[ppml] Policy Proposal 2006-7 - Staff Assessment

Policy Proposal 2006-7
Changes to IPv6 initial allocation criteria

ARIN Staff Assessment

The assessment of this proposal includes comments from ARIN staff and
the ARIN General Counsel. It contains analysis of procedural, legal, and
resource concerns regarding the implementation of this policy proposal
as it is currently stated. Any changes to the language of the proposal
may necessitate further analysis by staff and Counsel.

I. Proposal

Policy Proposal 2006-7 is available as Annex A below and at:
http://www.arin.net/policy/proposals/2006_7.html

II. Understanding of the proposal

ARIN staff understands this proposal would add to the list of criteria
for an initial allocation of IPv6 address space (NRPM section 6.5.1.1.).
Specifically, in addition to the common criteria, if an ISP is not
known, nor can it provide a plan, it can instead attempt to justify
intent to announce the address space within one year.

III. Comments

   A.  ARIN staff

     1.  Change I - the statement be a “known ISP” is still contained in
this policy.  This term is ambiguous and open to interpretation and
should be defined.  It should be noted that there is no authoritative
definition for either ISP or LIR.

     2.  ARIN staff is concerned about confusion that may occur if the
text is inserted as the author indicated (letter "d" already has an
"or"). ARIN staff has suggested alternative placement; see Annex B below.

     3.  What criteria would staff use to verify that an organization is
new to providing "Internet services"?

     4.  What actions should staff take at the end of 1 year if the v6
block is not announced?

     5.  The requirement to announce the v6 block at the end of 1 year
would seem to preclude the use of this address space on a private
network.  Is that the intent of this proposal?

     B. ARIN General Counsel
This policy as proposed poses no significant legal risks for ARIN.

IV. Resource Impact - Minimal

The resource impact of implementing this policy is viewed as minimum.
Barring any unforeseen resource requirements, this policy could be
implemented within 30 - 90 days from the date of the ratification of the
policy by the ARIN Board of Trustees. Implementation would not require
the acquisition of staff personnel or equipment. It will require the
following:

- Revisions to registration guidelines
- Staff Training

Respectfully submitted,

Member Services
American Registry for Internet Numbers (ARIN)


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Annex A

Policy Proposal 2006-7

Changes to IPv6 initial allocation criteria

Proposal type: Insert a new additional line item e. to 6.5.1.1 of NRPM

Policy term: permanent

Policy statement:

New organizations need a policy that allows them to apply for IPv6
address space. To provide this we need to insert a new additional line
item to 6.5.1.1. The new line item would be line 'e' as follows:
e. OR be an organization new to providing internet services, and can
justify intent to announce the requested IPv6 address space within one
year, through records such as contracts, inventory and/or other
applicable documentation.

Rationale:

- New organizations who do not want to use IPv4 at all and start off
using IPv6 addresses only, need a policy that gives them permission to
do so. This is also valid for existing companies that may or may not
have assigned IPv4 addresses and now want to start offering IPv6
services. These organizations may also wish to request IPv4 at the same
time.

- One year is given as the sufficient time frame to actually implement
usage of the IPv6 address space and reveal if the 'said organization' is
truly using the IPv6 space granted.

- Every means of documentation that can reveal 'true intent of use' is
not listed as this can be a very long list and should be left to the
discretion of the RIR staff.

- An ISP or LIR may decide to assign a different prefix size than /48.
For example, a cellular operator may use /64.

- ASN is not required because as long as they are statically routed to
an upstream and don't want to run bgp/announce directly to the Internet,
they don't need an ASN, therefore we shouldn't create policy that would
contribute to ASN bloat.

- Organization in this is defined as a Corporation, ISP, LLC et al.

In SUMMARY if this policy is implemented the change to the NRPM would
read as follows:

6.5.1.1 Initial allocation criteria
To qualify for an initial allocation of IPV6 address space, an
organization must:

a. be a LIR;

b. not be an end site;

c. plan to provide IPV6 connectivity to which it will assign IPV6
address space, by advertising that connectivity through its single
aggregated address allocation;

d. be an existing, known ISP in the ARIN region or have a plan for
making at least 200/48 assignments to other organizations within five years.

e. OR be an organization new to providing internet services, and can
justify intent to announce the requested IPV6 address space within one
year, through records such as contracts, inventory and/or other
applicable documentation.

Timetable for implementation: Immediate

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Annex B


ARIN staff suggested format for the insertion of the policy text

6.5.1.1. Initial allocation criteria
To qualify for an initial allocation of IPv6 address space, an
organization must:

a. be an LIR;

b. not be an end site;

c. plan to provide IPv6 connectivity to organizations to which it will
assign IPv6 address space, by advertising that connectivity through its
single aggregated address allocation; and

d. meet at least one of the following:

  1. be an existing, known ISP in the ARIN region.

  2. have a plan for making at least 200 /48 assignments to other
organizations within five years.

  3. be an organization new to providing internet services that can
justify intent to announce the requested IPv6 address space within one
year, through records such as contracts, inventory and/or other
applicable documentation.