[arin-ppml] Draft Policy 2012-2: IPv6 Subsequent Allocations Utilization Requirement

[ARIN]

Correction. Earlier post did not use updated policy text.

Draft Policy ARIN-2012-2
IPv6 Subsequent Allocations Utilization Requirement

On 16 February 2012 the ARIN Advisory Council (AC) selected "Clarifying 
requirements for IPv4 transfers" as a  draft policy for adoption 
discussion on the PPML and at the Public Policy Meeting in Vancouver in 
April.

The draft was developed by the AC from policy proposal "ARIN-prop-159 
IPv6 Subsequent Allocations Utilization Requirement." 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. Below the draft 
policy is the ARIN staff and legal assessment, followed by the text that 
was submitted by the AC.

Draft Policy ARIN-2012-2 is below and can be found at:
https://www.arin.net/policy/proposals/2012_2.html

You are encouraged to discuss Draft Policy 2012-2 on the PPML prior to
the April 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)


## * ##


Draft Policy ARIN-2012-2
IPv6 Subsequent Allocations Utilization Requirement

Date: 22 February 2012

Policy statement:

Proposal text:
Modify 6.5.3.b as follows:
An LIR may request a subsequent allocation when they can show utilization
of:
75% or more of their total address space
   or
more than 90% of any serving site
   or
when 75% of the aggregate has been subnetted, and each subnet contains 
at least 1* customer or infrastructure allocation or assignment
  ( *1 can be replaced here with any reasonable number)

Original Rationale:

If you are executing to a long term plan, you should be able to continue 
to execute on your approved allocation and assignment plan regardless of 
the number of regions/groupings you originally planned for. We want to 
promote tie downs on nibbles and long term planning.

Timetable for implementation: Immediately


##########


ARIN Staff and Legal Assessment

Draft Policy:  PP 159 “IPv6 Subsequent Allocations Utilization Requirement”
Date of Assessment:  15 Feb 2012
1.  Proposal Summary (Staff Understanding)

The intent of this proposal is to allow an additional way for ISP's that 
have already begun using their IPv6 space but who may not have 
sufficiently planned for longer term growth, to receive an additional 
allocation.   This policy would allow an organization to qualify for an 
additional IPv6 allocation if they can show that 75% of their IPv6 
address space as a whole is subnetted, provided that each subnet has at 
least 1 customer or infrastructure assignment/allocation.

2. Staff Comments:

A. ARIN Staff Comments:

If this policy were to be implemented exactly as written, ARIN staff 
would approve an additional IPv6 allocation as long as a network had 
subnetted at least 75% of their IPv6 allocation, with at least one 
customer or internal assignment/allocation in each subnet.  ARIN would 
not evaluate subnet size; as long as any portion of a subnet is used, 
then that subnet would be considered to be fully used, regardless of its 
size.  Effectively, this allows an operator to qualify for IPv6 
addresses any time they want, because it's trivial to subnet out 75% of 
an allocation(s) and use at least a tiny portion of each, and may not 
encourage conservation of IPv6 address space.

If the author's intent is to allow operators to make reasonable decisions
about their IPv6 deployment, another option would be to simplify the 
IPv6 additional allocation policy to allow an operator to qualify for 
more IPv6 addresses when they can show a need for them.

Alternatively, if the author's intent is to have ARIN staff evaluate 
whether those decisions are reasonable, then specific criteria needs to 
be laid out to give staff guidance as to how we do that (e.g. block 
size, timeframes, etc.).
The author's original proposal rationale stated that the expectation 
would be for ARIN to use its discretion to weed out such requests, but 
there is no policy basis for doing so.  Nothing in this text gives staff 
any basis for rejecting any subnet size, regardless of how reasonable we 
think it is.
  If the author wants ARIN to review requests to determine if 
technically reasonable, than some criteria or guidance must be provided 
within the policy text.

B. ARIN General Counsel –

This policy does not create significant legal issues.

3. Resource Impact

This policy would have minimal resource impact from an implementation 
aspect.  It is estimated that implementation could occur within 3 months 
after ratification by the ARIN Board of Trustees.

The following would be needed in order to implement:

Guidelines and procedures need to be updated
Staff training

Proposal text:
Modify 6.5.3.b as follows:
An LIR may request a subsequent allocation when they can show utilization
of:
75% or more of their total address space
   or
more than 90% of any serving site
   or
when 75% of the aggregate has been subnetted, and each subnet contains 
at least 1* customer or infrastructure allocation or assignment
  ( *1 can be replaced here with any reasonable number)

Original Rationale:

If you are executing to a long term plan, you should be able to continue 
to execute on your approved allocation and assignment plan regardless of 
the number of regions/groupings you originally planned for. We want to 
promote tie downs on nibbles and long term planning.