[ARIN-consult] discounting registration fees for IPv6 assignments

Owen DeLong owen at delong.com
Wed Oct 31 13:16:18 EDT 2012

On Oct 31, 2012, at 05:45 , Michael Richardson <mcr+arin at sandelman.ca> wrote:

>>>>>> "Jesse" == Jesse D Geddis <jesse at la-broadband.com> writes:
>    Jesse> I don't think it would hurt anything to use a standard flat fee per block
>    Jesse> size. I have a feeling it would lower costs significantly for the vast
>    Jesse> majority of people and I think it would also server better to get IPv6 out
>    Jesse> there. I also think it would force carriers to take efficiency in
>    Jesse> addressing much more seriously than they do now. All of these are good
>    Jesse> things There's no better time than now, with IPv6 in relative infancy to
>    Jesse> start fostering such things with policy and fees.
> Further, IPv6 is for more than the Internet.
> Address space != default-free-zone-router slot.
> Enterprises need IPv6 space for use internally (they might have PA
> addresses as well). ULA won't cut it in a big organization.
> Products/systems often need IPv6 space for use *inside-the-chassis*
> ** But, for now, the policy says that you can't have it unless you have two
> ** upstreams...that's a policy discussion.

I think you may have missed the latest updates to IPv6 policy. Here is an excerpt of the current IPv6 end-user assignment policy:

============================ Initial Assignment Criteria
Organizations may justify an initial assignment for addressing devices directly attached to their own network infrastructure, with an intent for the addresses to begin operational use within 12 months, by meeting one of the following criteria:
Having a previously justified IPv4 end-user assignment from ARIN or one of its predecessor registries, or;
Currently being IPv6 Multihomed or immediately becoming IPv6 Multihomed and using an assigned valid global AS number, or;
By having a network that makes active use of a minimum of 2000 IPv6 addresses within 12 months, or;
By having a network that makes active use of a minimum of 200 /64 subnets within 12 months, or;
By providing a reasonable technical justification indicating why IPv6 addresses from an ISP or other LIR are unsuitable.
Examples of justifications for why addresses from an ISP or other LIR may be unsuitable include, but are not limited to:
An organization that operates infrastructure critical to life safety or the functioning of society can justify the need for an assignment based on the fact that renumbering would have a broader than expected impact than simply the number of hosts directly involved. These would include: hospitals, fire fighting, police, emergency response, power or energy distribution, water or waste treatment, traffic management and control, etc.
Regardless of the number of hosts directly involved, an organization can justify the need for an assignment if renumbering would affect 2000 or more individuals either internal or external to the organization.
An organization with a network not connected to the Internet can justify the need for an assignment by documenting a need for guaranteed uniqueness, beyond the statistical uniqueness provided by ULA (see RFC 4193).
An organization with a network not connected to the Internet, such as a VPN overlay network, can justify the need for an assignment if they require authoritative delegation of reverse DNS. Initial assignment size
Organizations that meet at least one of the initial assignment criteria above are eligible to receive an initial assignment of /48. Requests for larger initial assignments, reasonably justified with supporting documentation, will be evaluated based on the number of sites in an organization’s network and the number of subnets needed to support any extra-large sites defined below.
The initial assignment size will be determined by the number of sites justified below. An organization qualifies for an assignment on the next larger nibble boundary when their sites exceed 75% of the /48s available in a prefix. For example:
More than 1 but less than or equal to 12 sites justified, receives a /44 assignment;
More than 12 but less than or equal to 192 sites justified, receives a /40 assignment;
More than 192 but less than or equal to 3,072 sites justified, receives a /36 assignment;
More than 3,072 but less than or equal to 49,152 sites justified, receives a /32 assignment; etc... Standard sites
A site is a discrete location that is part of an organization’s network. A campus with multiple buildings may be considered as one or multiple sites, based on the implementation of its network infrastructure. For a campus to be considered as multiple sites, reasonable technical documentation must be submitted describing how the network infrastructure is implemented in a manner equivalent to multiple sites.
An organization may request up to a /48 for each site in its network, and any sites that will be operational within 12 months. Extra-large sites
In rare cases, an organization may request more than a /48 for an extra-large site which requires more than 16,384 /64 subnets. In such a case, a detailed subnet plan must be submitted for each extra-large site in an organization’s network. An extra-large site qualifies for the next larger prefix when the total subnet utilization exceeds 25%. Each extra-large site will be counted as an equivalent number of /48 standard sites.
You must meet ANY ONE (or more) of the criteria in If you have IPv4, you qualify. If you have 2000 nodes or 200 subnets, you qualify. If you are multihomed, you qualify. If none of those apply and you can write a convincing technical justification for some other reason, you qualify.

In other words, IPv6 PI policy isn't quite a Pez dispenser, but it's _REALLY_ darn close to it.

When David and I were reworking the policy last time, we wanted to make it as easy as possible for organizations with remotely reasonable need to get PI IPv6 space and I believe we accomplished that goal with the above policy as written. If you think that there is a legitimate use case for PI IPv6 space that is not covered in the above policy text, I would be very interested in knowing more about that case and developing additional policy language to support it if necessary.

> -> Fine, but don't tie IPv6 pricing to IPv4 scarcity.
> (If people are worried about DFZ routing slots, then find a way to write
> olicy to discourage the piles of IPv4/24s that pollute the table)

How do you distinguish the piles of /24 pollution from the legitimate /24s?

What would such a policy look like?

How would it be part of ARIN policy given that ARIN does not control the operation of any routers outside of the few that provide ARIN's network connectivity?

I'm not trying to be obnoxious or confrontational, just trying to understand how you see such a suggestion working out in practice.


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