ARIN-prop-297: Special Use IPv4 Space Out of Scope for Purposes of Determining Waitlist Eligibility

Date: 16 February 2021

Proposal Originator: Robert Seastrom

Problem Statement:

Eligibility for number resources is based on demonstrated need. In NRPM Section 4, IPv4 demonstrated need is furcated into three categories: ordinary use addresses for ISPs and end users (sections 4.2 and 4.3), special use addresses for critical infrastructure (section 4.4). and special use addresses for facilitation of IPv6 deployment (section 4.10).

Documentation of need for each category of addresses has always been evaluated without respect for address holdings and utilization of other address categories. For instance a TLD operator could get more section 4.4 space for new TLD customers by showing an MOU with ICANN without having to speak to efficient use of its back office section 4.3 space. Likewise, an organization that operated multiple internet exchanges each with a comparatively small number of participants could show efficient use of its section 4.3 back office space and get more under the standard demonstrated need policy despite the fact that its internet exchanges were nowhere near full, thus driving their host density ratio sufficiently low across all their holdings that if they were taken in aggregate they could not possibly meet the requirements to justify more space. Furthermore, an organization that needed address space for IPv6 transition under section 4.10 had those requirements evaluated irrespective of its current holdings and/or efficient utilization.

The current wording of section 4.1.8 (ARIN Waitlist) begins “ARIN will only issue future IPv4 assignments/allocations (excluding 4.4 and 4.10 space) from the ARIN Waitlist.”, a nod to the fact that there is space held in reserve for this type of special use. However a couple of sentences later, “Organizations which hold more than a /20 equivalent of IPv4 space in aggregate are not eligible to apply.” suggests that special use space might count against an organization wishing to apply for waitlist space despite the fact that based on the terms of its issuance 4.4 and 4.10 space is not to be used for general purposes. Either of the types of organizations described above could easily fall into the corner case of having enough special use space to preclude getting ordinary use space via the waitlist.

In the Staff and Legal Assessment (1 May 2019) for ARIN-2019-20, Staff noted:

“… ARIN staff would immediately perform an audit of the current waitlist and remove and inform any organization that holds more than a /20 in IPv4 space excluding 4.4 and 4.10…” indicating a clear intent to treat these blocks specially. Failure to either incorporate this policy nuance into the NRPM or explicitly contradict it has resulted in confusion; a recent Policy Experience Report cited three occurrences in as many weeks.

Policy statement:

Replace the sentence “Organizations which hold more than a /20 equivalent of IPv4 space in aggregate are not eligible to apply.” in section 4.1.8 with “Organizations which hold more than a /20 equivalent of IPv4 space in aggregate (exclusive of special use space received under section 4.4 or 4.10) are not eligible to apply.”

Timetable for implementation: Immediate