2012-6 Staff Assessment

View the current policy proposal text.

ARIN STAFF ASSESSMENT for Draft Policy 2012-6
Draft policy 2012-6Revising Section 4.4 C/I Reserved Pool Size”
Date of Assessment:  10 Dec 2012 (due to AC 12 Dec 2012)
1.   Summary (Staff Understanding)
This draft policy would revise the definition of “critical infrastructure providers of the Internet, with the revised definition being: 1) Public exchange points, 2) Core DNS operators of ccTLD operators and the DNS root, and 3) the RIRs/IANA.  Under the revised definition, gTLD operators would be ineligible to receive assignments from the critical infrastructure reserved space but would be eligible to receive micro-allocations from space outside the reservation, with a maximum allocation size of a /23 per each gTLD.  Micro-allocations made prior to this policy's implementation are grandfathered; this policy will not apply to gTLD allocations made previously.
A.   ARIN Staff Comments

•      At present, there is no maximum assignment size for any micro-allocation.  The /23 limit would apply on a per-gTLD basis, meaning an organization providing core DNS for multiple gTLDs would be eligible to receive more than a /23 in total so long as no individual gTLD receives more than a /23.

•      The micro-allocation policy was originally a means to issue single /24s, with larger blocks occasionally issued where justified.  As a point of information, staff has received and approved blocks larger than a /23 for a single gTLD on previous occasions.  It may be worth considering mentioning specifically permitting larger assignments via 8.3 transfers (with appropriately documented need.)

•      This proposal refers to a policy term and says specifically “If at the end of the policy term there is unused address space remaining in this pool, ARIN staff is authorized to utilize this space”, however, there is no actual policy term set within the policy text.  Staff suggests adding the following for clarity and completeness:

“If at the end of the 3 year policy term there is unused address space remaining in this pool, ARIN staff is authorized to reutilize this space in a manner consistent with community expectations.” 


B.  ARIN General Counsel - Legal Assessment
“The draft policy being considered by the community would  treat critical infrastructure such as exchange points differently than the infrastructure associated with the new gTLD’s program. As a result, one category of entities are favored for scarce resources. As the ARIN community makes such scarcity decisions they must be rationally related to appropriate principles of stewardship, conservation etc. The description of this reasoning should be crisply described in writing so that ARIN members and outside entities, such as the companies seeking new gTLD resources can understand the reasoning , the process  and fully provide their input.  “

3. Resource Impact
This policy would have minimal resource impact from an implementation aspect.  It is estimated that implementation would occur within 3 months after ratification by the ARIN Board of Trustees. The following work would be needed in order to implement:
·      Updated guidelines
·      Staff training
 4. Proposal Text

Replace NRPM section 4.4 with the following:


4.4. Micro-allocation
ARIN will make IPv4 micro-allocations to critical infrastructure providers of the Internet, including public exchange points, core DNS service providers (e.g. ICANN-sanctioned root and ccTLD operators) as well as the RIRs and IANA. These allocations will be no smaller than a /24. Multiple allocations may be granted in certain situations.

Exchange point allocations MUST be allocated from specific blocks reserved only for this purpose. All other micro-allocations WILL be allocated out of other blocks reserved for micro-allocation purposes.
ARIN will make a list of these blocks publicly available.

Exchange point operators must provide justification for the allocation,
including: connection policy, location, other participants (minimum of two total), ASN, and contact information. ISPs and other organizations receiving these micro-allocations will be charged under the ISP fee schedule, while end-users will be charged under the fee schedule for end-users. This policy does not preclude exchange point operators from requesting address space under other policies.

ARIN will place an equivalent of a /16 of IPv4 address space in a reserve for Critical Infrastructure, as defined in section 4.4. If at the end of the policy term there is unused address space remaining in this pool, ARIN staff is authorized to utilize this space in a manner consistent with community expectations.

ICANN-sanctioned gTLD operators may justify up to the equivalent of an IPv4 /23 block for each authorized new gTLD, allocated from the free pool or received via transfer, but not from the above reservation. This limit of a /23 equivalent per gTLD does not apply to gTLD allocations made under previous policy.



Additional ICANN-sanctioned DNS infrastructure is being added to the Internet and in quantities greater than anticipated when the micro allocation proposal was written and adopted.

The original CI pool was created to serve new IXP and new CI requirements. The pending need is estimated to be over 1000 new gTLD range, which may exhaust the current /16 reservation before the ARIN free pool is exhausted. Once the current /16 reservation is exhausted, CI providers would no longer be eligible to receive address space, either via the general free pool or via transfer.

The original proposal dealt with this by expanding the reservation to a
/15 and allowing CI to draw from the free pool instead of the reservation until it gets down to a /8.  The consensus coming out of the Dallas meeting seems to be that this is an inadequate solution. As the new expanded gTLD demand will obliterate any reasonable reservation, leaving no resources for the other IXP and CI demands that the original reservation was intended to serve. It is therefore, not possible to services them both out of a common reservation.

In order to ensure continued access to IPv4 number resources by new IXP and DNS operators alike, the AC is modifying the proposal going into last call to allow gTLD operators to continue to qualify for micro allocations from the general free pool or via transfer only, and leaving one /16 reserved for IXP, root, and ccTLD DNS operators.

As a result of the close examination of the CI policy brought about by this proposal, the AC has identified a number of issues in the original policy text that should be addressed. However, the AC is intentionally minimizing the overall changes to this proposal as much as possible for last call in keeping with the spirit of the PDP. The AC intends to make future proposals to deal with these other concerns. The current proposal addresses issues of some urgency and we did not want to delay it to another policy cycle as a result.