A couple of nits…

1. I think since this would be effectively a new replacement 4.4, we should 
make it clear that ARIN is not reserving a new /15, but rather continuing with 
what is left of the existing reservation.

2. I think that we should retire the renumber and return portion of 4.4.3 as 
the board suspended it a long time ago and that emergency policy decision was 
subsequently ratified by the membership.

Owen


> On Sep 23, 2025, at 09:31, ARIN <[email protected]> wrote:
> 
> On 18 September 2025, the ARIN Advisory Council (AC) advanced the following 
> Draft Policy to Recommended Draft Policy status: 
> 
> * ARIN-2024-5: Rewrite of NRPM Section 4.4 Micro-Allocation
> 
> The text of the Recommended Draft Policy is below, and may also be found at: 
> 
> https://www.arin.net/participate/policy/drafts/2024_5/
> 
> You are encouraged to discuss all Recommended Draft Policies on PPML prior to 
> their presentation at the next ARIN Public Policy Consultation (PPC). PPML 
> and PPC discussions are invaluable to the AC when determining community 
> consensus. 
> 
> 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)
> 
> 
> Recommended Draft Policy ARIN-2024-5: Rewrite of NRPM Section 4.4 
> Micro-Allocation
> 
> AC Assessment of Conformance with the Principles of Internet Number Resource 
> Policy:
> 
> "Following a review of community feedback, staff and legal recommendations, 
> and AC discussions, Draft Policy  ARIN-2024-5: Rewrite of NRPM Section 4.4 
> Micro-Allocation, was found to conform to the principles of the ARIN Policy 
> Development Process. Based on being fair, impartial, and technically sound, 
> this Draft Policy was moved to Recommended Draft state by the Advisory 
> Council. If adopted by the ARIN Board Of Trustees, it would update the NRPM’s 
> terminology from “Micro-Allocation” to “Critical Internet Infrastructure” in 
> order to better describe the usage for the resources described in Section 
> 4.4, as well as clarify qualification and usage requirements for resources 
> allocated under the section."
> 
> 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 exchange points (IXPs), core DNS 
> service providers (e.g. ICANN-sanctioned root and ccTLD operators) ARIN, and 
> IANA.
> 
> ICANN-sanctioned gTLD operators may justify up to the equivalent of an IPv4 
> /23 block for each authorized gTLD, allocated from the free pool or received 
> via transfer, but not from the above reservation. This limit of a /23 
> equivalent per gTLD does not apply to gTLD allocations made under previous 
> policy.
> 
> Previous allocations under this policy must continue to meet the 
> justification requirements of this policy.
> 
> Use of this policy for CII is voluntary; address holders that qualify for CII 
> allocations may use allocations obtained via other means for CII resources. 
> ARIN will publish a record of all addresses allocated under this section 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 directly related to the operation of 
> 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.
> 
> In cases where fulfilling the request by expanding the existing allocation is 
> not possible, a single prefix sized to accommodate both the prior and 
> additional requested allocation will be issued to facilitate renumbering. The 
> original allocation must be returned to ARIN within 12 months of the new 
> allocation.
> 
> Timetable for Implementation: Immediate.
> 
> 
> 
> 
> 
> _______________________________________________
> ARIN-PPML
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