[arin-ppml] Draft Policy ARIN-2017-5: Equalization of Assignment Registration requirements between IPv4 and IPv6 - updated 2017-07-21

[Paul McNary]

+1


On 7/21/2017 12:34 PM, Scott Leibrand wrote:
> This looks good: I support.
>
> For clarity, so we don't all have to do it, and to help make sure 
> we're not missing anything, here's what the resulting 6.5.5 looks like 
> after modification:
>
> 6.5.5. Registration
>
> ISPs are required to demonstrate efficient use of IP address space 
> allocations by providing appropriate documentation, including but not 
> limited to assignment histories, showing their efficient use.
>
> 6.5.5.1. Reassignment information
>
> Each static IPv6 assignment containing a /47 or more addresses, or 
> sub-delegation of any size that will be individually announced, shall 
> be registered in the WHOIS directory via SWIP or a distributed service 
> which meets the standards set forth in section 3.2. Reassignment 
> registrations shall include each client's organizational information, 
> except where specifically exempted by this policy.
>
> 6.5.5.2. Assignments visible within 7 days
>
> All assignments shall be made visible as required in section 4.2.3.7.1 
> within seven calendar days of assignment.
>
> 6.5.5.3. Residential Subscribers
>
> 6.5.5.3.1. Residential Customer Privacy
>
> To maintain the privacy of their residential customers, an 
> organization with downstream residential customers may substitute that 
> organization's name for the customer's name, e.g. 'Private Customer - 
> XYZ Network', and the customer's street address may read 'Private 
> Residence'. Each private downstream residential reassignment must have 
> accurate upstream Abuse and Technical POCs visible on the WHOIS record 
> for that block.
>
> -Scott
>
> On Fri, Jul 21, 2017 at 9:44 AM, Leif Sawyer <lsawyer at gci.com 
> <mailto:lsawyer at gci.com>> wrote:
>
>     Happy Friday, everybody.
>
>     As promised, here is the latest rewrite of the draft policy below,
>      and it will soon be updated at:
>
>     https://www.arin.net/policy/proposals/2017_5.html
>     <https://www.arin.net/policy/proposals/2017_5.html>
>
>     There are two changes noted in the policy statement: the first of
>     which reflects what seems to be the current
>
>     consensus of the PPML regarding netblock sizing; the second is to
>     strike language that may be read as either restrictive
>
>     or non-operational.
>
>     ----
>
>     Problem Statement:
>
>     Current ARIN policy has different WHOIS directory registration
>     requirements for IPv4 vs IPv6 address assignments.
>
>            IPv4 registration is triggered for an assignment of any
>     address block equal to or greater than a /29 (i.e., eight IPv4
>     addresses).
>
>     In the case of IPv6, registration occurs for an assignment of any
>     block equal to or greater than a /64, which constitutes one entire
>     IPv6 subnet and is the minimum block size for an allocation.
>
>     Accordingly, there is a significant disparity between IPv4 and
>     IPv6 WHOIS registration thresholds in the case of assignments,
>     resulting in more work in the case of IPv6 than is the case for IPv4.
>
>     There is no technical or policy rationale for the disparity, which
>     could serve as a deterrent to more rapid IPv6 adoption.
>
>     The purpose of this proposal is to eliminate the disparity and
>     corresponding adverse consequences.
>
>     Policy statement:
>
>     1) Alter section 6.5.5.1 "Reassignment information" of the NRPM to
>     strike "/64 or more addresses" and change to "/47 or more
>     addresses, or sub-delegation of any size that will be individually
>     announced,"
>
>     and
>
>            2) Alter section 6.5.5.3.1. "Residential Customer Privacy"
>     of the NRPM by deleting the phrase "holding /64 and larger blocks"
>
>     Comments:
>
>     a. Timetable for implementation:
>
>     Policy should be adopted as soon as possible.
>
>     b. Anything else:
>
>         Author Comments:
>
>     IPv6 should not be more burdensome than the equivalent IPv4
>     network size.
>
>     Currently, assignments of /29 or more of IPv4 space (8 addresses)
>     require registration
>
>     The greatest majority of ISP customers who have assignments of
>     IPv4 space are of a single IPv4 address which do not trigger any
>     ARIN registration requirement when using IPv4.
>
>     This is NOT true when these same exact customers use IPv6, as
>     assignments of /64 or more of IPv6 space require registration.
>
>              Beginning with RFC 3177, it has been standard practice to
>     assign a minimum assignment of /64 to every customer end user
>     site, and less is never used.
>
>              This means that ALL IPv6 assignments, including those
>     customers that only use a single IPv4 address must be registered
>     with ARIN if they are given the minimum assignment of /64 of IPv6
>     space.
>
>              This additional effort may prevent ISP's from giving IPv6
>     addresses because of the additional expense of registering those
>     addresses with ARIN, which is not required for IPv4.
>
>     The administrative burden of 100% customer registration of IPv6
>     customers is unreasonable, when such is not required for those
>     customers receiving only IPv4 connections.
>
>     ---
>
>     Leif Sawyer
>
>     Advisory Council
>
>
>     _______________________________________________
>     PPML
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>
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