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[arin-ppml] Policy Proposal 2008-3 - Staff Assessment

Policy Proposal 2008-3
Title: Community Networks IPv6 Allocation
Revised: 16 September 2008
Revised Assessment: 8 October 2008


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 below and at:
http://www.arin.net/policy/proposals/2008_3.html

II. Proposal Summary

ARIN staff understands this policy would provide an IPv6 assignment of a
/48 or larger to any community network that has at least 100 users and,
if it has less than 200 users, projects to double its user base within
one year.


III. Issues and concerns

A. ARIN Staff Comments

No modification to section 6.5.8.1b is necessary. The new section 6.5.9
contains all necessary policy information.

The policy text for 6.5.9.3 requires the community network to provide a
plan for doubling its user base within one year if it currently has less
than 200 users. This would penalize networks that are close to the 200
user requirement. For example, a network with 199 users would need to
show a plan for 398 users within one year, while a network with 100
users would need to show a plan for 200 users within a year. A network
with 200 users wouldn’t need to provide any plan to double its user
base, even though it has just one more user than the network with 199.
Is this intended? If not, the requirement should be converted to a hard
target, such as “must show a plan to provide service to at least 200
users within one year”.

For clarity, 6.5.9 should follow the format established by current
section 6.5.8.

Section 6.5.9.1 should be entitled "Qualification Criteria" and contain
the text in 6.5.9.3. A suggested wording based on the concerns expressed
in #2 above is:
6.5.9.1 Qualification Criteria
To qualify for a direct assignment, a community network must demonstrate
it will immediately provide service to at least 100 users and must
demonstrate a plan to provide service to at least 200 users within one year.

Section 6.5.9.2 ("Initial assignment size") should have the text
currently listed as 6.5.9.1 with the first sentence removed.

Section 6.5.9.3 ("Subsequent assignment size") should have the text
currently listed as 6.5.9.2.

B. ARIN General Counsel

Counsel sees no significant legal or litigation risk regarding this policy.

IV. Resource Impact - Minimal

The resource impact of implementing this policy is minimal. Barring any
unforeseen resource requirements, this policy could be implemented
within 120 days from the date of the ratification of the policy by the
ARIN Board of Trustees. It will require the following:

- New template
- Registration software changes
- New set of guidelines
- Staff training

Regards,

Member Services
American Registry for Internet Numbers (ARIN)


#####


Policy Proposal 2008-3
Community Networks IPv6 Allocation

Author: Joshua King

Date: 16 September 2008

Proposal type: new

Policy term: permanent

Policy statement:

[Add Section 2.8 to the NRPM.]

2.8 Community Network
A community network is a generic reference to a network that is
operated by a group of people living in a particular local area
organized for the purposes of delivery or provision of free or low-cost
network services to the residents of an incorporated or unincorporated
regional municipality, city, town, village, rural municipality,
township, county, district or other municipality or other such
geographic space, however designated. In order to qualify as a community
network under this policy, the community network must certify to ARIN
that their staff is at least half volunteer and that their annual
revenue is less than $250000 (in 2009 dollars, adjusted for inflation).
Legal responsibility for the network as a whole must be held by an
organization either possessing non-profit status or fiscally sponsored
by a non-profit organization or university.

[Modify 6.5.8.1b as follows.]
b. qualify for an IPv4 assignment or allocation from ARIN under the IPv4
policy currently in effect or be a qualifying Community Network as
defined in Section 2.8, with allocation criteria defined in section 6.5.9.

[Add Section 6.5.9 to the NRPM.]

6.5.9 Community Network Allocations
6.5.9.1. Initial assignment size
Organizations defined as Community Networks under section 2.8 are
eligible to receive a direct assignment. The minimum size of the
assignment is /48. Organizations requesting a larger assignment must
provide documentation of the characteristics of the Community Network's
size and architecture that require the use of additional subnets. An
HD-Ratio of .94 with respect to subnet utilization within the network
must be met for all assignments larger than a /48.

These assignments shall be made from a distinctly identified prefix and
shall be made with a reservation for growth of at least a /44. This
reservation may be assigned to other organizations later, at ARIN's
discretion.

6.5.9.2. Subsequent assignment size
Additional assignments may be made when the need for additional subnets
is justified. Justification will be determined based on a detailed plan
of the network's architecture and the .94 HD-Ratio metric. When
possible, assignments will be made from an adjacent address block.

6.5.9.3. Number of customers
Community Networks seeking an allocation must demonstrate that they
provide for a user base of at least 100 through connectivity to homes
and businesses, public facilities, public access points, or mobile
users. Community Networks with user bases of under 200 must also submit
a plan for doubling their service base over the next year.

Rationale:

There are currently a number of projects globally that aim to develop
community network infrastructure and related technologies. These are
usually coordinated by volunteer-run, grassroots organizations which
lack many of the resources of traditional internet service providers and
other network operators. They have diverse goals, including public
policy, software development, and implementation of community services
and resources. Many of them provide services free of charge, and thus
lack any paying user base. However, in order to create and maintain
community networks that are often composed of hundreds if not thousands
of inexpensive consumer-grade network devices, a significant amount of
address space will be required. Current-generation workarounds to this
problem, such as NAT, not only make it difficult to develop
next-generation decentralized network technology by segmenting the
community's architecture from the Internet as a whole, but will cease to
be as viable a stopgap as the Internet moves towards IPv6 integration.

Community-based, volunteer-run organizations that are operated with an
eye towards the public good often do not have the resources to qualify
as an LIR under the current policy. They are often multi-homed networks
utilizing multiple, relatively inexpensive consumer-grade internet
uplinks and lacking the funds to meet the qualifications for an IPv4
allocation, but which wish an avenue to develop future IPv6 capability
for their constituent users. If this proposal is adopted, I intend to
immediately move forward with the process to request a change in fee
structure for community networks so that they are permitted to pay a
small percentage of their annual revenue in lieu of a flat fee. By
establishing a procedure by which these organizations can seek to
acquire the resources they require for further development, ARIN can
reach out to this active community and establish a small but definite
space for them in the future of Internet.

Timetable for implementation: Immediate.