[ppml] Policy Proposal: Definition of known ISP and changes to IPv6 initial allocation criteria

Scott Leibrand sleibrand at internap.com
Mon Jul 30 13:01:45 EDT 2007

I think this proposal moves in the right direction.  However, I think it 
goes a bit too far in allowing any organization with a /23 of IPv4 PA 
space to get an IPv6 /32 if they can get their ISP to re-SWIP it as an 
allocation.  I think it would be more appropriate to require that, to be 
a known ISP, an organization must reassign and/or reallocate a /23 worth 
of space to their own downstream customers.  Such reassignments and 
reallocations are already covered under existing policy requiring 
justification and efficient use, so this criterion would be much harder 
to game.

It would also be worthwhile for the policy to recognize that not all 
reallocations and reassignments are done via SWIP: rwhois should be just 
as good.


Member Services wrote:
> ARIN received the following policy proposal. In accordance with the ARIN
> Internet Resource Policy Evaluation Process, the proposal is being
> posted to the ARIN Public Policy Mailing List (PPML) and being placed on
> ARIN's website.
> The ARIN Advisory Council (AC) will review this proposal at their next
> regularly scheduled meeting. The AC may decide to:
>    1. Accept the proposal as a formal policy proposal as written. If the
> AC accepts the proposal, it will be posted as a formal policy proposal
> to PPML and it will be presented at a Public Policy Meeting.
>    2. Postpone their decision regarding the proposal until the next
> regularly scheduled AC meeting in order to work with the author. The AC
> will work with the author to clarify, combine or divide the proposal. At
> their following meeting the AC will accept or not accept the proposal.
>    3. Not accept the proposal. If the AC does not accept the proposal,
> the AC will explain their decision. If a proposal is not accepted, then
> the author may elect to use the petition process to advance their
> proposal. If the author elects not to petition or the  petition fails,
> then the proposal will be closed.
> The AC will assign shepherds in the near future. ARIN will provide the
> names of the shepherds to the community via the PPML.
> In the meantime, the AC invites everyone to comment on this proposal on
> the PPML, particularly their support or non-support and the reasoning
> behind their opinion. Such participation contributes to a thorough
> vetting and provides important guidance to the AC in their deliberations.
> The ARIN Internet Resource Policy Evaluation Process can be found at:
> http://www.arin.net/policy/irpep.html
> Mailing list subscription information can be found at:
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> Regards,
> Member Services
> American Registry for Internet Numbers (ARIN)
> ## * ##
> Policy Proposal Name: Definition of known ISP and changes to IPv6
> initial allocation criteria
> Author: Kevin Loch
> Proposal Version: 1
> Submission Date: 2007-07-27
> Proposal type: new
> Policy term: permanent
> Policy statement:
> Add the following section 6.2.10:
> 6.2.10 Existing ISP
>      An existing ISP is an organization which meets the following
>      criteria:
>         1. Has IPv4 or IPv6 address space directly allocated
>            by ARIN; or
>         2. Has at least a total of an IPv4 /23 or an IPv6 /44 of address
>            space reallocated to them via SWIP by one or more upstream
>            ISPs.
>         Address space directly assigned from ARIN or reassigned from
>         upstream ISPs does not count towards these requirements.
> Replace (d) with the following text:
>      d.  be an existing ISP in the ARIN region or have a plan for
>          making assignments to at least 200 separate organizations
>          within five years.
> Rationale:
>         This policy proposal would change two things in the IPv6
>         Initial allocation criteria.  It adds a definition for
>         "known ISP" and changes "200 /48 assignments" to
>         200 assignments of any size, but to separate organizations.
>         Existing ISP:
>         The term "existing, known ISP" in the IPv6 ISP qualification
>         section is too vague and does not give ARIN staff sufficient
>         guidance for evaluating qualifications.  This text defines
>         "existing, ISP" in a precise manner and removes the unnecessary
>         and ambiguous word "known".
>         It has come to the author's attention that several organizations
>         have been refused IPv6 ISP allocations because they were not
>         considered an existing, known ISP.  At least one of these
>         organizations has a /18 worth of IPv4 space reallocated to them
>         by various upstream ISPs and over 200 IPv4 customers.  An
>         organization's choice to use provider addresses does not
>         have any affect on whether or not they are in fact an ISP.
>         Address space that has been reallocated (not reassigned)
>         is a good indicato of an ISP as those SWIP templates
>         are only supposed to be used for downstream ISPs.
>         The IPv4 /23 value was selected to match the utilization
>         requirement for the smallest direct IPv4 allocation from ARIN
>         under current policy.
>         The IPv6 /44 value was selected to represent a number
>         of downstream customers comparable to the IPv4 requirements.
>         Updates to IPv6 initial allocation criteria:
>         Section recommends /56 assignments in some cases and
>         /48 assignments in others.  The Initial allocation criteria
>         should reflect the flexibility of these recommendations.
>         An ISP should not have to provide an inefficient address
>         plan on their application even though they expect to have
>         over 200 IPv6 customers.
> Timetable for implementation: Immediate
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