Draft Policy ARIN-2019-9

Clarify Interactions Between NRPM 4.10 IPv6 Transition Space Requests and NRPM 4.1.8.2 Unmet Needs Requests

Status: Abandoned 24 September

Staff and Legal Review: 22 July 2019

Advisory Council Shepherds: Kat Hunter, Andrew Dul

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History:

Revisions:

ARIN Advisory Council Meetings:

Latest Version: 30 July 2019

Problem Statement:

It has been observed that an organization requesting IPv4 resources under NRPM Section 4.10, Dedicated IPv4 Block To Facilitate IPv6 Deployment, can also request similar or the same resources under Section 4.2.1.8, Unmet Needs. This proposal aims to remove this potential for duplicate requests under these sections.

Policy Statement:

Section 4.1.8.2, Unmet Needs:

Current language:

Any requests met through a transfer will be considered fulfilled and removed from the waiting list.

Proposed language:

Any requests met through a transfer or an allocation request fulfilled under Section 4.10 will be considered fulfilled and removed from the waiting list.

Timetable for Implementation: Immediate

Anything Else:

Currently, organizations can receive no more than a /24 at a time under Section 4.10. However, Proposal ARIN-PROP-269, submitted by Chris Tacit and myself, could potentially allow an org to receive up to a /21 under that section, widening the potential for abuse by “double-dipping” waiting list and transition space requests. As such, this proposal should be considered in that context.

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ARIN STAFF & LEGAL ASSESSMENT

Summary (Staff Understanding)

Staff’s understanding is that Draft Policy ARIN-2019-9: Clarify Interactions Between NRPM 4.10 IPv6 Transition Space Requests and NRPM 4.1.8.2 Unmet Needs Request clearly states that any organization on the Waiting List who receives IPv4 addresses either via a transfer or allocation under Section 4.10 Dedicated IPv4 Block to Facilitate IPv6 Deployment will be removed from the Waiting List.


Comments

ARIN Staff Comments

This policy could be implemented as written. Current policy is that any organization on the waiting list that receives IPv4 addresses through a transfer are removed from the waiting list, but those receiving an NRPM 4.10 (Dedicated IPv4 Block to Facilitate IPv6 Deployment) assignment are not removed from the waiting list. The proposed change would result those organizations receiving an NRPM 4.10 assignment also being removed from the waiting list.

Staff notes that adding the “…or an allocation request fulfilled under Section 4.10…” may be detrimental to some organizations, as address space received per NRPM 4.10 must be used in a manner consistent with IPv6 translation services and cannot be used for other purposes such as customer assignments, shared hosting services, etc.

Organizations need IPv4 address space to assign to their customers, and many organizations will request a block from the Waiting List to be used for their customer assignments but still need some IPv4 space for deployment of IPv6 translation services as outlined in section NRPM 4.10. Removing organizations from the Waiting List when they receive a NRPM 4.10 assignment would hinder the existing IPv4 operations & growth of organizations, and may provide a disincentive to IPv6 deployment.

ARIN General Counsel – Legal Assessment

The policy does not create material legal risk


Resource Impact

Implementation of this policy would have minimum 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:

  • Staff training
  • Updated guidelines and internal procedures
  • Updated documentation on website ___

Proposal/Draft Policy Text Assessed

Latest Version: 23 May 2019

Problem Statement:

It has been observed that an organization requesting IPv4 resources under NRPM Section 4.10, Dedicated IPv4 Block To Facilitate IPv6 Deployment, can also request similar or the same resources under Section 4.2.1.8, Unmet Needs. This proposal aims to remove this potential for duplicate requests under these sections.

Policy Statement:

Section 4.1.8.2, Unmet Needs:

Current language: Any requests met through a transfer will be considered fulfilled and removed from the waiting list.

Proposed language:

Any requests met through a transfer or an allocation request fulfilled under Section 4.10 will be considered fulfilled and removed from the waiting list.

Timetable for Implementation: Immediate

Anything Else:

Currently, organizations can receive no more than a /24 at a time under Section 4.10. However, Proposal ARIN-PROP-266, submitted by Chris Tacit and myself, could potentially allow an org to receive up to a /21 under that section, widening the potential for abuse by “double-dipping” waiting list and transition space requests. As such, this proposal should be considered in that context.

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Earlier Version

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Version Date: 23 May 2019

Problem Statement:

It has been observed that an organization requesting IPv4 resources under NRPM Section 4.10, Dedicated IPv4 Block To Facilitate IPv6 Deployment, can also request similar or the same resources under Section 4.2.1.8, Unmet Needs. This proposal aims to remove this potential for duplicate requests under these sections.

Policy Statement:

Section 4.1.8.2, Unmet Needs:

Current language: Any requests met through a transfer will be considered fulfilled and removed from the waiting list.

Proposed language:

Any requests met through a transfer or an allocation request fulfilled under Section 4.10 will be considered fulfilled and removed from the waiting list.

Timetable for Implementation: Immediate

Anything Else:

Currently, organizations can receive no more than a /24 at a time under Section 4.10. However, Proposal ARIN-PROP-266, submitted by Chris Tacit and myself, could potentially allow an org to receive up to a /21 under that section, widening the potential for abuse by “double-dipping” waiting list and transition space requests. As such, this proposal should be considered in that context.

##########

Earlier Version

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Version Date: 21 May 2019

Problem Statement:

It has been observed that an organization requesting IPv4 resources under NRPM Section 4.10, Dedicated IPv4 Block To Facilitate IPv6 Deployment, can also request similar or the same resources under Section 4.2.1.8, Unmet Needs. This proposal aims to remove this potential for duplicate requests under these sections.

Policy Statement:

Section 4.1.8.2, Unmet Needs:

Current language: Any requests met through a transfer will be considered fulfilled and removed from the waiting list.

Proposed language (New text in italics):

Any requests met through a transfer or an allocation request fulfilled under Section 4.10 will be considered fulfilled and removed from the waiting list.

Comments:

Timetable for implementation: Immediate

Anything Else

Currently, organizations can receive no more than a /24 at a time under Section 4.10. However, Proposal ARIN-PROP-266, submitted by Chris Tacit and myself, could potentially allow an org to receive up to a /21 under that section, widening the potential for abuse by “double-dipping” waiting list and transition space requests. As such, this proposal should be considered in that context.