If some business running some form of critical non-network infrastructure (like a nuclear power plant) tried to argue it was entitled to a 4.4 allocation because of that, it would be good to have "critical INTERNET infrastructure" explicit in the NRPM.

On 5/23/2024 11:56 AM, Martin Hannigan wrote:

I'm torn.

On one hand, it doesn't matter. The purpose of the NRPM is to regulate *Internet* networks so it's not a hard leap of faith to understand (legally or otherwise) what 4.4 serves especially with the two specific subsections for exchanges and root ops.

On the other hand, some room for staff to maneuver this small piece might be 
wise.

If someone has a use case, all ears. The usual suspects, nuclear power plants, traffic lights, DHS CSI networks, SOSUS, SS7/SS8, etc. don't seem to fly.

+ / - overall.

Thanks,

-M<






On Thu, May 23, 2024 at 10:48 AM A N <[email protected] <mailto:[email protected]>> wrote:

    I also like the suggested change to "Critical Internet Infrastructure".

    (There has been a lot of discussion regarding the FCCs use of the term
    "Critical Infrastructure" being too broad. I think using "critical internet
    infrastructure" is a good way to be specific about what the policy is
    addressing.)

    On Wed, May 22, 2024 at 4:31 PM Chris Woodfield <[email protected]
    <mailto:[email protected]>> wrote:

        In general, I support this proposal.

        Replying to selected points:

         > On May 22, 2024, at 14:22, Tyler O'Meara via ARIN-PPML
        <[email protected] <mailto:[email protected]>> wrote:
         >
         > I support this change, but have a few suggestions:
         >
         > 1) I'd use Critical Internet Infrastructure (CII) as the official
        term for this
         > section; Critical Infrastructure seems a bit too vague.

        I like this change. +1

         > 2) Instead of "ARIN will reserve", should we change it to "ARIN has
        reserved",
         > since the reservation has already occurred and there's no intention
        in the
         > policy to keep the reserved block at a /15 equivalent?

        note that section 4.1.7.1 includes a mechanism by which the reserved
        block will be replenished  (presumably via reclaimed resources), so we
        can’t assume that it will only be a /15 going forward. See
        
https://www.arin.net/participate/policy/nrpm/#4-1-7-2-precedence-for-replenishment 
<https://www.arin.net/participate/policy/nrpm/#4-1-7-2-precedence-for-replenishment>

         > 3) Add the following sentence to the 2nd paragraph: "IP Addresses
        allocated
         > under this section must only be used for the operation of CII".
         >    The current wording permits an operator of CII to use 4.4 space
        for any
         > purpose, which is likely not the intent.

        I’m not going to speak for the authors, but I’d be in support of this
        language change. Usage of CII space outside the operation of CII does
        not likely fit with the communities expectations for this space (The
        community is welcome to disagree with me on this, of course).

         > 4) In "Assigned addresses may be publicly reachable at the operators
        discretion
         > and be used to operate all of the Internet Exchange's infrastructure"
        replace
         > "operators" with "operator's".

        Likely a typo, in support of fixing of course.

        Thanks,

        -Chris


         >
         >
         > On Tue, 2024-05-21 at 12:26 -0400, ARIN wrote:
         >> On 16 May 2024, the ARIN Advisory Council (AC) accepted 
“ARIN-prop-333:
         >> Rewrite of NRPM Section 4.4 Micro-Allocation” as a Draft Policy.
         >>
         >> Draft Policy ARIN-2024-5 is below and can be found at:
         >>
         >> https://www.arin.net/participate/policy/drafts/2024_5
        <https://www.arin.net/participate/policy/drafts/2024_5>
         >>
         >> You are encouraged to discuss all Draft Policies on PPML. The AC
        will evaluate
         >> the discussion to assess the conformance of this draft policy with
        ARIN's
         >> Principles of Internet number resource policy as stated in the 
Policy
         >> Development Process (PDP). Specifically, these principles are:
         >>
         >> * Enabling Fair and Impartial Number Resource Administration
         >> * Technically Sound
         >> * Supported by the Community
         >>
         >> The PDP can be found at:
         >>
         >> https://www.arin.net/participate/policy/pdp/
        <https://www.arin.net/participate/policy/pdp/>
         >>
         >> Draft Policies and Proposals under discussion can be found at:
         >> https://www.arin.net/participate/policy/drafts/
        <https://www.arin.net/participate/policy/drafts/>
         >>
         >> Regards,
         >>
         >> Eddie Diego
         >> Policy Analyst
         >> American Registry for Internet Numbers (ARIN)
         >>
         >>
         >> Draft Policy ARIN-2024-5: Rewrite of NRPM Section 4.4 
Micro-Allocation
         >>
         >> Problem Statement:
         >>
         >> The current NRPM Section 4.4 language hasn’t aged well. As the ARIN
        53 policy
         >> experience report demonstrated, 4.4 has also become difficult to
        implement by
         >> ARIN staff. Growth and use of Internet Exchanges has also changed. 
The
         >> overhaul seeks to improve technical soundness, respect the privilege
        of a
         >> dedicated pool and to more closely observe conservation principles 
using
         >> clear, minimum and enforceable requirements and underscoring the
        value of
         >> routability of assigned prefixes as required.
         >>
         >> ARIN 4.4 CI Assignments
         >>
         >> The intent of this policy is not to unreasonably preclude the use 
of an
         >> allocated or assigned prefix in servicing the needs of critical
        infrastructure
         >> of the Internet.
         >>
         >> ARIN will reserve a /15 equivalent of IPv4 address space for 
Critical
         >> Infrastructure (CI) of the Internet within the ARIN RIR service 
area.
         >> Assignments from this pool will be no smaller than a /24. Sparse
        allocation
         >> will be used whenever practical. CI includes Internet Exchanges, 
IANA
         >> authorized root servers, ccTLD operators, ARIN, and IANA. Addresses
        assigned
         >> from this pool may be revoked if no longer in use or not used for
        approved
         >> purposes. Only Section 8.2 transfers are allowed. Use of this policy
        for CI is
         >> voluntary. ARIN will publish all 4.4 allocated addresses for 
research
         >> purposes.
         >>
         >> 4.4.1 Internet Exchange Assignments
         >>
         >> • Internet Exchange operators must justify their need by providing 
the
         >> following:
         >>
         >> • A minimum of three initial participants connected to a physically
        present
         >> ethernet switch fabric to be used for the purpose of Internet 
Exchange
         >> facilitated peering
         >>
         >> • Justification must include:
         >>      - Three unique participant names and ASNs not under common 
control
         >>      - Direct contact information for each participant
         >>
         >> • Staff can reasonably validate hardware existence and participants
        intent
         >>
         >> • Applicant Internet Exchange affiliated ASNs are not eligible to be
        included
         >> in meeting the participant requirement
         >>
         >> • Assigned addresses may be publicly reachable at the operators
        discretion and
         >> be used to operate all of the Internet Exchange's infrastructure
         >>
         >> 4.4.2 Root and ccTLD Assignments
         >>
         >> Root and ccTLD operators will provide justification of their need 
and
         >> certification of their status as currently active zone operators.
         >>
         >>
         >>
         >> _______________________________________________
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         >> You are receiving this message because you are subscribed to
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         >> Unsubscribe or manage your mailing list subscription at:
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        <https://lists.arin.net/mailman/listinfo/arin-ppml>
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        experience any issues.
         >
         > _______________________________________________
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