As AC shepherds for the critical infrastructure draft (2024-5) we'd like to get
input on the draft policy text and collect some feedback on open issues that
the shepherds have received from multiple sources. This will help us edit the
draft for presentation at ARIN 55 and, if there is consensus, advancement to
the NRPM.
The current draft text can be found on ARIN’s policy page here:
https://www.arin.net/participate/policy/drafts/2024_5/
Below are the points in the current proposed policy text that we’d like to get
community feedback on.
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Under 4.4, Critical Internet Infrastructure (CII) Allocations:
“The intent of this policy is not to unreasonably preclude the use of an
allocated prefix in servicing the needs of Critical Internet Infrastructure.”
- We’ve received feedback that text declaring the intent of a policy is
superfluous, and could lead to ambiguous guidance to ARIN staff when evaluating
specific address requests under this section. Should this statement be removed?
Also under 4.4:
“Only Section 8.2 transfers are allowed.”
- Current policy prohibits 4.4 resources, along with 4.10 resources, from being
transferred under sections 8.3 and 8.4, making this statement redundant under
current text, as that leaves 8.2 as the only qualified type of transfer. Should
this be deleted, or might it make sense to keep it in to disallow any
additional transfer types that may be added to Section 8 in the future?
Under 4.4:
“ARIN will reserve a /15 equivalent of IPv4 address space for Critical Internet
Infrastructure (CII) within the ARIN RIR service area. Allocations from this
pool will be no smaller than a /24.”
and later under 4.4.2:, Root and ccTLD Allocations:
“Root and ccTLD operators will provide justification of their need and
certification of their status as currently active zone operators.”
- The proposal text (and, to be fair, the text it aims to replace) is silent on
justification criteria for IX allocations larger than a /24. Our understanding
is that absent explicit guidance, ARIN staff has used the justification
language in Section 4.2.2 or 4.2.4 to evaluate these depending on the request
type. Should the qualification criteria be made explicit in the proposed policy
text? Should an alternate justification criteria be proposed for larger IX
allocations under this section?
“[Critical Internet Infrastructure] includes Internet Exchanges,
IANA-authorized root servers, ccTLD operators, ARIN and IANA”
- The current text references “core DNS service providers”, while the proposal
text is more restrictive, only specifying ccTLD operators as eligible to apply
for CII resources. Should this be expanded to encompass other types of TLD
operators, such as gTLD, sponsored TLD, and/or possibly others? Or simply
revert to the more expansive language in existing text?
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Thank you and we look forward to your feedback.
Regards,
Chris Woodfield and Bill Herrin
ARIN Advisory Council
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