ARIN-2018-2

Status: Under Discussion

Staff and Legal Review: 11 October 2018

Advisory Council Shepherds: Rob Seastrom, Kerrie Richards

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History:

Advisory Council Meetings:

Presented at:

Latest Version: 26 February 2019

AC Assessment of Conformance with the Principles of Internet Number Resource Policy:

This Recommended Draft Policy is technically sound and is fair and impartial number policy. This draft policy is an attempt to clarify the changes that came about from 2016-4. It also aligns section 4.2 with current transfer policy. It also re-established the understanding that ISP can renumber and return, by putting the last section 4.2.2.1.4 into the ISP additional requests section. The policy text has been changed and the proposed section 4.2.2.1.4 was deleted in its entirety.

Problem Statement:

As discussed in more detail in ARIN-2017-9 and noted in the ARIN 40 Policy Experience Report, the criteria to qualify for an initial block of address space in 4.2.2 and 8.5.4 are seeming at odds with each other. At ARIN 41 the community seemed to prefer the approach contained in this policy over the approach in ARIN-2017-9, which was subsequently abandoned.

Moreover, as the NRPM (2018-1) currently sits, 4.2.2 appears to state that an initial allocation of up to a /21 could be granted without any more justification than needed to qualify for a /24. Therefore, 4.2.2 should be modified, allowing an initial allocation of only a /24 without any additional justification and allowing an initial allocation of up to a /21 when justified by a 24-month allocation plan.

Policy Statement:

Replace the current Section 4.2.2 with:

4.2.2. Initial allocation to ISPs

All ISP organizations without direct assignments or allocations from ARIN qualify for an initial allocation of up to a /21, subject to ARIN’s minimum allocation size.

All ISP organizations without direct allocations, direct assignments, re-allocations or reassignments automatically qualify for a /24. These organizations are exempt from requirements of showing the efficient utilization of previously held IPv4 space. These organizations may qualify for a larger than a /24 by documenting how the requested allocation will be utilized within the request size specified in 4.2.4.3

ISPs holding re-allocations and/or reassignments must show the efficient utilization of their resources consistent with the requirements in sections 4.2.3 and 4.2.4

Comments:

Timetable for Implementation: Immediate

Anything Else:

This is an attempt to clarify the changes that came about from 2016-4. It also aligns section 4.2 with current transfer policy. It also re-established the understanding that ISP can renumber and return, but putting the last section 4.2.2.1.4 into the ISP additional requests section. This text is slightly modified to include returns to ARIN in addition to returns to the upstream.

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Earlier Version

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Version Date: 15 November 2018

AC Assessment of Conformance with the Principles of Internet Number Resource Policy:

This Recommended Draft Policy is technically sound and is fair and impartial number policy. This draft policy is an attempt to clarify the changes that came about from 2016-4. It also aligns section 4.2 with current transfer policy. It also re-established the understanding that ISP can renumber and return, by putting the last section 4.2.2.1.4 into the ISP additional requests section. The policy text has been changed and the proposed section 4.2.2.1.4 was deleted in its entirety.

Problem Statement:

As discussed in more detail in ARIN-2017-9 and noted in the ARIN 40 Policy Experience Report, the criteria to qualify for an initial block of address space in 4.2.2 and 8.5.4 are seeming at odds with each other. At ARIN 41 the community seemed to prefer the approach contained in this policy over the approach in ARIN-2017-9, which was subsequently abandoned.

Moreover, as the NRPM (2018-1) currently sits, 4.2.2 appears to state that an initial allocation of up to a /21 could be granted without any more justification than needed to qualify for a /24. Therefore, 4.2.2 should be modified, allowing an initial allocation of only a /24 without any additional justification and allowing an initial allocation of up to a /21 when justified by a 24-month allocation plan.

Policy Statement:

Replace the current Section 4.2.2 with:

4.2.2. Initial allocation to ISPs

All ISP organizations without direct assignments or allocations from ARIN qualify for an initial allocation of up to a /21, subject to ARIN’s minimum allocation size.

