[arin-ppml] Draft Policy 2012-2: IPv6 Subsequent Allocations Utilization Requirement

[Heather Schiller]

I am working on final text and prepping slides for the meeting in a
few weeks.  Does anyone have any feedback on this policy or on the
staff feedback?

The goal is to be able to get a subsequent allocation when, partway
through deploying, you realize you don't have enough room to subnet.
I would really like to hear from people who have encountered this
problem and what their assignment vs subnet utilization was.  I don't
expect the "1* customer or infrastructure allocation or assignment" to
hold -- I would like to hear what reasonable number 1 could be
replaced with.  10? 20? 50?

Should there be some bounds that could be put around what a reasonable
subnet size is, so that you can't game the process by creating large,
empty subnets?  Or is subnet size too unique to the network?

 Thanks,
--Heather

Proposal text:
Modify 6.5.3.b as follows:
An LIR may request a subsequent allocation when they can show utilization
of:
75% or more of their total address space
or
more than 90% of any serving site
or
when 75% of the aggregate has been subnetted, and each subnet contains
at least 1* customer or infrastructure allocation or assignment
( *1 can be replaced here with any reasonable number)



On Sat, Feb 25, 2012 at 10:10 PM, ARIN <info at arin.net> wrote:
> Correction. Earlier post did not use updated policy text.
>
> Draft Policy ARIN-2012-2
> IPv6 Subsequent Allocations Utilization Requirement
>
> On 16 February 2012 the ARIN Advisory Council (AC) selected "Clarifying
> requirements for IPv4 transfers" as a  draft policy for adoption discussion
> on the PPML and at the Public Policy Meeting in Vancouver in April.
>
> The draft was developed by the AC from policy proposal "ARIN-prop-159 IPv6
> Subsequent Allocations Utilization Requirement." 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 ARIN-2012-2 is below and can be found at:
> https://www.arin.net/policy/proposals/2012_2.html
>
> You are encouraged to discuss Draft Policy 2012-2 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 ARIN-2012-2
> IPv6 Subsequent Allocations Utilization Requirement
>
> Date: 22 February 2012
>
> Policy statement:
>
> Proposal text:
> Modify 6.5.3.b as follows:
> An LIR may request a subsequent allocation when they can show utilization
> of:
> 75% or more of their total address space
>  or
> more than 90% of any serving site
>  or
> when 75% of the aggregate has been subnetted, and each subnet contains at
> least 1* customer or infrastructure allocation or assignment
>  ( *1 can be replaced here with any reasonable number)
>
> Original Rationale:
>
> If you are executing to a long term plan, you should be able to continue to
> execute on your approved allocation and assignment plan regardless of the
> number of regions/groupings you originally planned for. We want to promote
> tie downs on nibbles and long term planning.
>
> Timetable for implementation: Immediately
>
>
> ##########
>
>
> ARIN Staff and Legal Assessment
>
> Draft Policy:  PP 159 “IPv6 Subsequent Allocations Utilization Requirement”
> Date of Assessment:  15 Feb 2012
> 1.  Proposal Summary (Staff Understanding)
>
> The intent of this proposal is to allow an additional way for ISP's that
> have already begun using their IPv6 space but who may not have sufficiently
> planned for longer term growth, to receive an additional allocation.   This
> policy would allow an organization to qualify for an additional IPv6
> allocation if they can show that 75% of their IPv6 address space as a whole
> is subnetted, provided that each subnet has at least 1 customer or
> infrastructure assignment/allocation.
>
> 2. Staff Comments:
>
> A. ARIN Staff Comments:
>
> If this policy were to be implemented exactly as written, ARIN staff would
> approve an additional IPv6 allocation as long as a network had subnetted at
> least 75% of their IPv6 allocation, with at least one customer or internal
> assignment/allocation in each subnet.  ARIN would not evaluate subnet size;
> as long as any portion of a subnet is used, then that subnet would be
> considered to be fully used, regardless of its size.  Effectively, this
> allows an operator to qualify for IPv6 addresses any time they want, because
> it's trivial to subnet out 75% of an allocation(s) and use at least a tiny
> portion of each, and may not encourage conservation of IPv6 address space.
>
> If the author's intent is to allow operators to make reasonable decisions
> about their IPv6 deployment, another option would be to simplify the IPv6
> additional allocation policy to allow an operator to qualify for more IPv6
> addresses when they can show a need for them.
>
> Alternatively, if the author's intent is to have ARIN staff evaluate whether
> those decisions are reasonable, then specific criteria needs to be laid out
> to give staff guidance as to how we do that (e.g. block size, timeframes,
> etc.).
> The author's original proposal rationale stated that the expectation would
> be for ARIN to use its discretion to weed out such requests, but there is no
> policy basis for doing so.  Nothing in this text gives staff any basis for
> rejecting any subnet size, regardless of how reasonable we think it is.
>  If the author wants ARIN to review requests to determine if technically
> reasonable, than some criteria or guidance must be provided within the
> policy text.
>
> B. ARIN General Counsel –
>
> This policy does not create significant legal issues.
>
> 3. Resource Impact
>
> This policy would have minimal resource impact from an implementation
> aspect.  It is estimated that implementation could occur within 3 months
> after ratification by the ARIN Board of Trustees.
>
> The following would be needed in order to implement:
>
> Guidelines and procedures need to be updated
> Staff training
>
> Proposal text:
> Modify 6.5.3.b as follows:
> An LIR may request a subsequent allocation when they can show utilization
> of:
> 75% or more of their total address space
>  or
> more than 90% of any serving site
>  or
> when 75% of the aggregate has been subnetted, and each subnet contains at
> least 1* customer or infrastructure allocation or assignment
>  ( *1 can be replaced here with any reasonable number)
>
> Original Rationale:
>
> If you are executing to a long term plan, you should be able to continue to
> execute on your approved allocation and assignment plan regardless of the
> number of regions/groupings you originally planned for. We want to promote
> tie downs on nibbles and long term planning.
>
>
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