Potential addition the ARIN NRPM:
Once every 24months each holder of IPv4 addresses is required to fully document their IP utilization and demonstrate that the current utilization standard for IPv4 assignments and allocations is being met. This shall include all currently held IPv4 space, regardless of origin or registration status.
A fee shall be assessed for underutilization or insufficient documentation.
- The fee for one 24m period shall be waived if the address holder returns a contiguous block of IPv4 space equal to at least 1/256th of currently held space and no less than one /24 (class C equivalent) to ARINs free pool.
- The fee for one 24m period shall be waived if the address holder signs an ARIN RSA for any uncontested and unregistered IPv4 space, this waiver shall be restricted to one use per member organization.
IP space (v4, v6, vX) is a public resource and as such should be borrowed, used and returned by those with a need for it. Think of IPv4 prefixes like library books (another finite public resource): When you check out a book, you are expected to return it on a certain date. If that date comes and you are still actively using the book, you are allowed to state that and keep the book. Since we are at a point now where IPv4 space is recognizably finite and will start to be replaced by IPv6 space, it makes sense to implement a similar policy at the RIR – that is a time frame. This policy would require that after X amount of time, the LIR/EU would need to return to the RIR with justification if they wish to keep the space. The burden should be on the LIR/EU to prove that they are actively using the space.
1) This policy should be part of a comprehensive plan including:
– A policy to identify abandoned space
– A policy to reclaim abandoned space
– A policy to restrict some (if not all) IPv4 space allocations/assignments to new entrants deploying IPv6
– A continuing increase in utilization requirements
2) I do worry that some (perhaps many) will try to game the system by exaggerating or falsifying ‘proof’ of efficient utilization. At the same time I think that having that caveat will make this much easier for most to swallow and hopefully accept than a similar proposal which assessed the fee to all holders of IPv4 space regardless of utilization. The idea (hope) is that as IPv4 becomes more and more scarce, the community will raise the utilization requirements to include things like NAT and IPv6. This would provide a constant pressure on all community members to become more efficient in their IPv4 use which in turn should help keep some addresses free for new entrants. This is the opposite effect of an unrestricted market based approach which would encourage large holders of addresses to hold more and more IPv4, to store value and bar new competition.
3) I am not sure what the fee should be or if it should be spelled out in policy, this is probably something that ARIN staff should set and be able to change when needed. Perhaps the policy should define simply how the fee is assessed, ie: per IP or per % underutilized, etc. It may also be helpful or necessary to add a statement in the policy requiring any proceeds from these fees to be used for something in particular (legacy outreach, IPv6 promotion, payment/credit to orgs with utilization above the efficiency requirement, etc).
4) I expect that some (possibly many) organizations will find it easier to simply return some space than even trouble themselves with trying to justify their current holdings. This will be especially true of organizations which hold large amounts of space.
5) I am expecting that bringing resources under an ARIN RSA may be easier and less painfull for organizations which already hold other RSA covered space than a full IP audit or returning space. Under this assumption the final sentance has two goals:
A) It is meant to help incent organizations to secure legacy space in any existing or inevitable grey/black market early on (and get it over with). If there are no back-room deals for exchange of legacy space now or in the future, than this is not an issue and can be ignored, this policy will have no affect in this area.
B) To get most (ideally all) IPv4 space under an RSA so that we are all playing on the same field by the same rules. I will note however that legacy holders with no RSA covered space who do not need more ARIN managed resources have no increased incentive to sign an RSA under this proposal then they do today (and no increased risk in not signing one).
6) The time frame may need to be shortened to 12 months considering the rapid approach of IANA free pool exhaustion, 24 months may be far to long of an interval to have a significant impact on IPv4 availability.
Update [28-Oct-08, 14:18]: I posted this to the ARIN PPML yesterday (27 October) for review. So far the majority of feedback has been negative.