All ISP organizations without direct allocations, direct assignments, re-allocations or reassignments automatically qualify for a /24. These organizations are exempt from requirements of showing the efficient utilization of previously held IPv4 space. These organizations may qualify for up to and including a /21 by documenting how the requested allocation will be utilized within the request size specified in 4.2.4.3

ISPs holding re-allocations and/or reassignments must show the efficient utilization of their resources consistent with the requirements in sections 4.2.3 and 4.2.4

Comments:

The timetable for Implementation: Immediate

Anything Else:

This is an attempt to clarify the changes that came about from 2016-4. It also aligns section 4.2 with current transfer policy. It also re-established the understanding that ISP can renumber and return, but putting the last section 4.2.2.1.4 into the ISP additional requests section. The policy text has been changed and the proposed section 4.2.2.1.4 was deleted in its entirety.

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Earlier Version

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Version Date: 23 June 2018

Problem Statement:

As discussed in more detail in ARIN-2017-9 and noted in the ARIN 40 Policy Experience Report, the criteria to qualify for an initial block of address space in 4.2.2 and 8.5.4 are seeming at odds with each other. At ARIN 41 the community seemed to prefer the approach contained in this policy over the approach in ARIN-2017-9, which was subsequently abandoned.

Moreover, as the NRPM (2018-1) currently sits, 4.2.2 appears to state that an initial allocation of up to a /21 could be granted without any more justification than needed to qualify for a /24. Therefore, 4.2.2 should be modified, allowing an initial allocation of only a /24 without any additional justification and allowing an initial allocation of up to a /21 when justified by a 24-month allocation plan.

Policy Statement:

Replace the current Section 4.2.2 with:

4.2.2. Initial allocation to ISPs

All ISP organizations without direct assignments or allocations from ARIN qualify for an initial allocation of up to a /21, subject to ARIN’s minimum allocation size.

All ISP organizations without direct allocations, direct assignments, re-allocations or reassignments automatically qualify for a /24. These organizations are exempt from requirements of showing the efficient utilization of previously held IPv4 space. These organizations may qualify for a larger than a /24 by documenting how the requested allocation will be utilized within the request size specified in 4.2.4.3

ISPs holding re-allocations and/or reassignments must show the efficient utilization of their resources consistent with the requirements in sections 4.2.3 and 4.2.4

Comments:

The timetable for Implementation: Immediate

Anything Else:

This is an attempt to clarify the changes that came about from 2016-4. It also aligns section 4.2 with current transfer policy. It also re-established the understanding that ISP can renumber and return, but putting the last section 4.2.2.1.4 into the ISP additional requests section. This text is slightly modified to include returns to ARIN in addition to returns to the upstream.

##########

Earlier Version

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Version Date: 20 March 2018

Problem Statement:

The criteria to qualify for an initial block of address space in 4.2.2 and 8.5.4 are at odds with each other.

Moreover, as the NRPM (2018-1) currently sits, 4.2.2 appears to state that an initial allocation of up to a /21 could be granted without any more justification than needed to qualify for a /24.

Policy Statement:

Replace the current Section 4.2.2 with:

4.2.2. Initial allocation to ISPs

All ISP organizations without direct assignments or allocations from ARIN qualify for an initial allocation of up to a /21, subject to ARIN’s minimum allocation size.

All ISP organizations without direct allocations, direct assignments, re-allocations or reassignments automatically qualify for a /24. These organizations are exempt from requirements of showing efficient utilization of previously held IPv4 space. These organizations may qualify for a larger than a /24 by documenting how the requested allocation will be utilized within the request size specified in 4.2.4.3

ISPs holding re-allocations and/or reassignments must show efficient utilization of their resources consistent with the requirements in sections 4.2.3 and 4.2.4

Comments:

Timetable for Implementation: Immeddiate

Anything Else:

This is an attmept to clarify the changes that came about from 2016-4.

It also aligns section 4.2 with current transfer policy.

It also also re-established the undertsanding that ISP can renumber and retrun, but putting the last section 4.2.2.1.4 into the ISP additional requests section. This text is slightly modified to include returns to ARIN in addition to returns to the upstream.

