[arin-ppml] LAST CALL - Recommended Draft Policy ARIN-2017-5: Improved IPv6 Registration Requirements

[ARIN]

The ARIN Advisory Council (AC) met on 6 October 2017 and decided to send 
the following to Last Call:

Recommended Draft Policy ARIN-2017-5: Improved IPv6 Registration 
Requirements

The AC provided the following statement to the community:

"Based on strong community support - on both the Public Policy Mailing 
List and in person at ARIN 40 during the policy consultation - for
replacing the "should" qualifier in section 6.5.5.4 with "shall", the 
Advisory Council, after careful review and discussion, has made the 
requested change to the text."

Feedback is encouraged during the Last Call period. All comments should 
be provided to the Public Policy Mailing List. This Last Call period 
will expire on 10 November 2017. After Last Call, the AC will conduct 
their Last Call review.

The full text is below and available at:
https://www.arin.net/policy/proposals/

The ARIN Policy Development Process is available at:
https://www.arin.net/policy/pdp.html

Regards,

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



AC's Statement of Conformance with ARIN's Principles of Internet Number 
Resource Policy:

This proposal is technically sound and enables fair and impartial number 
policy for easier IPv6 Registrations. The staff and legal review noted a 
single clarification issue which has been addressed. There is ample 
support for the proposal on PPML and no concerns have been raised by the 
community regarding the proposal.

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 "assignment containing a /64 or more addresses" and change to 
"re-allocation, reassignment containing a /47 or more addresses, or 
subdelegation of any size that will be individually announced,”

and

2) Alter section 6.5.5.2. "Assignments visible within 7 days" of the 
NRPM to strike the text "4.2.3.7.1" and change to “6.5.5.1"

and

3) Alter section 6.5.5.3.1. "Residential Customer Privacy" of the NRPM 
by deleting the phrase "holding /64 and larger blocks"

and

4) Add new section 6.5.5.4  "Registration Requested by Recipient" of the 
NRPM, to read: "If the downstream recipient of a static assignment of 
/64 or more addresses requests publishing of that assignment in ARIN's 
registration database, the ISP shall register that assignment as 
described in section 6.5.5.1."

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.