[ppml] Policy Proposal 2003-4: IPv6 Policy Changes

[Thomas Narten]

I have some comments on this proposal.

> 5.1.1
> 	[under d) add:

> 	Other organizations are defined as any customer of the LIR.

I have no issue with this. The intent of the orignal wording was to
make it clear that the LIR is assigning address space to someone else,
not themselves internally. Clearly, a customer of the ISP is such an
example.

> 	No distinction will be made in terms of number of IP addresses
> 	required, even if that number is one.

Not sure why this is needed or what problem this is intended to
fix. Specifically, the intent of the LIR requirement is that the LIR
be assigning address space in such a way that it will use up that
address space at some point in the future as IPv6 gets significant
deployment. If ISPs are giving out /48s and /64s, this will presumably
happen. But if the ISP is giving each customer a /128 (i.e, one
address), it is much less clear how quickly address space is being
consumed.

Looking it another way, if an ISP is planning on giving its customers
/128s, why does it /32 worth of address space?

> 5.8 Allocation for Early Adopters

> 5.8.1 Waiver of criteria listed in 5.1.1 (d)

> 	To promote the allocation of IPv6 space the requirement to make 200
> 	/48 assignments within two years shall be waived for anyone
> 	requesting IPv6 space before Dec 31, 2004 or until this policy
> 	is amended.  In the event that this policy is amended the
> 	existing IPv6 space holders shall not be subject to new or
> 	waived criteria for a period of 10 years from their initial
> 	allocation date.

The intention of 5.1.1 is to give allocations to organizations that
are assigning address space to end sites. As we don't really know in
what time IPv6 will really take off, it is hard to come up with a hard
rule that says at what point an orgnization is making a Bad Faith
effort at assign space to customers. The "plan" for "200 sites", over
"2 years" was an attempt to capture the notion that allocations go to
organizations who are serious about assigning space to end sites, as
opposed to those that just want a "permanent" allocation that is "PI",
but can't otherwise meet the intention that they (eventually) assign
to significant numbers of end sites.

At the time this text was originally discussed, I think the individual
RIRs made it fairly clear that they did not intend to immediately go
after LIRs after 2 years to see if they really had 200 customers. What
they wanted was a tool to push back if a particular LIR clearly wasn't
doing anything with IPv6, had no real intentions too, and meanwhile,
looking at what other LIRs were doing, IPv6 was actually taking off
and compared to other LIRs, a particular LIR was really not making a
Good Faith attempt at meeting its obligations. Those LIRs would be
targets.

So, I'd certainly be willing to consider changes that made the above
more clear, or made potential LIRs feel better about applying (when
they should). But I'd be opposed to policy changes that undermines the
basic intent.

Having said that, I'm opposed to the above wording changes for 3
different reasons:

1) it goes against the spirit of being an LIR and seems to allow folks
   to get an IPv6 allocation when they have no plans to deploy
   IPv6. We should not be giving /32s to organizations that have not
   intention of assigning address space to end sites.

2) I'm also opposed to a 10 year waiver on fees. That is way too
   long. I think it is fine to have a fee waiver for a year or two,
   subject to extension as needed (which is more-or-less already the
   current situation, I believe). But I see no reason to lock in a ten
   year time period. That is excessive.

3) As a general rule, it seems bad policy to say that for any policy
   we put into place today, it is exempt from future policies or
   future policy changes. We always need to reserve the right to
   correct mistakes. That does not mean that new policies should
   ignore previous policies. Indeed, it should be required that new
   policies consider the impact they have to existing allocation
   holders. But they should retain the option to modifying previous
   policies.

> 5.8.2 Waiver of fees

> 	a) To promote the allocation of IPv6 space all IPv6 related fees
> 	shall be waived until Dec 31, 2006 for anyone requesting and
> 	receiving space before Dec 31, 2004.  In the even that this
> 	policy is amended the existing IPv6 space holders shall
> 	under no circumstances be subject to waived or new fees until
> 	Dec 31, 2006.

Per above, I don't have a big problem with waiving fees, if the fees
are considered to be an excessive burden. But I'd like to understand
that better. My understanding is that that the fees associated with
getting a /32 are relatively low, and are a small fraction of the $$
that would be required to provide a production IPv6 service. I'd like
to understand more how the existing fees are barriors to getting IPv6
space and providing IPv6 service.

> 	b) For billing purposes fees will be due according to normal
> 	ARIN billing policies on Jan 1, 2007.  All early adopters
> 	will have the same billing date regardless of the date
> 	they received their allocation.

> 5.8.3 Micro Allocations

> 	a) To promote the allocation and deployment of IPv6 all the
> 	criteria in 5.1.1 shall be waived to those requesting a /48
> 	micro allocation before Dec 31, 2004, or until this policy
> 	is changed.  If this policy is changed, current space holders
> 	shall not be subject to any new or waived criteria.

This goes against the intent of the IPv6 policy, namely that only LIRs
get address space from the RIRs, and that end sites do not. The above
seems to allow end sites to get /48s directly from RIRs. This is a
mistake and will open the floodgates.

> 	b) All fees shall be waived under the same rules listed in
> 	5.8.2.

> 	c) Those receiving micro allocations shall not be allowed to
> 	make further allocations or assignments out of their /48.  It
> 	is intended for their internal use only.

> 	d) When possible those receiving micro allocations shall
> 	return their allocation and receive a new /48 from their
> 	upstream provider (a LIR).  This is requested in a good faith
> 	manner until Jan 1, 2007 at which time all micro allocations
> 	granted under these waived criteria must be returned.

Thomas