[arin-ppml] Recommended Draft Policy ARIN-2015-1: Modification to Criteria for IPv6 Initial End-User Assignments

Tue Sep 1 16:18:42 EDT 2015

I support the policy as written.

> -----Original Message-----
> From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On
> Behalf Of ARIN
> Sent: September 1, 2015 1:21 PM
> To: arin-ppml at arin.net
> Subject: [arin-ppml] Recommended Draft Policy ARIN-2015-1: Modification to
> Criteria for IPv6 Initial End-User Assignments
> 
> ARIN-2015-1 has been revised to show only the proposed addition to the
> policy.
> 
> ARIN-2015-1 is below and can be found at:
> https://www.arin.net/policy/proposals/2015_1.html
> 
> You are encouraged to discuss Draft Policy 2015-1 on the PPML prior to the
> ARIN Public Policy Consultation at ARIN 36 in Montreal in October 2015. 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.
> 
> ARIN-2015-1 is below and can be found at:
> https://www.arin.net/policy/proposals/2015_1.html
> 
> Regards,
> 
> Communications and Member Services
> American Registry for Internet Numbers (ARIN)
> 
> 
> ## * ##
> 
> 
> Recommended Draft Policy ARIN-2015-1
> Modification to Criteria for IPv6 Initial End-User Assignments
> 
> Date: 27 August 2015
> 
> AC's assessment of conformance with the Principles of Internet Number
> Resource Policy:
> 
> ARIN-2015-1 enables fair and impartial number resource administration by
> providing a concrete threshold (13 active sites) under which end-user
> organizations who have a large number of potentially geographically
> dispersed sites, or sites with low subnet and/or user counts, can be
> reasonably assured of receiving IPv6 address space from ARIN. This proposal
> is technically sound, in that it retains reasonable thresholds on obtaining IPv6
> assignments from ARIN in order to support the aggregation of Internet
> number resources in a hierarchical manner to the extent feasible. It has been
> well supported by the community on PPML and at the ARIN PPC at NANOG in
> San Francisco, where nearly everyone agreed that this was a step in the right
> direction. To the extent that some in the community desire even more
> relaxed IPv6 assignment policy, the AC encourages those community
> members to discuss on PPML and/or submit as additional policy proposals
> any further changes they would like to see.
> 
> Problem Statement:
> 
> Current policy for assignment to end users excludes a class of users whose
> costs to renumber would far exceed what current policy is designed to
> mitigate.
> 
> Current measures designed to minimize the economic cost of renumbering
> per NRPM 6.5.8.1 (Initial Assignment Criteria) are:
> 
> c. By having a network that makes active use of a minimum of 2000 IPv6
> addresses within 12 months, or; d. By having a network that makes active use
> of a minimum of 200 /64 subnets within 12 months, or;
> 
> These two measures fail to take into account end users who have a large
> number of potentially geographically dispersed sites, or sites with low subnet
> and/or user counts. The economic costs for this class of end user would likely
> far exceed the costs that 6.5.8.1 c. and d. are designed to mitigate.
> 
> While an end user could possibly apply (and receive an assignment) under
> 6.5.8.1 e. ("By providing a reasonable technical justification indicating why
> IPv6 addresses from an ISP or other LIR are unsuitable"), it fails to provide a
> concrete threshold under which this class of end-user can be reasonably
> assured of receiving address space.
> 
> Without having the reasonable assurance of IPv6 address number resource
> continuity that a direct assignment allows, many smaller enterprises are
> unlikely to adopt IPv6 (currently perceived as an already tenuous proposition
> for most users given current cost/benefit); or are likely to adopt technical
> measures (such as using ULA addressing + NAT66) that are widely held to be
> damaging to the IPv6 Internet.
> 
> Policy Statement:
> 
> Renumber NRPM 6.5.8.1 Initial Assignment Criteria subsection e. to f.
> and and insert a new subsection e. with the following text:
> 
> By having a contiguous network that has a minimum of 13 active sites within
> 12 months, or;
> 
> Comments:
> a. Timetable for implementation: Immediate b. General Comments:
> 
> - The threshold of 13 sites was chosen based on NRPM 6.5.8.2, which
> specifies 13 sites as the minimum number of sites required to receive a
> /40 initial assignment, to attempt to provide a balance between the costs of
> carrying the prefix vs. the costs to the end-user in renumbering.
