[arin-ppml] Simplified IPv6 policy

[Scott Leibrand]

On 12/23/2009 12:43 PM, Owen DeLong wrote:
>>
>>
>>
>> Replacement text:
>>
>> 1.1.  Number resources not to be considered property
>>
>> It is contrary to the goals of this document and is not in the 
>> interests of the Internet community as a whole for address space to 
>> be considered freehold property.
>>
>> The policies in this document are based upon the understanding that 
>> globally-unique number resources are licensed for use rather than 
>> owned. Specifically, IP addresses and ASNs will be allocated and 
>> assigned on a license basis, with licenses subject to renewal on a 
>> periodic basis. The granting of a license is subject to specific 
>> conditions applied at the start or renewal of the license, as 
>> definied in the ARIN Registration Services Agreement.
>>
>> Note that when a license is renewed, the new license will be 
>> evaluated under and governed by the applicable number resource 
>> policies in place at the time of renewal, which may differ from the 
>> policy in place at the time of the original allocation or assignment.
>>
> I do not like the use of the term license, and, I think Steve Ryan 
> would likely take issue with it as well.
>
> Personally, I think that the first paragraph is sufficient.  The 
> remaining two paragraphs simply restate
> (badly) what is in the RSA and do not need to be part of the NRPM.

I already deleted a couple extraneous paragraphs, and would be happy to 
trim further, once we've gotten to the point of getting a Legal review 
if not before.  In any event, this is all in the existing NRPM already.

>> ARIN is not concerned about which address size an LIR/ISP actually 
>> assigns. Accordingly, ARIN will not request the detailed information 
>> on IPv6 user networks as in IPv4, except for the purpose of measuring 
>> utilization as defined in this document.
>>
> This paragraph should be deleted.  ARIN is concerned if you want to 
> issue more than a /48 to an end site and should
> be able to review such large assignments.

Ok.  I like deleting unnecessary text.  :-)

>> 6.2.3. Allocations and assignments from ARIN
>>
>> 6.2.3.1  Goals
>> To balance the goals of Aggregation, Conservation, Fairness, and 
>> Minimized Overhead, ARIN normally makes allocations only in the 
>> discrete sizes of /48, /40, /32, /28, or /24 or larger.  Each 
>> organization or discrete network may qualify for one allocation or 
>> assignment of each size, and must pay fees according to ARIN's <a 
>> href="https://www.arin.net/fees/fee_schedule.html">fee schedule</a>
>> for each size assigned.
>>
> The first "makes allocations" should either be "issues IPv6 addresses" 
> or "makes allocations or assignments".
> The last "assigned" should either be "issued" or "assigned or allocated".

Agreed.

>
>> 6.2.3.2  X-Small (/48)
>> To qualify for a /48 allocation or assignment, an organization must:
>>    * Serve at least 500 hosts, if multihomed; or
>>    * Serve at least 1000 hosts; or
>>    * Demonstrate efficient utilization of all direct IPv4 assignments 
>> and allocations, each of which must be covered by any current ARIN 
>> RSA; or
>>    * Be a critical infrastructure provider of the Internet, including 
>> public exchange points, core DNS service providers (e.g. 
>> ICANN-sanctioned root, gTLD, and ccTLD operators) as well as the RIRs 
>> and IANA; or
>>    * Qualify for a Micro-allocations for Internal Infrastructure per 
>> 6.3.3.2.2.
>>
> I would rather see this in the ~100 host range, if multihomed.  I'm 
> fine with 1000 hosts otherwise.
>
> There should not be any IPv4 requirement for getting IPv6 space.  The 
> efficient utilization of IPv4 resources as a determining
> factor for getting IPv6 resources should be removed in my opinion.

Note that this is an "or", so it's just another way to get space.  
Removing it would repeal 2007-21, which I don't think should be done 
until we're much further along in IPv6 deployment.

