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

[ARIN]

The following has been revised:

* Draft Policy ARIN-2017-5: Equalization of Assignment Registration 
requirements between IPv4 and IPv6

Revised text is below and can be found at:
https://www.arin.net/policy/proposals/2017_5.html

You are encouraged to discuss all Draft Policies on PPML. The AC will 
evaluate the discussion in order to assess the conformance of this draft 
policy with ARIN's Principles of Internet number resource policy as 
stated in the Policy Development Process (PDP). Specifically, these 
principles are:

* Enabling Fair and Impartial Number Resource Administration
* Technically Sound
* Supported by the Community

The PDP 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,

Sean Hopkins
Policy Analyst
American Registry for Internet Numbers (ARIN)





Problem Statement:

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 or less (CGnat), 
which do not trigger any ARIN registration requirement when using IPv4. 
This is NOT true when these same exact customers use IPv6.

Currently, 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.

IPv6 assignments are therefore treated stricter than IPv4 assignments. 
Policy should either treat both protocols the same, or provide incentive 
for the IPv6 future. A typical ISP serving residential and small 
business customers with both IPv4 and IPv6 would typically provide the 
following assignments to each customer site: /32 (one IP) of IPv4 and a 
/64 (one network) of IPv6. Under the current policy, that small network 
customer is exempt from registration for their IPv4 assignment, but the 
ISP would be required to register ALL IPv6 customers, even those of this 
smallest network size.

In actual fact, most ISP's that are providing their customers with a /64 
or more of IPv6 space are not in fact registering this fact with ARIN, 
even though 6.5.5.1 clearly requires this.

It is my belief that these residential and small business customers 
should not require registration if they did not require registration for 
the same size IPv4 network, including routers with Vlan and other 
security support. and thus I propose to make the standard for 
registration only those customers that have more than 16 IPv6 /64 
networks. This would treat IPv6 slightly better than IPv4, and provide 
additional encouragement for adoption.

Policy statement:

Amend 6.5.5.1 of the policy manual to strike "/64 or more" and change to 
"more than a /60".

Comments:

a.    Timetable for implementation:

Policy should be adopted as soon as possible, as the new administrative 
burden of 100% customer registration of IPv6 customers is unreasonable, 
when such is not required for those customers receiving only IPv4 
connections. IPv6 should not be more burdensome than the equivalent IPv4 
network size.

b.    Anything else:

The specific sizes chosen set the point of registration for each site to 
more than 16 networks or addresses, so that those with 16 or less IPv6 
networks (/60)  have no registration requirement. This change will 
result in both protocols being treated exactly the same, and removes 
residential and small business accounts from any registration 
requirement with ARIN, and the burden that will create for all ISP's.

There are those that might argue that a residental customer will never 
have a need for more than a /64 of IPv6. Clearly this is false in an IOT 
and/or wireless world, as many routers already provide a separate 
address range for wired vs wireless to prevent wired hacking via the 
wireless space, and also may provide a guest wireless SSID apart from 
the one provided to the regular users of that same network. Such 
separation in the IPv4 world is currently done in RFC1918 space using 
NAT. In IPv6, the equivalent must be done with different /64 blocks. 
Since good security practices require use at least 2 /64 blocks for 
wireless and/or IOT isolation, this would require a minimum of a /60 of 
IPv6 space or up to 16 networks or vlans, an amount that is consistent 
with a residential or small business network. This type network does not 
trigger registration under the current IPv4 policy, and its equal should 
not trigger registration with ARIN based on the current IPv6 policy as 
is currently the case, and thus, this policy needs to be changed.