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[arin-ppml] Draft Policy ARIN-2012-2: IPv6 Subsequent Allocations Utilization Requirement - updated staff assessment

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

Below is an updated staff assessment for ARIN-2012-2.

This draft policy is open for discussion on this mailing list and will 
be on the agenda at the upcoming ARIN Public Policy Meeting in Dallas.

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

Regards,

Communications and Member Services
American Registry for Internet Numbers (ARIN)


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ARIN Staff Assessment

1. Summary (Staff Understanding):

The intent of this proposal is to allow an additional way for ISPs that 
have already begun using their IPv6 space but who may not have 
sufficiently planned for longer term growth, to receive an additional 
allocation.

2. Staff Comments:

A. ARIN Staff Comments:

We believe that the intent of this policy is to allow ISPs who have 
allocated at least 90% of their space to serving sites to qualify for an 
additional allocation as long as the block size allocated to each 
serving site is justified based on the number of customers at the 
largest single serving site.  However, we find the new policy text "Has 
allocated more than 90% of their serving site blocks to serving sites, 
and has sufficient actual utilization at their serving sites to continue 
to justify the block size being utilized for all serving sites as 
specified in section 6.5.2."  to be unclear and confusing.

The phrase "has sufficient actual utilization at their serving sites" 
implies that what's being considered is only what's actually being used 
today, which seems to conflict with the policy's intent to allow an ISP 
to carry out their deployment plan to allow for aggregation and growth.
To illustrate the point, suppose an ISP has 180 serving sites with 200 
customers at the largest serving site, /48 per customer.  200 customers 
at the largest serving site justifies a /36 per serving site, and 180 
serving sites @ /36 justifies a /28.  The ISP deploys a /36 to each of 
the 180 serving sites.  Their IPv6 deployment goes slowly.  In one year 
they've opened 60 more serving sites, but the largest one only has 100 
customers converted to using IPv6.  They now have 240 /36s deployed to 
serving sites, which is 94% of the block.  But the "actual utilization" 
of their serving sites only justifies a /40 per serving site (100 
customers @ /48 justifies a /40).  They wouldn't qualify for more.  We 
think this is the exact opposite of the policy's intent.

To avoid this problem, staff suggests that the text be modified to: "has 
allocated more than 90% of their total address space to serving sites, 
with the block size allocated to each serving site being justified based 
on the criteria specified in section 6.5.2"  This would allow block size 
to be based on the same criteria used to determine block size for the 
initial allocation.

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

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

Date: 26 September 2012

Policy statement:

2.14. Serving Site (IPv6) When applied to IPv6 policies, the term 
serving site shall mean a location where an ISP terminates or aggregates 
customer connections, including, but, not limited to Points of Presence 
(POPs), Datacenters, Central or Local switching office or regional or 
local combinations thereof. It does not require the implementation of 
such aggregation in routing, only the implementation of an addressing 
plan that is subnetted along these topological boundaries to support the 
ability to aggregate.

6.5.3. Subsequent Allocations to LIRs

a.  Where possible ARIN will make subsequent allocations by expanding 
the existing allocation.

b.  An LIR qualifies for a subsequent allocation if they meet any of the 
following criteria:

* Shows utilization of 75% or more of their total address space

* Shows utilization of more than 90% of any serving site

* Has allocated more than 90% of their serving site blocks to serving 
sites, and has sufficient actual utilization at their serving sites to 
continue to justify the block size being utilized for all serving sites 
as specified in section 6.5.2.

c.  If ARIN can not expand one or more existing allocations, ARIN shall 
make a new allocation based on the initial allocation criteria above. 
The LIR is encouraged, but not required to renumber into the new 
allocation over time and return any allocations no longer in use.

d.  If an LIR has already reached a /12 or more, ARIN will allocate a 
single additional /12 rather than continue expanding nibble boundaries.

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