[ppml] Policy Proposal 2007-25 - Staff Assessment

Policy Proposal 2007-25
IPv6 Policy Housekeeping

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_25.html

II. Understanding of the proposal

ARIN staff understands that this proposal would make changes to the IPv6
section of the NRPM. It would remove the prefix size from the initial
IPv6 allocation criteria, move a modified version of 6.5.3 to a new
location (6.5.4.4), establish criteria for assignments larger than a /48
(.94 HD-Ratio), and make reserved space (from the /44s) available for
other use.

III. Comments

   A. ARIN Staff

     1. Change I - the statement be a “known ISP” is still contained in
this policy.  This term is ambiguous and open to interpretation and
should be defined.  It should be noted that there is no authoritative
definition for either ISP or LIR.

     2. Change J - The section number, 6.5.3, would be retired instead
of renumbering all the subsequent sections.

   B. ARIN General Counsel

Counsel does not believe this policy creates any legal issues that need
further consideration.

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
-  May be minor text changes to the template

Respectfully submitted,

Member Services
American Registry for Internet Numbers (ARIN)


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Annex A

Policy Proposal 2007-25
IPv6 Policy Housekeeping

Author: Leo Bicknell

Proposal type: modify

Policy term: permanent

Policy statement:

Change I:

In section 6.5.1.1.d, replace the existing statement with the new statement:

"be an existing, known ISP in the ARIN region or have a plan for making
at least 200 end-site assignments to other organizations within 5 years."

Change J:

Remove section 6.5.3 entirely. Update all subsequent sections to have
new section numbers (6.5.[n-1]).

Replace part of the text as (new) section 6.5.4.4:

"All /56 and larger assignments to end sites are required to be
registered either by the LIR or its subordinate ISPs in such a way that
the RIR/NIR can properly evaluate the HD-Ratio when a subsequent
allocation becomes necessary."

Change K:

Section 6.5.8.2, add the following sentence to the end of the first
paragraph:

"An HD-Ratio of .94 must be met for all assignments larger than a /48."

Add to the end of the second paragraph:

"This reservation may be assigned to other organizations later, at
ARIN's discretion."

Change L:

Section 6.5.8.3, add a sentence between the two existing sentences:

"Justification will be determined based on the .94 HD-Ratio metric."

Rationale:

When the IPv6 policy was passed, it was considered to be an "interim"
policy, and it was intended to be similar in all 5 RIR's. Since that
time it has become clear the policy is no longer interim (and proposal
2007-4 was passed to change just that) and it has also been modified
separately in the different RIR's.

It was brought to the ARIN AC's attention that there were a number of
problems with "Section 6" of the NRPM as a result of this legacy:

* The policy contained a large number of items that were not policy. *
The policy contained a few items that were self contradictory. * The
added text was redundant in some cases with existing text. * The policy
was overly vague in a few areas, leaving ARIN staff to have to make
interpretations of what the policy intended. * Policy changes made since
the initial IPv6 policy was adopted have not always updated all of the
relevant sections due to the complexity of section 6.

The intent of these changes is not to change any existing policy, but
rather to remove all non-policy items, and update any ambiguous items
with the way that ARIN staff is currently interprets the policy.

Change I:

Proposal 2005-8 amended section 6.5.4.1 to allow /56 and /64
allocations, but section 6.5.1.1.d was never updated to match the
change. It is believed the intent of the policy, and ARIN staff's
current interpretation of the policy match the updated text.

Change J:

The first part is not policy, and incorrectly states there is no policy
as section 6.5.4 has the policy in it. Take the one useful part and make
it part of the 6.5.4 criteria.

Change K:

No metric is currently listed to justify a larger initial assignment. It
is believed ARIN staff is currently applying the HD-Ratio similar to the
ISP policy, this puts that in writing.

Make it clear that the reservation may not exist in perpetuity.

Change L:

No metric is given to justify additional assignments. It is believed
that ARIN staff is currently applying the HD_Ratio similar to the ISP
policy, this puts that in writing.

Timetable for implementation: Immediate