Good observations Dave, thank you for the feedback.

_
Brian Jones
ARIN Advisory Council





On Jan 31, 2025, at 18:05, David Farmer <[email protected]> wrote:

The current 4.10 envisions directly allocating a whole /24 to an end user and 
having them operate their own NAT64 IPv6 transition service; in some cases, 
this isn't very efficient. Some smaller end users may not need a full 24 for 
their NAT64 needs.

I interpret the proposal as allowing for NAT64-as-a-Service where the customer 
is IPv6-only, and a service provider provides the NAT64, dedicating a small 
IPv4 pool, less than /24 per customer for each customer's NAT64 needs. This 
would allow for more efficient use of the 4.10 pool, and such a use case would 
be consistent with 4.10 rules if the NAT64-as-a-Service provided reassignments 
of smaller blocks to its customers.

Thanks.

On Fri, Jan 31, 2025 at 1:46 PM Jones, Brian 
<[email protected]<mailto:[email protected]>> wrote:

As shepherds of Draft Policy ARIN-2024-11 Kaitlyn and I would very much like to 
refocus the discussion surrounding it. When this was circulated to the PPML 
last October there was some discussion, but much of it was not directed at the 
root issues associated with these proposed changes.

My very unofficial hallway discussions indicate the space that gets allocated 
from section 4.10 of the Number Resource Policy Manual is a large target for 
those wishing to do other things with that space than convert their 
organization to IPv6.

This section was never intended to allocate resources that would then be 
reallocated to another entity or used for any other purpose than to allow for 
the conversion of the applicant to IPv6.

The policy experience report given by John Sweeting at ARIN 54 indicated that 
at the current rate of allocations from section 4.10 of the NRPM there should 
be enough to last through the year 2050 or approximately 25 years. Keep in mind 
that the 4.10 dedicated pool has a mandate to be replenished when it gets down 
below a 3 year supply. This would mean any ARIN recovered IPv4 address space 
would come back into this pool for replenishment instead of the waitlist once 
this threshold is reached.

So with these things in mind my question to the community is do we really need 
to allow reallocations from applicants of this dedicated space as this policy 
is suggesting or should each entity that needs IPv4 space to facilitate their 
transition to IPv6 continue to apply for their own /24 as the policy is 
currently written?

Thank you in advance for your input and feedback.



-------------------------------------------------------------------------------------------------------------



On 25 October 2024, the ARIN Advisory Council (AC) accepted “ARIN-prop-338: 
IPv4 Transition Efficiency Reallocation Policy (ITERP)” as a Draft Policy.

*Draft Policy ARIN-2024-11 is below and can be found at:

https://www.arin.net/participate/policy/drafts/2024_11

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/

Draft Policies and Proposals under discussion can be found at:

https://www.arin.net/participate/policy/drafts/


Draft Policy ARIN-2024-11: IPv4 Transition Efficiency Reallocation Policy 
(ITERP)

Problem Statement:

As the exhaustion of IPv4 addresses continues, ISPs and end-users face 
increasing challenges in managing their transition to IPv6. Many end-users 
require small amounts of IPv4 space to implement technologies like 
Carrier-Grade NAT (CG-NAT) or dual-stack environments, which are critical for 
their own IPv6 deployment efforts. Under the current NRPM 4.10 policy, ISPs are 
prohibited from reallocating portions of their IPv4 blocks to end-users, 
forcing these organizations to request larger, inefficiently used blocks (e.g., 
/24s) from ARIN.

This practice contributes to the unnecessary consumption of scarce IPv4 
resources, as many end-users only need small blocks (e.g., /29s or /28s) for 
their CG-NAT and IPv6 transition processes. The inability to reallocate these 
smaller blocks results in wasteful allocations and hampers the overall 
efficiency of IPv4 address management.

Without a mechanism to allow ISPs to reallocate small portions of their NRPM 
4.10 space to qualified end-users, the current policy inadvertently encourages 
inefficient IPv4 address utilization, which conflicts with ARIN’s goal of 
maximizing the use of remaining IPv4 resources while facilitating the 
widespread adoption of IPv6.

