this policy is a logical extension of the existing policy to allow resources to be transferred to where they are needed.

Prediction: This policy will have signification discussion about the need for the policy and the role of inter-RIR relationships, but I suspect the final consensus at the meeting will be to proceed with the implementation of this draft policy.

2013-2 3GPP IP Resource Policy

Policy Summary: Allows organizations to use a lower utilization requirement for provisioning their 3GPP networks when requesting additional IP addresses.

Issues: Wireless operators have been using space beyond RFC 1918 (such as 1.0.0.0/8) to solve their addressing needs and now that this is becoming part of the “Internet” they need to move off of that space. With ARIN’s /8 inventory currently at approximately 2.5, I’m skeptical that any policy using global IPv4 unicast space can actually solve this problem.   The policy text of this draft policy is also not complete at this time and if consensus is achieved on the concepts of the policy change this draft policy would have to return for discussion at another ARIN meeting.

Prediction: This policy will be abandoned by the AC following the meeting.

2013-3 Tiny IPv6 Allocations for ISPs

Policy Summary: Allows ISPs to request smaller than normal IPv6 address blocks or return larger IPv6 blocks to reduce their IPv6 holdings.

Issues: This draft policy addresses an issue where ISPs are being moved into a larger ARIN fee category under the new fee schedule and allows them to return address space to move to a smaller IPv6 fee category.  There has been significant discussion on the PPML mailing list about this issue and at this point it seems unclear if this proposal will achieve consensus at the meeting.   The primary argument against this policy is that this policy undermines the best current practices for IPv6 subnetting, the intended hierarchical addressing structure defined by the IETF in the IPv6 RFCs, and generous nature of intended IPv6 assignments to end-users.  Some stakeholders will argue that ARIN’s fees shouldn’t be used as a force to dictate a network’s IPv6 architecture.   Arguments for the policy are that some small ISPs don’t need and never will use the current minimum block size of a /32 or /36 and should be able to get a /48 which meets their network needs.

Prediction: This policy will be sent to last call by the AC following the meeting.  (I suspect it is possible that the /48 option will be removed from the draft policy as part of the discussion)

 

ARIN XXIX meeting update

ARIN’s XXIX regional meeting in Vancouver, Canada concluded last week.  A couple of notable discussions occurred.

An updated IPv4 transfer policy 2012-1 was discussed alongside the 2011-1 inter-RIR transfer policy which is pending implementation and board adoption.  ARIN staff noted that the inter-RIR transfer policy will be ready for implementation in about 90 days.  I expect that the ARIN board will implement and move forward with implementing inter-RIR transfers using the revised 2012-1 text which is currently in last call on the public policy mailing list.

A policy 2012-3 to allow ASN numbers to be transferred in a method similar to the existing IPv4 transfers was recommended for last call.  While the circumstances for transfer are different compared with IPv4 transfers, ARIN’s general counsel is recommending that adopting the policy reduces legal liability for ARIN.  During the meeting it was also noted that there is an existing bankruptcy case pending which contains an ASN which has been requested to be transferred.  It seems likely that the board will adopt this policy in due time.

Finally, the community considered a policy 2012-4 to reverse the current 3 month supply restriction on IPv4 allocations.  This policy would have modified the policy to allow a 12-month supply while ARIN has at least a /8 equivalent in its free pool.  This policy would likely have caused the run-out in the ARIN region to proceed faster.  The policy was recently abandoned by the Advisory Council which indicates the current 3 month supply policy is likely to continue until ARIN’s IPv4 free pool is exhausted.