[ppml] Policy Proposal 2006-7 - Staff Assessment
JORDI PALET MARTINEZ
jordi.palet at consulintel.es
Mon Apr 23 11:40:01 EDT 2007
Hi,
I think this staff assessment (for all the policy proposals, not speaking
about this one now) it is very useful. However, I will like to suggest that
it may be much better to have it as part of the PDP with a different timing.
For example, if this comes once the AC decide to accept the proposal, the
author (and also other participants in ppml) could suggest alternative
wordings or whatever it is required to react in time for a possible reviewed
version of the proposal (of course if the proposal has been submitted in
time to allow that, as in this case which was over half a year ago).
Now regarding this proposal, the first thing I will like to say is that I
like very much the staff wording suggested in Annex B below. I also believe
that this doesn't change the content of the proposal, so hopefully it can be
accepted as such by the PDP.
Regarding "How can staff verify that an organization is new to providing
"Internet services"?", it believe it is obvious. If the organization is NOT
a "known ISP" as per the existing policy text, should be considered as
"new". I think this could be read also as new to "ARIN" ?
Regarding to "What happens at the end of 1 year if the v6 block is not
announced?", I will say that the staff should follow the same criteria they
use today for the existing option d. What they do if the 200 /48 aren't
assigned to other organizations within five years ? Also c is still
required.
Regarding "What if the IPv6 address space is used on a ³private network² and
can¹t be seen from the public Internet?". The suggested proposal is not
intended for private usage, and point b already indicates that must not be
an end site, so the organization necessarily will need to announce the
allocated space as in c.
Regards,
Jordi
> De: Member Services <info at arin.net>
> Responder a: <ppml-bounces at arin.net>
> Fecha: Mon, 16 Apr 2007 08:51:33 -0400
> Para: <ppml at arin.net>
> Asunto: [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. Issues and concerns
>
> A. ARIN staff
>
> 1. 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.
>
> 2. How can staff verify that an organization is new to providing
> "Internet services"?
>
> 3. What happens at the end of 1 year if the v6 block is not announced?
>
> 4. What if the IPv6 address space is used on a ³private network²
> and can¹t be seen from the public Internet?
>
> 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:
>
> - Revisions to registration guidelines
> - Staff Training
>
> Respectfully submitted,
>
> Member Services
> American Registry for Internet Numbers (ARIN)
>
>
> ##*##
>
>
> 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
>
> ##*##
>
>
> 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.
>
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