[ppml] Proposed Policy: Changes to IPv6 initial allocationcriteria

JORDI PALET MARTINEZ jordi.palet at consulintel.es
Thu Oct 12 13:10:22 EDT 2006

Hi Stephen,

My comments below, in-line.


> De: Stephen Sprunk <stephen at sprunk.org>
> Responder a: <ppml-bounces at arin.net>
> Fecha: Thu, 12 Oct 2006 11:29:54 -0500
> Para: Andrew Dul <andrew.dul at quark.net>, ARIN PPML <ppml at arin.net>
> Asunto: Re: [ppml] Proposed Policy: Changes to IPv6 initial allocationcriteria
> Thus spake "Andrew Dul" <andrew.dul at quark.net>
>>>  Policy statement:
>>>  Delete section d. of NRPM
>>> 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.
>> My main understanding of why this policy might be needed is that
>> some feel that the 200 /48 assignments is an arbitrary requirement.
>> Some feel that this type of requirement would encourage a smaller
>> LIR to provide false information to ARIN in order to obtain PA address
>> space.
>> If the problem is with the 200 /48 requirements, I would suggest just
>> striking the words "at least 200" from the policy rather than removing
>> the entire requirement.
> The requirement, as I understand it, is to prevent allocations to "flash
> in the pan" startups who have no track record or orgs who are not really
> LIRs from getting a routing table slot; the latter was a major concern
> before the PI policy was adopted (e.g. WTF did Cisco, IBM, et al qualify
> as LIRs and get /32s?).

This requirement comes from an historical perspective of the original policy
developed jointly by APNIC, ARIN and RIPE NCC.

Any allocation may "flash in the pan", but this is another issue, and that's
why we have recovery processes.

> A lot of this hinges on the ARIN staff's interpretation of "have a
> plan".  I would hope that any startup ISP with a reasonable business
> model would be accepted as "having a plan", and virtually no ISP is
> going to be economically viable without at least 200 customers.  There
> may be some specialized orgs that cater to specific niches which might
> be under 200 users, but those would likely qualify under the "known ISP"
> category, or their customers may be large enough to get PI space now
> anyways.

A problem frequently raised by several RIRs with different policy proposals
is that how a RIR staff "interprets" wordings as "have a plan". A plan may
be good enough for them, but not for the community. It seems to me that
there is a subtle line here ...

I disagree in your vision that having less than 200 customers is not
economically viable. There are many ISPs all around the world that have just
a dozen of "big" customers, enough the be on business. And if that ISP is a
new business, will not qualify as per the "known ISP" category.

> The other thing is that a small ISP is most likely to start up as a PA
> customer of another ISP; asking them to accumulate N customers before
> getting their own routing table slot seems reasonable, though there's
> room for debate on what N should be.

I think a small or new ISP doesn't necessarily going to have just one
upstream provider.

Even if has a single upstream, what about the cost of renumbering the ISP
and its customers if he decides to change the upstream or just add a second
upstream in a second stage ?

How do you define that N is reasonable for 200 or any other number ? That's
always absolutely subjective, and I don't think we do the right thing, as a
community, setting up policies that are subjective in their terms or in
their implementation by the RIR staff.

> I'd like to see stats on how many ISPs have been _denied_ an allocation
> under the existing rules, and why.  I'd also be curious if ARIN's
> counsel has any comments on the anti-trust implications mentioned in the
> rationale.  If neither of those turns up a motivation for change, I'm
> against this proposal by default on the grounds it's a solution in
> search of a problem.
>> I do not think that small ISPs should use the PI address space policy
>> to a bootstrap to getting PA address space later.
> Agreed; I'd rather have LIRs lying about their customer counts to get PA
> space than have them using PI space, which is specifically intended for
> direct assignment to end users.
> S
> Stephen Sprunk         "God does not play dice."  --Albert Einstein
> CCIE #3723         "God is an inveterate gambler, and He throws the
> K5SSS        dice at every possible opportunity." --Stephen Hawking
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