The problem is twofold:

1. End-users are forced to request larger, underutilized IPv4 blocks for their 
IPv6 transition needs.

2. ISPs are unable to efficiently manage and reallocate their IPv4 resources 
under NRPM 4.10 to meet end-user demands for small-scale CG-NAT and IPv6 
transition deployments.

Policy Statement:

Add these bullets to section 4.10 of the NRPM to facilitate ARIN approved 
reallocation of 4.10 resources.

* ISPs may reassign a /29 or /28 for their direct downstream customers for IPv6 
transition only. ARIN reserves the right to validate any downstream allocations 
from ISPs to direct customers.

* Anyone wishing to perform a reassignment of a 4.10 allocation must be 
approved through ARIN and meet all the justification requirements of this 
policy.

Comments:

IPv4 Transition Efficiency Reallocation Policy (ITERP) and Its Impact on 
CG-NAT, IPv6, and Efficient Resource Use

Utilization of Reallocated IP Space by End-Users and Small ISPs for CG-NAT

Under the IPv4 Transition Efficiency Reallocation Policy (ITERP), end-users and 
even small ISPs can efficiently use reallocated IPv4 space for CG-NAT 
(Carrier-Grade NAT) while leveraging their IPv6 deployments. Many smaller ISPs, 
particularly those that only have NRPM 4.10 space and limited IPv4 allocations, 
could benefit from this policy by reallocating IPv4 subnets (e.g., /29 or /28) 
to their customers or other ISPs who require minimal IPv4 addresses for CG-NAT 
in dual-stack environments.

Through the use of BGP for IPv6, along with alternative IPv4 multi-homing 
technologies like source and policy based routing combined with CG-NAT, 
end-users or small ISPs could even connect to multiple providers utilizing IPv6 
natively while performing CG-NAT towards multiple providers over IPv4. This 
approach helps balance traffic, increase redundancy, and achieve better 
failover capabilities. By employing IPv6 for outward-facing traffic and CG-NAT 
for IPv4 communication, smaller networks can provide their customers a seamless 
experience without consuming large amounts of IPv4 space.

Eligibility and Address Space Efficiency

This policy amendment is strictly intended for organizations that would 
otherwise be eligible for a /24 under NRPM 4.10. Instead of receiving an entire 
/24 (256 addresses) that may go largely underutilized, these end-users could 
now request smaller blocks (e.g., /29s or /28s) from multiple providers that 
only hold NRPM 4.10 space. This allows for much more efficient use of IPv4 
resources, as the smaller allocations can directly serve CG-NAT needs without 
wasting a significant portion of the address space.

Such end-users are typically transitioning to IPv6 and need small amounts of 
IPv4 space only for backward compatibility and legacy systems. This policy 
ensures that they don’t have to unnecessarily consume large blocks of IPv4 
addresses that are rapidly depleting, especially since most of their traffic 
will run over IPv6.

Incentivizing IPv6 Deployment by ISPs

This policy can also incentivize ISPs to evangelize IPv6 deployment to their 
customers. As the ISPs are held accountable for monitoring and reporting the 
usage of reallocated space, they are motivated to actively assist their 
customers in migrating to IPv6 to ensure compliance with ARIN’s policies. By 
reallocating IPv4 space under the NRPM 4.10 policy, ISPs will naturally push 
for greater IPv6 adoption and encourage their end-users to take advantage of 
the superior capabilities and scalability of IPv6.

In many cases, ISPs can act as trusted technology advocates, guiding their 
customers through the transition process, offering resources, and providing 
technical support for deploying dual-stack environments. This not only supports 
IPv6 growth but also fosters stronger partnerships between ISPs and their 
customers as they collectively work toward the next generation of networking 
technologies.