>
>> 6.2.3.2.1 Critical Infrastructure
>> Organizations qualified as critical infrastructure providers may be 
>> granted multiple /48 allocations in certain situations.  Exchange 
>> point allocations MUST be allocated from specific blocks reserved 
>> only for this purpose. All other micro-allocations WILL be allocated 
>> out of other blocks reserved for micro-allocation purposes. ARIN will 
>> make a list of these blocks publicly available. Exchange point 
>> operators must provide justification for the allocation, including: 
>> connection policy, location, other participants (minimum of two 
>> total), ASN, and contact information. ISPs and other organizations 
>> receiving these micro-allocations will be charged under the ISP fee 
>> schedule, while end-users will be charged under the fee schedule for 
>> end-users. This policy does not preclude exchange point operators 
>> from requesting address space under other policies.
>>
> Why create a separate pool for exchange point allocations?

Cause that's what existing policy does.  I'd be OK with deleting this, 
but didn't see a reason to.

>> 6.2.3.2.2 Micro-allocations for Internal Infrastructure
>> Organizations that currently hold IPv6 allocations may apply for a 
>> /48 micro-allocation for internal infrastructure. Applicant must 
>> provide technical justification indicating why a separate non-routed 
>> block is required. Justification must include why a sub-allocation of 
>> currently held IP space cannot be utilized. Internal infrastructure 
>> allocations must be allocated from specific blocks reserved only for 
>> this purpose.
>>
>> 6.2.3.3  Small (/40)
>> To qualify for a /40 allocation or assignment, an organization must 
>> qualify for two or more /48s.
>>
> This is in direct conflict with the statement at the beginning that an 
> organization can only qualify for one block of each size. This problem 
> persists in your subsequent requirements to qualify for larger blocks 
> as well.

The idea here is that if you qualify for a /48, you get one.  If you 
qualify for more than one /48, you can't have a second, but you can have 
a /40 instead.  I'd welcome suggestions for better ways to say that.

>> 6.3. Registration
>>
>> When an organization holding an IPv6 address allocation makes IPv6 
>> address assignments, it must register assignment information in a 
>> database, accessible by RIRs as appropriate (information registered 
>> by ARIN may be replaced by a distributed database for registering 
>> address management information in future). Information is registered 
>> in units of assigned /56 networks. When more than a /56 is assigned 
>> to an organization, the assigning organization is responsible for 
>> ensuring that the address space is registered in an ARIN database.
>>
> This is a major departure from current whois policy and I do not think 
> that an overhaul of whois
> should be packaged with a major change to IPv6 policy.  Please restore 
> the current SWIP/rhwois
> requirements for publishing the data.
>
> I'm fine with registering IPv6 data in terms of /56s, but, what about 
> cases where customers are
> issued /64s? There are 256 /64 customers in a single /56.

This isn't a departure, this is a copy and paste (with minor edits) from 
existing policy (https://www.arin.net/policy/nrpm.html#six55)
>
>> IRs shall maintain systems and practices that protect the security of 
>> personal and commercial information that is used in request 
>> evaluation, but which is not required for public registration.
>>
> I don't think this needs to be in the NRPM.  I think that it is 
> already addressed in other areas.

It's in the current NRPM, but I'll be happy to remove it unless anyone 
thinks it needs to stay.  (Like much of NRPM section 6, the globally 
coordinated policy restates a lot of policy from elsewhere, and some 
operational practice stuff as well.)

>> 6.3.1. Residential Customer Privacy (2003-3)
>>
>> To maintain the privacy of their residential customers, an 
>> organization with downstream residential customers may substitute 
>> that organization's name for the customer's name, e.g. 'Private 
>> Customer - XYZ Network', and the customer's street address may read 
>> 'Private Residence'. Each private downstream residential reassignment 
>> must have accurate upstream Abuse and Technical POCs visible on the 
>> WHOIS record for that block.
>>
>> 6.3.2. Reverse lookup
>>
>> When ARIN delegates IPv6 address space to an organization, it also 
>> delegates the responsibility to manage the reverse lookup zone that 
>> corresponds to the allocated IPv6 address space. Each organization 
>> should properly manage its reverse lookup zone. When making an 
>> address assignment, the organization must delegate to an assignee 
>> organization, upon request, the responsibility to manage the reverse 
>> lookup zone that corresponds to the assigned address.
>>
> I think this needs word-smithing, but, I'm at a loss to come up with 
> something better at the moment.

Well, this too is existing NRPM text, so we don't have to fix it right now.

Thanks for the feedback.  I'd also like to hear anyone's general 
thoughts on the proposal as a whole, if you've formed an opinion on it yet.

Thanks,
Scott
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