ARIN STAFF & LEGAL ASSESSMENT

Draft Policy ARIN-2018-2

Clarification to ISP Initial Allocation and Permit Renumbering

https://arin.net/policy/proposals/2018_2.html

Date of Assessment: 11 October 2018


  1. Summary (Staff Understanding)

Draft Policy 2018-2 NRPM section 4.2.2 Initial allocation to ISPs provides the criteria that organizations without direct assignments for allocations from ARIN must meet in order to receive an initial amount of IPv4 address space. It states very clearly that all ISP organizations without direct allocations, direct assignments, re-allocations or reassignments automatically qualify for a /24 of IPv4 space. These organizations may qualify for more than a /24 but no more than a /21 of IPv4 space by providing documentation on how the space will be utilized following the guidance in NRPM 4.2.4.3 which today states up to a 24-month supply of IPv4 addresses. DP 2018-2 provides guidance for ISPs that hold re-allocations and/or assignments by stating that they must show efficient utilization of their resources consistent with the requirements of 4.2.3 and 4.2.4.


  1. Comments

A. ARIN Staff Comments

This is a very straight forward change to NRPM 4.2.2. Initial allocation to ISPs and will be easy to implement if approved. Once implemented ARIN staff will be able to approve an initial allocation of a /24 to any ISP that applies and does not currently have a direct assignment, allocation, re-allocation or reassignment. ISPs may qualify for a larger block by providing documentation of utilization in accordance with NRPM 4.2.4.3.

Organizations that currently hold IPv4 resources must show efficient utilization of their current resources consistent with the requirements of 4.2.3 and 4.2.4 in order to qualify for additional IPv4 address space.

It would be more clear for the community to repeat the /21 maximum in the 3rd sentence of the 2nd paragraph so that it reads”These organizations may qualify for up to and including a /21 by documenting how the requested allocation will be utilized within the request size specified in 4.2.4.3”

It is recommended that the title be changed to drop the “and Permit Renumbering” and that the Anything Else: portion of the proposal be updated to reflect that the policy text has been changed and the proposed section 4.2.2.1.4 was deleted in its entirety.

This policy does align this section with current transfer policy language.

B. ARIN General Counsel – Legal Assessment

There are no material legal issues regarding this proposal.

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  1. Resource Impact

Implementation of this policy would have minimal impact. It is estimated that implementation could occur within 3 months after ratification by the ARIN Board of Trustees. The following would be needed in order to implement:

  • Updated guidelines and internal procedures

  • Staff training

  • None to minimum engineering work will be required


  1. Proposal/Draft Policy Text Assessed

Draft Policy 2018-2: Clarification to ISP Initial Allocation and Permit Renumbering

Version Date: 23 June 2018

Problem Statement:

As discussed in more detail in ARIN-2017-9 and noted in the ARIN 40 Policy Experience Report, the criteria to qualify for an initial block of address space in 4.2.2 and 8.5.4 are seeming at odds with each other. At ARIN 41 the community seemed to prefer the approach contained in this policy over the approach in ARIN-2017-9, which was subsequently abandoned.

Moreover, as the NRPM (2018-1) currently sits, 4.2.2 appears to state that an initial allocation of up to a /21 could be granted without any more justification than needed to qualify for a /24. Therefore, 4.2.2 should be modified, allowing an initial allocation of only a /24 without any additional justification and allowing an initial allocation of up to a /21 when justified by a 24-month allocation plan.

Policy Statement:

Replace the current Section 4.2.2 with:

4.2.2. Initial allocation to ISPs

All ISP organizations without direct assignments or allocations from ARIN qualify for an initial allocation of up to a /21, subject to ARIN’s minimum allocation size.

All ISP organizations without direct allocations, direct assignments, re-allocations or reassignments automatically qualify for a /24. These organizations are exempt from requirements of showing the efficient utilization of previously held IPv4 space. These organizations may qualify for a larger than a /24 by documenting how the requested allocation will be utilized within the request size specified in 4.2.4.3

ISPs holding re-allocations and/or reassignments must show the efficient utilization of their resources consistent with the requirements in sections 4.2.3 and 4.2.4

Comments:

The timetable for Implementation: Immediate

Anything Else:

This is an attempt to clarify the changes that came about from 2016-4. It also aligns section 4.2 with current transfer policy. It also re-established the understanding that ISP can renumber and return, but putting the last section 4.2.2.1.4 into the ISP additional requests section. This text is slightly modified to include returns to ARIN in addition to returns to the upstream.