[arin-ppml] Draft Policy ARIN-2017-5: Equalization of Assignment Registration requirements between IPv4 and IPv6 - updated 2017-07-21

[Leif Sawyer]

Happy Friday, everybody.

As promised, here is the latest rewrite of the draft policy below,  and it will soon be updated at:
https://www.arin.net/policy/proposals/2017_5.html

There are two changes noted in the policy statement: the first of which reflects what seems to be the current
consensus of the PPML regarding netblock sizing; the second is to strike language that may be read as either restrictive
or non-operational.

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Problem Statement:
       Current ARIN policy has different WHOIS directory registration requirements for IPv4 vs IPv6 address assignments.
       IPv4 registration is triggered for an assignment of any address block equal to or greater than a /29 (i.e., eight IPv4 addresses).
       In the case of IPv6, registration occurs for an assignment of any block equal to or greater than a /64, which constitutes one entire IPv6 subnet and is the minimum block size for an allocation.
       Accordingly, there is a significant disparity between IPv4 and IPv6 WHOIS registration thresholds in the case of assignments, resulting in more work in the case of IPv6 than is the case for IPv4.
       There is no technical or policy rationale for the disparity, which could serve as a deterrent to more rapid IPv6 adoption.
       The purpose of this proposal is to eliminate the disparity and corresponding adverse consequences.

Policy statement:
       1) Alter section 6.5.5.1 "Reassignment information" of the NRPM to strike "/64 or more addresses" and change to "/47 or more addresses, or sub-delegation of any size that will be individually announced,"
and
       2) Alter section 6.5.5.3.1. "Residential Customer Privacy" of the NRPM by deleting the phrase "holding /64 and larger blocks"

Comments:
a.    Timetable for implementation:
       Policy should be adopted as soon as possible.

b.    Anything else:
    Author Comments:
         IPv6 should not be more burdensome than the equivalent IPv4 network size.
         Currently, assignments of /29 or more of IPv4 space (8 addresses) require registration
         The greatest majority of ISP customers who have assignments of IPv4 space are of a single IPv4 address which do not trigger any ARIN registration requirement when using IPv4.
         This is NOT true when these same exact customers use IPv6, as assignments of /64 or more of IPv6 space require registration.
         Beginning with RFC 3177, it has been standard practice to assign a minimum assignment of /64 to every customer end user site, and less is never used.
         This means that ALL IPv6 assignments, including those customers that only use a single IPv4 address must be registered with ARIN if they are given the minimum assignment of /64 of IPv6 space.
         This additional effort may prevent ISP's from giving IPv6 addresses because of the additional expense of registering those addresses with ARIN, which is not required for IPv4.
         The administrative burden of 100% customer registration of IPv6 customers is unreasonable, when such is not required for those customers receiving only IPv4 connections.


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Leif Sawyer
Advisory Council

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