I got a mysterious bounce. I don't know if my comment went to the list or not, so I'm sending it again. Sorry if it's a duplicate.


-------- Forwarded Message --------
Subject: Re: [arin-ppml] Revised - Draft Policy ARIN-2024-5: Rewrite of NRPM Section 4.4 Micro-Allocation
Date: Tue, 18 Mar 2025 15:58:48 -0400
From: John Santos <[email protected]>
Reply-To: [email protected]
Organization: Evans Griffiths & Hart, Inc.
To: [email protected]

Maybe I'm just being persnickety, but is "Use of this policy for CII is voluntary." unambiguous? To me, it means a user can implement CII using any addresses that are allocated to them, i.e. they are not required to apply for and use 4.4 space for CII, *BUT* might someone argue that this clause means that if they have 4.4 space, or acquire it somehow, then using it for CII is voluntary and they can use it for anything they want? Should we add an explicit provision that 4.4 space may *ONLY* be used for CII?

Also, does section 4.4.2 create a chicken and egg problem: A TLD operator must be "a currently active zone operator" to apply for 4.4 space, but they can't become an active zone operator until they have acquired the IP addresses to do so? It would complicate the situation if we added "or plans to become one within <reasonable time period>", and another sentence that the allocation would be subject to revocation if they did not do so.

Or is this just too pedantic to worry about?


On 3/18/2025 2:44 PM, ARIN wrote:
The following Draft Policy has been revised:
*ARIN-2024-5: Rewrite of NRPM Section 4.4 Micro-Allocation Revised text is below and can be found at: 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/ Draft Policies and Proposals under discussion can be found at: 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. The growth and use of Internet Exchanges have 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 allocated prefixes as required.

Policy Statement:

4.4 Critical Internet Infrastructure (CII) Allocations

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. Sparse allocation will be used whenever 
practical. CII includes Internet Exchanges, IANA-authorized root servers, TLD 
operators that offer domain-level DNS services to outside parties, ARIN, and 
IANA.

Previous allocations under this policy must continue to meet the justification 
requirements of this policy. Use of this policy for CII is voluntary. ARIN will 
publish all 4.4 allocated addresses for research purposes.

4.4.1 Internet Exchange Allocations

Internet Exchange operators must justify their need by providing a minimum of 
three initial participants not under common control connected to a shared, 
physical switching fabric to be used for the purpose of the exchange of data 
destined for and between the respective networks. This justification must 
include participant names, ASNs and contact information for each named 
participant. The applicant’s Internet Exchange affiliated ASNs are not eligible 
to be included in meeting the participant requirement.

Allocated addresses may be publicly reachable at the operator’s discretion, but 
must be assigned only to resources required to operate the IXP.

4.4.2 TLD Allocations

TLD operators will provide justification of their need and certification of 
their status as currently active zone operators.

4.4.3 Additional Requests

A recipient may request up to a 24-month supply of IPv4 resources under this 
section. Requests for additional resources under this section will be evaluated 
using Section 4.2.4.1’s usage requirements.

Timetable for Implementation: Immediate




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--
John Santos
Evans Griffiths & Hart, Inc.
781-861-0670 ext 539

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