[arin-ppml] Draft Policy 2009-7: Open Access To IPv6

[Member Services]

Draft Policy 2009-7
Open Access To IPv6

On 20 August 2009 the ARIN Advisory Council (AC) selected "Open Access
To IPv6" as a draft policy for adoption discussion on the PPML and at
the Public Policy Meeting in Dearborn.

The draft was developed by the AC from "Policy Proposal 90: Open Access
To IPv6". Per the Policy Development Process the AC submitted text to
ARIN for a staff and legal assessment prior to its selection as a draft
policy. After reviewing the assessment the AC did not change the text.

Draft Policy 2009-7 is below and can be found at:
https://www.arin.net/policy/proposals/2009_7.htm

Below the draft policy is the ARIN staff and legal assessment, including
the original proposal text.

You are encouraged to discuss Draft Policy 2009-7 on the PPML prior to
the October Public Policy Meeting. Both the discussion on the list and
at the meeting will be used by the ARIN Advisory Council to determine
the community consensus for adopting this as policy.

The ARIN Policy Development Process can be found at:
https://www.arin.net/policy/pdp.html

Draft Policies and Proposals under discussion can be found at:
https://www.arin.net/policy/proposals/index.html

Regards,

Member Services
American Registry for Internet Numbers (ARIN)


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Draft Policy 2009-7
Open Access To IPv6

Version/Date: 31 August 2009

Policy statement:

1) Remove “by advertising that connectivity through its single
aggregated address allocation” from article 3 of section 6.5.1.1

2) Remove article 4 of section 6.5.1.1, “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” in its entirety.

Rationale:

It is acknowledged that these concepts have been put before the
community in the past. However, with the wisdom of actual operational
experience, the necessity of promoting IPv6 adoption throughout our
region, and emerging native v6 only network models, it becomes obvious
that these modifications to the NRPM are necessary. Removing the 200 end
site requirement enables smaller, but no less important and viable,
networks access to IPv6. Removing the ‘known ISP’ requirement
enfranchises new, native v6 businesses that can drive innovation and
expansion in the Internet industry, as well as other industries.
Removing the requirement for a single aggregate announcement benefits
the NRPM itself, as it has been decided by the community that it should
not contain routing advice.

Timetable for implementation: immediately upon BoT ratification

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Staff Assessment

Proposal: Open Access to IPv6 (proposal #90)

Proposal Version (Date) 21 May 2009

Date Assessment Due: 05 Aug 2009

1. Proposal Summary (Staff Understanding)

This policy proposal would modify NRPM section 6.5.1.1 by removing all
or part of two initial criteria from the the existing IPv6 policy: the
requirement to advertise the single aggregate and the requirement to
plan on making 200 end site assignments to customers or be a known ISP
in the ARIN region. The only remaining criteria to qualify for an IPv6
allocation are to be an LIR/ISP, not be an end site, and plan on
providing IPv6 connectivity to organizations and assigning them IPv6
address space.

2. Comments

A. ARIN Staff Comments

* This policy would essentially remove all criteria for obtaining IPv6
address space, making it possible for any organization that claims to be
an ISP, and who may have very few, or perhaps no customers, to get a /32
allocation directly from ARIN.

* It may be viewed as unfair in that any ISP, regardless of size, will
now be able to come to ARIN for a /32 with little or no justification,
while other large enterprise organizations that are very well known to
ARIN (i.e. Hewlett Packard) need to provide detailed justification to
obtain any assignment larger than a /48.

B. ARIN General Counsel

Counsel believes this policy is unwise as a legal matter, but will not
recommend the Board refuse to enable it. The flaw is that the policy is
so permissive that fraudulent application to obtain resources will be
made and cannot be stopped because the policy's criterion are so heavily
weighted to issuance, and the criterion for issuance so limited that the
mere assertion one is an ISP, albeit without customers, could lead to
issuance of resources, unless I am misreading the proposed policy. While
encouraging small business or start ups is important, I believe this
policy will improperly encourage and permit fraud in the issuance of
small blocs of IPv6 addresses.

3. Resource Impact

This policy would have minimal resource impact. It is estimated that
implementation would occur within three months after ratification by the
ARIN Board of Trustees. The following would be needed in order to implement:
* Updated guidelines
* Staff training

4. Proposal Text

Policy Proposal Name: Open Access To IPv6

Version/Date: 21 May 2009

Policy statement:

1) Remove “by advertising that connectivity through its single
aggregated address allocation” from article 3 of section 6.5.1.1

2) Remove article 4 of section 6.5.1.1, “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” in its entirety.

Rationale:

It is acknowledged that these concepts have been put before the
community in the past. However, with the wisdom of actual operational
experience, the necessity of promoting IPv6 adoption throughout our
region, and emerging native v6 only network models, it becomes obvious
that these modifications to the NRPM are necessary. Removing the 200 end
site requirement enables smaller, but no less important and viable,
networks access to IPv6. Removing the ‘known ISP’ requirement
enfranchises new, native v6 businesses that can drive innovation and
expansion in the Internet industry, as well as other industries.
Removing the requirement for a single aggregate announcement benefits
the NRPM itself, as it has been decided by the community that it should
not contain routing advice.

Timetable for implementation: immediately upon BoT ratification