> 
> - Further constraints were added in that the sites must be in a contiguous
> network, to further attempt to reduce the costs of carrying the prefix
> 
> - By introducing this new threshold, we attempt to restore equivalency of
> number resources for those end-users whose economic costs to renumber
> are equal to that of other end-users who would qualify for a direct
> assignment under 6.5.8.1 c. and d.
> 
> c. Example:
> 
> Example of an end-user who would not qualify under 6.5.8.2 c. or d.:
> 
> - 50 locations (IPVPN) spread across the country/continent
> - 10 staff per location (average; 500 total)
> - 20 devices per location (average; 1000 total)
> - 2 subnets (voice & data) per location (average, 100 total)
> - Not multihomed
> - Currently using RFC1918 IPv4 space + NAT
> 
> This end-user only benefits minimally from IPv6 multihoming as they are
> using an IPVPN, and multihoming provides benefit only for Internet transit,
> not within their IPVPN. As such requiring the end-user to multihome under
> NRPM 6.5.8.2 b. is wasteful.
> 
> This end user currently uses RFC1918 IPv4 address space + a relatively small
> amount of IPv4 GUA + NAT (currently accepted industry practice for IPv4).
> Changing providers involves only renumbering the small amount of
> IPv4 GUA. Forcing the end-user to acquire an IPv4 direct assignment under
> NRPM 6.5.8.2 a. in order to be able to get a direct IPv6 assignment is
> incredibly wasteful of a valuable and limited number resource. It also forces
> the customer occupy more routing table space, as now an IPv4 PI prefix must
> be routed in addition to an IPv6 PI prefix, instead of using IPv4 PA + IPv6 PI
> (where only space for an IPv6 PI prefix is required).
> 
> #####
> 
> ARIN STAFF ASSESSMENT
> 
> Draft Policy ARIN-2015-1
> Modification to Criteria for IPv6 Initial End-User Assignments
> https://www.arin.net/policy/proposals/2015_1.html
> 
> Date of Assessment: June 11, 2015
> 
> ___
> 1. Summary (Staff Understanding)
> This proposal would add a criteria item to 6.5.8.1 (Initial Assignment Criteria).
> Because each of the existing criteria items in that section can independently
> qualify an organization for IPv6 address space from ARIN, this new criteria
> item adds an additional qualification criteria.
> It makes it easier for some organizations to qualify, and does not make it
> more difficult for anyone. In particular, it creates a new criteria point that
> allows any end-user organization large enough to have 13 sites to
> immediately qualify for IPv6 address space from ARIN.
> 
> ___
> 2. Comments
> A. ARIN Staff Comments
> This proposal can be implemented as written. Minimal staff training and
> preparation would be needed to implement this if it were to become policy.
> We see no negative impacts.
> 
> B. ARIN General Counsel – Legal Assessment Counsel sees no material legal
> issues in this policy.
> 
> ___
> 3. Resource Impact
> This policy would require minimal staff training and preparation. We see no
> negative impacts.
> 
> ___
> 4. Proposal / Draft Policy Text Assessed
> 
> Draft Policy ARIN-2015-1
> Modification to Criteria for IPv6 Initial End-User Assignments
> 
> Date: 24 March 2015
> 
> Problem Statement:
> Current policy for assignment to end users excludes a class of users whose
> costs to renumber would far exceed what current policy is designed to
> mitigate.
> 
> Current measures designed to minimize the economic cost of renumbering
> per NRPM 6.5.8.1 (Initial Assignment Criteria) are:
> 
> c. By having a network that makes active use of a minimum of 2000 IPv6
> addresses within 12 months, or; d. By having a network that makes active use
> of a minimum of 200 /64 subnets within 12 months, or;
> 
> These two measures fail to take into account end users who have a large
> number of potentially geographically dispersed sites, or sites with low subnet
> and/or user counts. The economic costs for this class of end user would likely
> far exceed the costs that 6.5.8.1 c. and d. are designed to mitigate.
> 
> While an end user could possibly apply (and receive an assignment) under
> 6.5.8.1 e. ("By providing a reasonable technical justification indicating why
> IPv6 addresses from an ISP or other LIR are unsuitable"), it fails to provide a
> concrete threshold under which this class of end-user can be reasonably
> assured of receiving address space.
> 
> Without having the reasonable assurance of IPv6 address number resource
> continuity that a direct assignment allows, many smaller enterprises are
> unlikely to adopt IPv6 (currently perceived as an already tenuous proposition
> for most users given current cost/benefit); or are likely to adopt technical
> measures (such as using ULA addressing + NAT66) that are widely held to be
> damaging to the IPv6 Internet.
