I support the spirit of the draft policy, but I’d like to see a change that I 
don’t think will be controversial…

1. ARIN should not be specifying network technologies. “A physically present 
ethernet switch” is way too specific for NRPM IMHO. I would propose, instead, 
that we specify “connected to a shared peering fabric via physical 
infrastructure (e.g. a shared ethernet switch).”

In the past, we have had internet exchanges that were (e.g.) ATM based and had 
multiple physical switches spread over a variety of locations. I don’t know 
that there are currently any non-ethernet based exchanges still in operation, 
but I also don’t know what kind of networking technology might occur next week. 
For example, I think it would be perfectly valid to set up an infiniband 
exchange if there were enough interested participants, but under this proposed 
policy, that would not be allowed.

Owen


> On May 21, 2024, at 09:26, ARIN <i...@arin.net> 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
> 
> 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. 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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