[arin-ppml] Draft Policy ARIN-2013-3: Tiny IPv6 Allocations for ISPs

[David Farmer]

Here is the update that I propose to submit tomorrow to meet the 
publication deadline for the Barbados meeting.  I believe it accurately 
reflects the changes discussed so for.  Any comments are appreciated.

Thanks.

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Draft Policy ARIN-2013-3
Tiny IPv6 Allocations for ISPs

Date: 4 April 2013

Problem Statement:

ARIN's fee structure provides a graduated system wherein organizations 
pay based on the amount of number resources they consume.

At the very bottom end of the scale, it is presently not possible to be 
an XX-Small ISP with an IPv6 allocation because the minimum allocation 
size of /36 automatically promotes one into Small ISP status, resulting 
in a doubling of annual fees.

While tiny in absolute terms, the extra costs incurred represent a 
disincentive to IPv6 deployment.

To the author's knowledge, it has never been possible for an LIR/ISP to 
get a /40 allocation direct from ARIN; assignments of /40s have been 
limited to organizations that qualify as end sites or critical 
infrastructure.  It is understood there is an expected correction of the 
xx-small fee category to "/40 or smaller".

Policy statement:

Part 1: In subsection 6.5.2. Initial Allocation Size, insert "or /40" at 
the end of the first sentence of subsection 6.5.2.1 clause (b), and add 
a new clause (g), resulting in;

b. In no case shall an LIR receive smaller than a /32 unless they 
specifically request a /36 or /40.  In no case shall an ISP receive more 
than a /16 initial allocation.

...

g. An LIR that requests a smaller /36 or /40 allocation is entitled to 
expand the allocation to /32 or /36 at any time without additional 
justification.  Such expansions are not considered subsequent 
allocations.  However, any expansions beyond /32 are considered 
subsequent allocations, and must conform to section 6.5.3.

Part 2: Add a new subsection to section 6 "IPv6";

6.12 Reduction or Return

ARIN will accept the return of whole or partial block(s) allowing an 
organization to reduce their holdings as long as:

a. The end result is not an increase in the number of non-contiguous 
blocks held by the organization.

b. Whole blocks are returned to the extent practicable.

c. Partial block(s) retained must conform to applicable policies, as to 
size, alignment, etc…

d. Partial block(s) retained are within a single reserved space or 
aggregate set aside for the organization in the ARIN database to the 
extent practicable.

e. All returned block(s) must not be in use by the organization or its 
customers.

Comments:

The author acknowledges the shortcomings of providing an ISP with an 
allocation of a size that is more traditionally associated with end 
sites. In order to avoid possible bad effects on the routing table, the 
author encourages ARIN staff to adopt the same sparse allocation 
practice as currently exists for larger allocations, perhaps even 
reserving a block as large as the /28 that is reserved for /32s.  Note 
the policy intent of part 1 requires a minimum of a /32 be reserved.

Part 1 brings ARIN's allocation policies in line with the upcoming fee 
schedule, with the addition of an expected correction of the xx-small 
fee category to "/40 or smaller".  This makes it possible to qualify for 
each ISP fee category while holding IPv6 number resources and allows 
expansion up to /32 without justification as a subsequent allocation as 
driven by an ISP's business demands.

Part 2 codifies and expands upon current practice for selective return 
in the manner described by John Curran on the arin-discuss mailing list 
(7-Mar-2013 in 
8DA1853CE466B041B104C1CAEE00B3748F9239EA at CHAXCH01.corp.arin.net ) It 
specifies the generic requirements that should be meet for such returns.

A more practical approach might to figure out a way to apply graduated 
fees to ISPs at the very small end of the scale using some metric other 
than prefix size. Fee schedules are outside of the purview of the Policy 
Development Process; such responsibility lies with the Board should they 
choose to take it up.

Timetable for implementation: Immediate


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David Farmer               Email: farmer at umn.edu
Office of Information Technology
University of Minnesota
2218 University Ave SE     Phone: 1-612-626-0815
Minneapolis, MN 55414-3029  Cell: 1-612-812-9952
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