[arin-ppml] I Oppose 2010-12: IPv6 Subsequent Allocation

[William Herrin]

>Draft Policy 2010-12
>IPv6 Subsequent Allocation
>
>Version/Date: 20 July 2010
>
>Policy statement:
>
>Modify 6.5.2.1 Subsequent allocation criteria. ADD the following
>sentence: Subsequent allocations will also be considered for
>transitional technologies that cannot be accommodated by,
>nor were accounted for, under the initial allocation.
>
>Justification for the subsequent subnet size will be based
>on the plan and technology provided. Justification for these
>allocations will be reviewed every 3 years and reclaimed
>if it is not in use. Requester will be exempt from returning
>all or a portion of the address space if they can show
>justification for need of this allocation for other existing
>IPv6 addressing requirements be it Native V6 or some
>other V6 network technology.

After careful consideration, I OPPOSE draft policy 2010-12 as written.
Although I agree in principle that subsequent IPv6 allocations at this
early stage should be driven more by recognized addressing needs than
competent consumption of the prior allocation, this particular
proposal needs more work.

2010-12 offers no guidance as to how ARIN staff is supposed to sort
reasonable requests for transition addresses from unreasonable ones.
Indeed, as written a small ISP with a pair of /20 IPv4 allocations
could request a /15 of IPv6 addresses for the purpose of hanging a /48
off each of their IPv4 address using 32-bit mapped 6rd in one /16 with
a second /16 left over for native IPv6. No language in the resulting
ARIN policy would suggest that such an enormous request is in any
respect improper. Indeed, the policy would fail to support ARIN staff
attempting to deny such a request.

Accordingly, I can not support proposal 2010-12 until it has been
rewritten in a form that offers guidance to staff as to how requests
are to be evaluated and places appropriately conservative safeguards
on the both the number of subsequent allocations and the raw count of
allocable addresses.

Regards,
Bill Herrin


-- 
William D. Herrin ................ herrin at dirtside.com  bill at herrin.us
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