[arin-ppml] Proposal 159 - Modification - feedback request

[Chris Grundemann]

On Fri, Jan 27, 2012 at 22:07, Heather Schiller
<heather.skanks at gmail.com> wrote:
> Proposal 159 seeks to add an additional way to justify a subsequent
> IPv6 allocation.  Prop 159 would make it possible for ISP's that have
> begun subnetting and allocating their IPv6 space, but who may not have
> planned for enough subnets, or longer term growth, to receive an
> additional allocation.   I have included our suggested modification,
> the text as it currently is in NRPM, and the original prop 159 text
> submitted.   The ARIN staff clarity and understanding statement
> expressed concern about the original text over the potential for
> abuse.  I believe this modification addresses that concern.

Thanks Heather, I think this is a definite improvement on the original
text, without losing the intent. I do have one question, below.

> --Heather Schiller
>
> 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
> atleast 1* customer or infrastructure
> allocation or assignment

Doesn't this third requirement supersede the first requirement? It
appears to me that a network would always meet this third requirement
before meeting the first requirement, and that a network which meets
the first requirement would also meet this third requirement.
Additionally, this still seems ripe for abuse. The existing allocation
policy is already VERY generous. Effectively reducing the subsequent
allocation requirement to one prefix per subnet seems a bit too lax.

For example, let's say my ISP Grund-NET get's a /32. I break that at
the nibble boundary into 16 /36. I assign one to each of 12 regions
(75% of the 16). Now I assign one /48 to a customer in each of those
12 regions. This allows me to go back for a subsequent allocation
under requirement three in your text (AFAICT). Having actually used
just 12 of 65,536 /48s (or a utilization of about .02%) I am now
eligible to double my allocation (correct me if I misunderstand).

Perhaps the third requirement could be re-worded to find a middle
ground (addressing the proposers problem without opening the door
completely)? Maybe something like:

"50% or more of their total address space when at least 90% of the
aggregate has been subnetted, and each subnet contains at least 1*
customer or infrastructure allocation or assignment"

Just some food for thought...
~Chris

> ( *1 can be replaced here with any reasonable number)
>
> Section 6.5.3.b as it stands today:
> b. An LIR which can show utilization of 75% or more of their total
> address space, or more than 90% of any serving site shall be entitled
> to a subsequent allocation.
>
>
> Original Prop 159 text:
> NRPM section 2.16 Utilized (IPv6)
> Add:
>
> 3. Tie down blocks shall be considered fully utilized, for the purpose
> of subsequent allocations, when the first reassignment is made from the
> tie down pool. (e.g. a /36 tie down for customer /48s will be considered
> utilized for subsequent allocations once the first /48 is assigned from
> the /36).
> _______________________________________________
> PPML
> You are receiving this message because you are subscribed to
> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
> Unsubscribe or manage your mailing list subscription at:
> http://lists.arin.net/mailman/listinfo/arin-ppml
> Please contact info at arin.net if you experience any issues.



-- 
@ChrisGrundemann
weblog.chrisgrundemann.com
www.burningwiththebush.com
www.theIPv6experts.net
www.coisoc.org