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[ppml] Policy Proposal 2007-21 - Staff Assessment

Policy Proposal 2007-21
PIv6 for legacy holders with RSA and efficient use

ARIN Staff Assessment

The assessment of this proposal includes comments from ARIN staff and
the ARIN General Counsel. It contains analysis of procedural, legal, and
resource concerns regarding the implementation of this policy proposal
as it is currently stated. Any changes to the language of the proposal
may necessitate further analysis by staff and Counsel.

I. Proposal

Policy Proposal is available as Annex A below and at:
http://www.arin.net/policy/proposals/2007_21.html

II. Understanding of the proposal

ARIN staff understands that this proposal would make direct assignments
of IPv6 space available to any organization with an efficiently utilized
v4 assignment or allocation covered under an RSA.

III. Comments

   A. ARIN Staff

The title uses the words “legacy holder” which is never mentioned within
the policy text.

   B. ARIN General Counsel
This policy does not create any legal concerns.

Resource Impact – Minimal

The resource impact of implementing this policy is viewed as minimum.
Barring any unforeseen resource requirements, this policy could be
implemented within 30 – 90 days from the date of the ratification of the
policy by the ARIN Board of Trustees.  It will require the following:

-  Updates to Guidelines will be required
-  Staff training will be required
-  New process to manually add RSA coverage will be required


Respectfully submitted,

Member Services
American Registry for Internet Numbers (ARIN)


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Annex A

Policy Proposal 2007-21
PIv6 for legacy holders with RSA and efficient use

Author: Scott Leibrand

Proposal type: new

Policy term: permanent

Policy statement:

Modify NRPM section 6.5.8.1 (Direct assignments from ARIN to end-user
organizations: Criteria), to read:

To qualify for a direct assignment, an organization must:

1. not be an IPv6 LIR; and 2. qualify for an IPv4 assignment or
allocation from ARIN under the IPv4 policy currently in effect, or
demonstrate efficient utilization of a direct IPv4 assignment or
allocation covered by a current ARIN RSA.

Rationale:

Current policy allows direct IPv6 allocations and assignments to nearly
all organizations with IPv4 allocations or assignments from ARIN. As a
result, such organizations can get IPv6 space just as easily as they can
get IPv4 space, making it easy for them to transition to IPv6 as soon as
they're ready to do so. However, there are some organizations who
received IPv4 /23's and /24's prior to the formation of ARIN, and use
that space in a multihomed, provider-independent fashion. Under current
policy, such organizations cannot get IPv6 PI space without artificially
inflating host counts, and are therefore discouraged from adopting IPv6.
This policy proposal aims to remove this disincentive, and allow such
organizations to easily adopt IPv6.

In addition, pre-ARIN assignments were issued through an informal
process, and many legacy resource holders have not yet entered into a
formal agreement with ARIN, the manager of many such IP numbering
resources. This policy proposal would require that such assignments be
brought under a current ARIN Registration Services Agreement, thereby
formalizing the relationship.

Some pre-ARIN assignments may not be used efficiently. As unallocated
IPv4 numbering resources are approaching exhaustion, it is important to
ensure efficient utilization of IPv4 assignments, and to arrange for
reclamation of unused space. Therefore, this policy would require that
the organization wishing to receive IPv6 PI space demonstrate efficient
utilization of their IPv4 assignment. (Efficient utilization is already
defined elsewhere in policy, and the exact mechanism for achieving and
determining efficient use is a matter of procedure, not of policy, so
detailed procedures are not included in the policy statement above. The
intent is that any organization with an assignment of /23 or larger
which is less than 50% utilized would renumber and return whole unused
CIDR blocks as necessary to bring the remaining CIDR block to 50%
utilization or higher. A /24 should be considered efficiently utilized
as long as it is in use for multihoming, as /25's and smaller are not
routable for that purpose.)

It has been suggested that this policy would be useful only until the
growth of IPv6 exceeds the growth of IPv4. I would agree with this, and
would further posit that the existing "qualify ... under the IPv4 policy
currently in effect" language should also be modified at that time. I
have therefore proposed this policy with a policy term of "permanent",
with the expectation that this section of policy (6.5.8.1) will be
rewritten at the appropriate time to entirely remove all IPv4 dependencies.

Timetable for implementation: immediate