[arin-ppml] Draft Policy 2010-4: Rework of IPv6 allocation criteria

[Member Services]

Draft Policy 2010-4
Rework of IPv6 allocation criteria

On 18 February 2010 the ARIN Advisory Council (AC) selected "Rework of
IPv6 allocation criteria" as a draft policy for adoption discussion on
the PPML and at the Public Policy Meeting in Toronto in April.

The draft was developed by the AC from policy proposal "101. Multihomed
initial allocation criteria". Per the Policy Development Process the AC
submitted text to ARIN for a staff and legal assessment prior to its
selection as a draft policy. Below the draft policy is the ARIN
staff and legal assessment, followed by the text that was submitted by
the AC.

Draft Policy 2010-4 is below and can be found at:
https://www.arin.net/policy/proposals/2010_4.htm

You are encouraged to discuss Draft Policy 2010-4 on the PPML prior to
the April Public Policy Meeting. Both the discussion on the list and
at the meeting will be used by the ARIN Advisory Council to determine
the community consensus for adopting this as policy.

The ARIN Policy Development Process can be found at:
https://www.arin.net/policy/pdp.html

Draft Policies and Proposals under discussion can be found at:
https://www.arin.net/policy/proposals/index.html

Regards,

Member Services
American Registry for Internet Numbers (ARIN)


## * ##


Draft Policy 2010-4
Rework of IPv6 allocation criteria

Version/Date: 23 February 2010

Policy statement:

Delete section 6.4.3. Minimum Allocation.

Modify the following sections;

6.5.1 Initial allocations for ISPs and LIRs

6.5.1.1. Initial allocation size

Organizations that meet at least one of the following criteria are
eligible to receive a minimum allocation of /32. Requests for larger
allocations, reasonably justified with supporting documentation, will be
evaluated based on the number of existing users and the extent of the
organization's infrastructure.

6.5.1.2. Criteria for initial allocation to ISPs

Organizations may justify an initial allocation for the purpose of
assigning addresses to other organizations or customers that it will
provide IPv6 Internet connectivity to, with an intent to provide global
reachability for the allocation within 12 months, by meeting one of the
following additional criteria:

a. Having a previously justified IPv4 ISP allocation from ARIN or one of
its predecessor registries, or;

b. Currently being IPv6 Multihomed or immediately becoming IPv6
Multihomed and using an assigned valid global AS number, or;

c. By providing a reasonable plan detailing assignments to other
organizations or customers for one, two and five year periods, with a
minimum of 50 assignments within 5 years.

6.5.1.3. Criteria for initial allocation to other LIRs

Organizations may justify an initial allocation for the purpose of
assigning addresses to other organizations or customers that it will
provide IPv6 based network connectivity services to, not necessarily
Internet connected, by meeting one of the following additional criteria:

a. Having a previously justified IPv4 ISP allocation from ARIN or one of
its predecessor registries, or;

b. By providing a reasonable technical justification, indicating why an
allocation is necessary, including the intended purposes for the
allocation, and describing the network infrastructure the allocation
will be used to support. Justification must include a plan detailing
assignments to other organizations or customers for one, two and five
year periods, with a minimum of 50 assignments within 5 years.

Rationale:

This proposal provides a complete rework of the IPv6 allocation criteria
while maintaining many of the basic concepts contained in the current
policies. The order of the subsections of 6.5.1 are rearranged moving
the initial allocation size to 6.5.1.1. This will facilitate adding
future criteria without additional renumbering the current policies.

The initial allocation criteria include the following general concepts:

• The need for an allocation is only justified by the need to assign
resource to customers, either internal or external.
• When the need to provide Internet connectivity is use to justify
resources it is implied the resources should be advertised to the
Internet, within some reasonable time frame after they are received.
• IPv4 resources may be use to justify the need for IPv6 resources.
• An ISP may justify independent resource by being Multihomed or
planning to assign IPv6 resource to some minimum number of customers.
• It should be possible to justify an IPv6 allocation for more than just
classical ISPs, such as non-connected networks or other types of LIRs.
But additional justification should be required, describing the purpose
and network infrastructure the allocation will be supporting.

Finally, section 6.4.3 Minimum Allocation, is deleted as it is
incomplete and redundant anyway.

Timetable for implementation: immediate


#####


STAFF ASSESSMENT

Proposal:  Rework of IPv6 allocation criteria

Proposal Version (Date): 5 Jan 2010

Date of Assessment:  12 Feb 2010


1. Proposal Summary (Staff Understanding)

ARIN staff understands this policy replaces existing IPv6 Allocation
Policy text with new, relaxed criteria in which an ISP must qualify for
one out of the three qualifying criteria; have an existing IPv4
allocation OR be multi-home OR have a detailed plan for assigning
address space to 50 customers within 5 years.  It introduces a separate
category for a LIR, which is defined as an organization that provides
IPv6 assignments to at least 50 customers, but not necessarily for the
purposes of providing internet transit.