> 
> Policy Statement:
> 
> Replace the contents of NRPM 6.5.8.1 with:
> 
> 6.5.8.1. Initial Assignment Criteria
> 
> Organizations may justify an initial assignment for addressing devices directly
> attached to their own network infrastructure, with an intent for the
> addresses to begin operational use within 12 months, by meeting one of the
> following criteria:
> 
> a. Having a previously justified IPv4 end-user assignment from ARIN or one
> of its predecessor registries, or; b. Currently being IPv6 Multihomed or
> immediately becoming IPv6 Multihomed and using an assigned valid global
> AS number, or; c. By having a network that makes active use of a minimum of
> 2000 IPv6 addresses within 12 months, or; d. By having a network that makes
> active use of a minimum of 200 /64 subnets within 12 months, or; e. By
> having a contiguous network that has a minimum of 13 active sites within 12
> months, or; f. By providing a reasonable technical justification indicating why
> IPv6 addresses from an ISP or other LIR are unsuitable.
> 
> Examples of justifications for why addresses from an ISP or other LIR may be
> unsuitable include, but are not limited to:
> 
> > An organization that operates infrastructure critical to life safety
> or the functioning of society can justify the need for an assignment based on
> the fact that renumbering would have a broader than expected impact than
> simply the number of hosts directly involved. These would
> include: hospitals, fire fighting, police, emergency response, power or energy
> distribution, water or waste treatment, traffic management and control, etc.
> > Regardless of the number of hosts directly involved, an organization
> can justify the need for an assignment if renumbering would affect 2000 or
> more individuals either internal or external to the organization.
> > An organization with a network not connected to the Internet can
> justify the need for an assignment by documenting a need for guaranteed
> uniqueness, beyond the statistical uniqueness provided by ULA (see RFC
> 4193).
> > An organization with a network not connected to the Internet, such as
> a VPN overlay network, can justify the need for an assignment if they require
> authoritative delegation of reverse DNS.
> 
> Comments:
> a. Timetable for implementation: Immediate b. General Comments:
> 
> - Changes to NRPM 6.5.8.1 are to renumber subsection e. to f. and and insert
> a new subsection e. with the following text:
> 
> "By having a contiguous network that has a minimum of 13 active sites within
> 12 months, or;
> 
> - The threshold of 13 sites was chosen based on NRPM 6.5.8.2, which
> specifies 13 sites as the minimum number of sites required to receive a
> /40 initial assignment, to attempt to provide a balance between the costs of
> carrying the prefix vs. the costs to the end-user in renumbering.
> 
> - Further constraints were added in that the sites must be in a contiguous
> network, to further attempt to reduce the costs of carrying the prefix
> 
> - By introducing this new threshold, we attempt to restore equivalency of
> number resources for those end-users whose economic costs to renumber
> are equal to that of other end-users who would qualify for a direct
> assignment under 6.5.8.1 c. and d.
> 
> c. Example:
> 
> Example of an end-user who would not qualify under 6.5.8.2 c. or d.:
> 
> - 50 locations (IPVPN) spread across the country/continent
> - 10 staff per location (average; 500 total)
> - 20 devices per location (average; 1000 total)
> - 2 subnets (voice & data) per location (average, 100 total)
> - Not multihomed
> - Currently using RFC1918 IPv4 space + NAT
> 
> This end-user only benefits minimally from IPv6 multihoming as they are
> using an IPVPN, and multihoming provides benefit only for Internet transit,
> not within their IPVPN. As such requiring the end-user to multihome under
> NRPM 6.5.8.2 b. is wasteful.
> 
> This end user currently uses RFC1918 IPv4 address space + a relatively small
> amount of IPv4 GUA + NAT (currently accepted industry practice for IPv4).
> Changing providers involves only renumbering the small amount of
> IPv4 GUA. Forcing the end-user to acquire an IPv4 direct assignment under
> NRPM 6.5.8.2 a. in order to be able to get a direct IPv6 assignment is
> incredibly wasteful of a valuable and limited number resource. It also forces
> the customer occupy more routing table space, as now an IPv4 PI prefix must
> be routed in addition to an IPv6 PI prefix, instead of using IPv4 PA + IPv6 PI
> (where only space for an IPv6 PI prefix is required).
> _______________________________________________
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