[ppml] Policy Proposal 2007-5 - Staff Assessment

[Member Services]

Policy Proposal 2007-5
Changes to IPv6 policy - removal of "multiple /48" justification

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 2007-5 is available as Annex A below and at:
   http://www.arin.net/policy/proposals/2007_5.html

II.	Understanding of the proposal

   Current policy is that ISPs are required to obtain approval from ARIN
when assigning an additional /48 to a single site. ARIN staff
understands that this proposal would remove that policy.

III.	Issues and concerns

   A.	ARIN Staff

     1.	ARIN has not yet seen or reviewed any requests for additional or
subsequent assignments to the same end site.

     2.	The existing policy text is confusing and might indicate to some
that even initial assignments of more than a /48 would need to be
reviewed by staff. However, we have not done this and have allowed
larger than /48 reassignments to be processed.

     3.	In addition, the policy text contains no criteria for ARIN to
use in their assessment of assignments larger than /48.

   B.	ARIN General Counsel

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

IV.	Resource Impact - Minimum

The resource impact of implementing this policy is viewed as minimum.
Barring any unforeseen resource requirements, this policy could be
implemented within 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:

- Template change
- Minor update to software
- Revisions to registration guidelines
- Staff Training

Respectfully submitted,

Member Services
American Registry for Internet Numbers (ARIN)


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Annex A

Policy Proposal 2007-5
Changes to IPv6 policy - removal of "multiple /48" justification

Proposal type: delete

Policy term: permanent

Policy statement:

Delete section 6.5.4.2 of NRPM.

Rationale:

The current text requires the LIR to justify to the RIR/NIR when
assigning multiple /48s to a single end site. It seems that the reason
for this requirement is the lack of experience, which seems unreasonable
after a few years this policy has been implemented, even if may not have
been specific cases which used this policy section.

It seems useless, now that there is already deployment experience, to
require a justification from the LIR to ARIN for assigning multiple /48s
(or a shorter prefix, such as for example a /47). It is up to the LIR to
require the justification to its own customers and decide according to
it. The LIR will be already responsible to justify to ARIN the usage of
any allocated block(s) when requesting for more, and this will already
implicate an implicit justification of this kind of assignments.

With this policy change, both ARIN and LIR staff will save resources in
a justification, which seems unnecessary and should be completely on the
hands of the LIR itself.

No financial/liability implications for the community and ARIN are foreseen.

No special conditions, fees, exceptions, etc. seem to be required.

Timetable for implementation: Immediate