2. Comments

A.	ARIN Staff Comments

•	This policy provides very clear direction for ISPs requesting IPv6
address space stating that they must “assign addresses to other
organizations or customers that it will provide IPv6 Internet
connectivity to, with an intent to provide global reachability for the
allocation within 12 months”.  This distinction should help clarify the
role of the ISP in relation to this policy.
•	Since 6.5.1.3b does not specify whether “other organizations or
customers” must be external, it seems likely that this policy will open
up allocation policy to enterprise customers (who presently receive
assignments under the End-user policies). Currently the larger
enterprise businesses we see typically define their operating divisions
and departments as 'customers'.
•	The new ISP and LIR qualification criteria lower the bar to receiving
a /32, which should significantly increase the number of allocations
ARIN makes each year.
•	6.5.1.3 states that a LIR can qualify for an allocation if it will be
“assigning addresses to other organizations or customers that it will
provide IPv6 based network connectivity services to, not necessarily
Internet connected”.  The words “network based connectivity services”
are somewhat confusing. Staff interprets this to mean that a LIR will
not necessarily be providing Internet connectivity to its customers, but
we are seeking clarification on this point.


B.	ARIN General Counsel

“This proposal poses no significant legal issues.”

3. Resource Impact

This policy would have minimal resource impact.  It is estimated that
implementation would occur within 3 months after ratification by the
ARIN Board of Trustees. The following would be needed in order to implement:

•	Changes to guidelines
•	May require new template
•	Staff training


4. Proposal Text

Delete section 6.4.3. Minimum Allocation.
Modify the following sections;
6.5.1 Initial allocations for ISPs and LIRs
6.5.1.1. Initial allocation size
Organizations that meet at least one of the following criteria are
eligible to receive a minimum allocation of /32. Requests for larger
allocations, reasonably justified with supporting documentation, will be
evaluated based on the number of existing users and the extent of the
organization's infrastructure.
6.5.1.2. Criteria for initial allocation to ISPs
Organizations may justify an initial allocation for the purpose of
assigning addresses to other organizations or customers that it will
provide IPv6 Internet connectivity to, with an intent to provide global
reachability for the allocation within 12 months, by meeting one of the
following additional criteria:
a. Having a previously justified IPv4 ISP allocation from ARIN or one of
its predecessor registries, or;
b. Currently being IPv6 Multihomed or immediately becoming IPv6
Multihomed and using an assigned valid global AS number, or;
c. By providing a reasonable plan detailing assignments to other
organizations or customers for one, two and five year periods, with a
minimum of 50 assignments within 5 years.
6.5.1.3. Criteria for initial allocation to other LIRs
Organizations may justify an initial allocation for the purpose of
assigning addresses to other organizations or customers that it will
provide IPv6 based network connectivity services to, not necessarily
Internet connected, by meeting one of the following additional criteria:
a. Having a previously justified IPv4 ISP allocation from ARIN or one of
its predecessor registries, or;
b. By providing a reasonable technical justification, indicating why an
allocation is necessary, including the intended purposes for the
allocation, and describing the network infrastructure the allocation
will be used to support. Justification must include a plan detailing
assignments to other organizations or customers for one, two and five
year periods, with a minimum of 50 assignments within 5 years.


Rationale:
This proposal provides a complete rework of the IPv6 allocation criteria
while maintaining many of the basic concepts contained in the current
policies. The order of the subsections of 6.5.1 are rearranged moving
the initial allocation size to 6.5.1.1. This will facilitate adding
future criteria without additional renumbering the current policies.
The initial allocation criteria include the following general concepts;
•	The need for an allocation is only justified by the need to assign
resource to customers, either internal or external.
•	When the need to provide Internet connectivity is use to justify
resources it is implied the resources should be advertised to the
Internet, within some reasonable time frame after they are received.
•	IPv4 resources may be use to justify the need for IPv6 resources.
•	An ISP may justify independent resource by being Multihomed or
planning to assign IPv6 resource to some minimum number of customers.
•	It should be possible to justify an IPv6 allocation for more than just
classical ISPs, such as non-connected networks or other types of LIRs.
But additional justification should be required, describing the purpose
and network infrastructure the allocation will be supporting.

Finally, section 6.4.3 Minimum Allocation, is deleted as it is
incomplete and redundant anyway.