[arin-ppml] Draft Policy ARIN-2017-5: Equalization of Assignment Registration requirements between IPv4 and IPv6

[theone at uneedus.com]

I would like to give an example of why the current /64 or more rule for 
IPv6 SWIP vs IPv4 is an issue for a project I am working on:

I am working on a project to enable public IPv6 on Public Transit busses. 
Currently we have a public V4 address assigned by the winner of a State 
Government Contract with a major wireless provider used for each bus in 
the fleet, which is in excess of 1000 busses.  Originally we used this 
connection only for administrative use, such as communicating the real 
time location of each bus back to headquarters and access to cameras and 
reporting in an emergency.  In the last few months, we added an additional 
RFC1918 IPv4 private address subnet so that a wireless access point for 
public wifi is available on each bus.  In order to address the 
administrative equipment from headquarters, we must have a static address 
to connect to.

Because it is a State Government contract, the major wireless provider 
still has to provide us public, static IPv4 addresses until the end of 
this contract, which is Sept 30, 2018.  This major provider has publiclly 
announced that they will no longer provide Static IPv4 addresses to 
anyone, and we have been told they will not bid on the next contract if 
that contract would require an option to assign static v4 addresses like 
the current contract, as they are leasing the IPv4 addresses we are using. 
We have been told if we want Static assignments, they now must be only 
IPv6, and they will provide up to a /56 for each bus out of a /48 of their 
space assigned to all our busses.

Thus, there is a plan to put the administrative parts of the busses onto 
IPv6 before the end of the contract. We wont care if the carrier v4 
address is static, public, or even CGnat, as it would then only be only 
used for the public v4 wifi.  We might also consider a PI v6 allocation 
from ARIN if they will route it to us.  This would keep us from having to 
renumber if the State Contract provider changes, and a /48 of space would 
be plenty for all v6 use.

Here is the SWIP issue:

The major provider according to the current rules must SWIP each static 
"Serving site"(NRPM 2.14), which in this case is a transit bus.  Each bus 
is its own account with the wireless provider, and will have its own 
static IPv6 network and IPv4 address assigned.

NRPM 2.12 requires each SWIP entry must contain Street Address, City, 
State, and Zip Code.  How can I give a Street Address for a mobile serving 
site as required by NPRM 2.12?  Each bus covers 200-300 miles a day, and 
about 1/2 do not return to our central location during any portion of 
their daily trips. I am sure that the abuse address for the SWIP will 
attract attention because of public wifi on each bus, and our intent to 
enable v6 connections on each "Serving Site" (Transit Bus) including the 
public wifi.

If the current proposal at more than a /60, or a greater amount such as 
more than a /56 is adopted, the wireless provider no longer has to SWIP 
each site (Transit Bus) just like v4. This would allow us to avoid having 
to SWIP each "Serving Site" as the current IPv6 rules would require and 
keep us legal with the policy manual.

If the community comes out against relaxing the IPv6 SWIP rules, my only 
other choices are to hope the wireless provider will ignore the NRPM, or 
write another proposal to add language to 2.12 to allow mobile "Serving 
Sites" to be registered to a central location to avoid the street address 
and city problem with mobile "Serving Sites".  The wireless provider is 
unlikely to allow all the busses to be SWIP'ed to the Central site because 
they would be the one trying to explain to ARIN why 1000 networks are all 
registered at the same location.

This was never an issue with IPv4, as each bus has only one IPv4 address, 
which did not trigger any SWIP requirement.  This example also shows how 
the different treatment of v4 and v6 affects small users of v6.

I Would love to hear some input as to the issue of dealing with "Serving 
Sites" that are mobile (like Transit Busses), or do not have a street 
address assigned, like some of the rural WISP sites I work with including 
my own home. If I decided to put a non residental circuit there that 
includes any amount of IPv6, it would not be able to be SWIP'ed as I have 
no Street Address and the rules do not allow the field to be left blank. 
What then???

Albert Erdmann
Network Administrator
Paradise On Line Inc.