Supporting ISPs with Only NRPM 4.10 Space and IPv6

Many ISPs, particularly newer or smaller ones, may only have access to NRPM 
4.10 IPv4 space and IPv6 allocations. These ISPs often lack sufficient 
general-purpose IPv4 space but are fully invested in deploying IPv6 to their 
customers. The IPv4 Transition Efficiency Reallocation Policy provides an 
efficient and pragmatic way for these ISPs to serve end-users with small-scale 
CG-NAT needs, helping them facilitate IPv6 adoption without having to apply for 
entire /24s of IPv4 space that they don’t require.

By allowing the reallocation of small IPv4 blocks to end-users for CG-NAT and 
IPv6 dual-stack environments, IPv4 exhaustion can be minimized, and numbering 
resources can be more efficiently utilized. These ISPs can push their customers 
toward IPv6 while offering minimal IPv4 resources needed for NAT and legacy 
services. This policy, therefore, promotes responsible IPv4 stewardship and 
accelerates the migration to IPv6.

Conclusion: Efficient Use of Resources and Push for IPv6 Adoption

The IPv4 Transition Efficiency Reallocation Policy (ITERP) ensures that IPv4 
address space is used efficiently by allowing small allocations to end-users 
for specific transitional technologies like CG-NAT. By utilizing BGP for IPv6 
and multi-homing technologies, end-users can effectively route traffic while 
minimizing their reliance on IPv4. This policy enables ISPs, particularly those 
that only have NRPM 4.10 space, to act as leaders in the push for IPv6, 
ensuring that numbering resources are preserved while advancing the deployment 
of the next generation of Internet technology.

Other technologies are also available, such as routing IPv4 space over IPv6, 
which is supported in many modern routing systems, meaning a /32 of IPv4 space 
could be routed to an end-user over a native IPv6 network with no other space 
involved. This policy would encourage ISPs to evangelize and accelerate the 
deployment of an IPv6 Internet by making deploying IPv6 even more beneficial to 
end users, while also preserving the precious remaining IPv4 address space.

By embracing this approach, ARIN can foster greater IPv6 adoption, prevent IPv4 
depletion, and empower ISPs and end-users alike to move forward with 
innovative, future-proof network architectures.

This policy provides a more efficient and responsible approach to achieving the 
goals initially intended by ARIN-2008-5, which aimed to allow the use of longer 
prefixes than /24s without causing the complications associated with ARIN 
allocating such longer prefixes directly.

When ARIN-2008-5 was introduced, the idea was to allow networks to receive 
smaller allocations than /24, recognizing that many organizations, particularly 
those transitioning to IPv6, do not require a full /24 for their IPv4 needs. 
However, allocating smaller prefixes directly from ARIN would have created 
routing and administrative challenges, including concerns about route 
fragmentation and maintaining the integrity of the global routing table.

The IPv4 Transition Efficiency Reallocation Policy (ITERP) resolves these 
issues by enabling ISPs to handle the reallocation of small IPv4 blocks (such 
as /29 or /28) from their NRPM 4.10 space, instead of ARIN directly assigning 
longer prefixes. This allows for more granular and flexible use of address 
space without fragmenting ARIN’s allocations, ensuring that the allocations 
remain efficient and manageable.

Furthermore, by placing responsibility on the ISPs to ensure proper 
utilization, ITERP:

• Minimizes the risk of route table bloat, as ISPs manage these smaller blocks 
within their own infrastructure.
• Ensures IPv4 allocations are tied to specific, justified use cases (such as 
CG-NAT and IPv6 transition), aligning with the original intent of ARIN-2008-5 
to avoid wasteful consumption of IPv4 addresses.

In doing so, this policy not only promotes efficient use of IPv4 space but also 
strengthens the transition to IPv6 by encouraging ISPs to work closely with 
their customers on deploying dual-stack environments, thus driving greater IPv6 
adoption. This policy balances the need for flexibility in smaller allocations 
while preventing the complications that could arise from direct ARIN 
allocations of smaller prefixes.

Timetable for implementation: Immediate

-------------------------------------------------------------------------------------------------------------

_
Brian Jones
ARIN Advisory Council





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