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

[John Curran]

On Apr 6, 2013, at 10:14 PM, Matthew Kaufman <matthew at matthew.at> wrote:

> Worse, we're creating a messy IPv6 situation downstream... as Owen points out, this type of financial pressure towards false conservation is going to give us things like /64-per-household instead of something sensible that lets the thermostat be on a different subnet than the Xbox.

Matthew - 
 
The current fee schedule reads as follows:

   IPV6 ANNUAL FEES (NOTE: FEE WAIVERS IN EFFECT), EFFECTIVE UNTIL 30 JUNE 2013
   Size Category   Fee (US Dollars)	Block Size
   Small           $2,250       /40 to /32
   Medium          $4,500       /31 to /30

   There is 25% IPv6 fee waiver in effect (this started out at 100% and
   was to be phased out over the last 4 years, although it was extended
   at the 25% discount level for this year to carry us into the Revised
   Fee schedule.)

So, any ISP using IPv6 under _today's_ fee schedule has a minimum annual 
fee of $1687 per year [$2250 * 75%] and that covers an allocation up to 
/32 of IPv6.  Unless we continue with the Revised Fee schedule, this is
effectively a minimum annual cost for any ISP making use of IPv6.

If we want to lower that cost of using IPv6 for smaller organizations, 
we need to find some manner to distinguish these smaller ISPs from all 
ISPs, and this is typically done through the total address block holdings.

At this point, ARIN can sustain some number of smaller ISPs having lower 
fees, and the Revised Fee schedule supports an ISP with no more than /20 
of IPv4 space and /36 of IPv6 being categorized as "x-small" with annual
fees of $1000/year.  This category makes IPv6 more approachable for these
ISPs but it is indeed at the downside of a smaller IPv6 allocation.  As
you are aware, /36 of IPv6 space would provide for more than 4000 /48 
and _lots_ of /56 assignments (but there would be less in practice due 
to internal hierarchy in assignment management.)

Draft Policy ARIN-2013-3, combined with the Revised Fee schedule as
corrected, would continue this approach of allowing very small ISPs
with no more than /22 of IPv4 to obtain a corresponding IPv6 allocation
of /40 and have annual fees of $500 year in the "xx-small" category.
The downside that you assert with Draft Policy ARIN-2013-3 is that 
"this type of financial pressure towards false conservation is going 
to give us things like/64-per-household instead of something sensible 
that lets the thermostat be on a different subnet than the Xbox."  

Given that any ISP qualifying as xx-small (even with wildly aggressive 
NAT) has no more 1024 customers each with a single IPv4 address, and the 
/40 IPv6 allocation would provide them with the ability to make 65K /56 
assignments to these same customers, it does seem somewhat strange that 
"false conservation" of those 65 thousand potential assignments would 
drive xx-small ISPs to instead make /64 IPv6 customer assignments.  

The community can indicate that it does not support ARIN-2013-3 if the 
resulting "false conservation" is a problem, and then there will be no use 
of the xx-small/$500/yr fee category.  Under the Revised Fee schedule, these 
ISPs would be paying at least $1000/year based on a /36 IPv6 allocation 
(which is still better than today's fees with IPv6 use as noted above.)

It would be good to hear from ISPs who would qualify for the xx-small
$500/year category about the resulting temptation that it poses for 
making smaller IPv6 customer assignments (and how they feel safer with
the /36 IPv6 minimum and corresponding $1000/year annual fee), as they 
are the ones who are most affected by the outcome of this draft policy
consideration.

Thanks!
/John

John Curran
President and CEO
ARIN