ok On Tuesday, December 21, 2021, ARIN <[email protected]> wrote:
> On 16 December 2021, the ARIN Advisory Council (AC) sent the following > Recommended Draft Policy to Last Call: > > > > * ARIN-2021-2: Special Use IPv4 Space Out of Scope for Purposes of > Determining Waitlist Eligibility > > > > Feedback is encouraged during the Last Call period. All comments should be > provided to the Public Policy Mailing List. Last Call will expire on 6 > January 2022, taking into account two US federal holidays. > > > > The Recommended Draft Policy text is below and available at: > > https://www.arin.net/participate/policy/drafts/2021_2/ > > > > The ARIN Policy Development Process is available at: > > https://www.arin.net/participate/policy/pdp/ > > > > Regards, > > > > Sean Hopkins > > Senior Policy Analyst > > American Registry for Internet Numbers (ARIN) > > > > > > > > Recommended Draft Policy ARIN-2021-2: Clarify and Update 4.2.1.2 Annual > Renewal Fee > > > > 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. The intent of the policy is to revise section > 4.1.8 of the NRPM to explicitly exclude space issued under 4.4 and > 4.10frombeing considered when staff are weighing the total holdings of an > org from the v4 wait list. > > > > 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 >
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