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

[theone at uneedus.com]

As for discussion of SWIP for /48's, some have suggested since these are 
the recommended minimum assignment for an end site, /48 should not trigger 
SWIP unless independently routed.  Others believe all /48's be SWIP'ed. 
Thus the two main ideas for this proposal currently are:

1) SWIP all independently routed (in the GRT) networks regardless of size 
but in actual fact they must be at least a /48 to be in the GRT, and all 
other assignments greater than a /48.  This is the "b)" language using /47 
from the other day.

2) SWIP every /48 regardless of routing, smaller are exempt.  This is the 
"/48 or more" language. Since the standard site size is /48, this catches 
a lot of small sites that are not independently routed but avoids setting 
the policy based on routing.  If this is chosen many ISP's are likely to 
choose giving out /52 or less instead of /48's.  As pointed out by others, 
a major cable ISP in the US already gives out only a /60 with their prefix 
delegation server.  Although like the mobile networks, they do have a 
current valid argument against SWIP, since these are not "static".

We are in agreement that anything smaller than /48 including /56 should 
not require SWIP. I would be happy with either result, but am biased 
toward not requiring SWIP for /48 blocks not independently routed.

The inequality between v4 and v6 is why I drafted this proposal.  The bus 
network I speak of operates today using a single static v4 address per 
bus. The wireless provider will no longer provide static v4 after the 
contract ends next year. There are currently two RFC1918 v4 subnets on 
each bus, one for administrative, and one for wifi. and each device on the 
bus is accessable from headquarters via forwarded ports from the bus 
router's static v4. There has never been a SWIP requirement for having a 
single static v4 address.

Now that we want to change the bus administrative network to v6 for lack 
of v4 static assignments from the contract wireless provider, we run into 
the ARIN 100% SWIP registration requirement of /64 or more in NRPM 
6.5.5.1. as v6 does not use NAT.  The policy of /64 or more is what I seek 
to change, to allow smaller v6 networks, like these busses to avoid a SWIP 
requirement.  Switching the same size network with the same number of 
hosts from v4 to v6 should not change the SWIP requirement, but current 
policy does. This is where the debate is, where to draw that line.

The thing to remember is that currently a /48, according to the 2.15 of 
the NRPM is the recommended value for every end site, residential or 
commercial.  Current ARIN policy would allow the transit agency to receive 
a /36 and assign each bus a /48. I have suggested they instead obtain a 
single end user /48 from either ARIN or a /48 assignment from a /32 block 
already controlled by state government for their bus use to avoid 
renumbering during contract provider changes, and use a /60 on each bus. 
Either saves money over getting a /36 from ARIN.

As far as public disclosure of CPNI, the size of an organization does not 
matter.  In the example discussed here of that 69.0.0.0/29 block we have 
been talking of, unless AT&T has written permission from that customer, 
they have committed a CPNI violation by simply publishing the name and 
address of that customer in SWIP, and AT&T could in theory be fined for 
that disclosure, even though ARIN policy requires the information be 
disclosed in SWIP. If the FCC in fact takes action is a different story. 
The usefulness of this SWIP record is also in doubt, as staff at that 
location, even if contacted might be unable to deal with an "owned" box.
It is better to have tech records with the contact info of actual 
technicians.

Albert Erdmann
Network Administrator
Paradise On Line Inc.

On Thu, 20 Jul 2017, Chris James wrote:

> Well I think in the bus example you would swip to the overall authority.
> But seriously this conversation has gone in so many different directions do
> any of us remember the original point?
>
> My vote as it applies to v6: Non-residential allocations of greater than or
> equal to a /48.
>
> If you as an ISP choose to allocate a /48 to a residential customer - then
> have fun. But this does not affect the purpose of the policy as most use it
> these days which is abuse management. Also as I understand it, there is an
> exception to the CPNI as it applies to business customers as long as they
> have an account manager and adequate language in the contract. How many of
> the smaller ISPs have a customer deserving of a /48 or better that does not
> have a larger account or spend? If a customer requests a large enough block
> from us, regardless of v4 vs v6, they agree via email/ticketing/contract
> that their business information will be made public. This is not difficult
> to put in your signed agreements with your business customers thus making
> the CPNI argument invalid.
>
> -Chris
>
>
>
> On Thu, Jul 20, 2017 at 2:28 PM, <hostmaster at uneedus.com> wrote:
>
>> My transit bus example is another example of SWIP difficulty.  Very hard
>> to provide a street address to SWIP a bus when it is mobile 16 hours a day.
>>
>> Current policy says SWIP every /64 or more, which is every network in v6.
>>
>> I did a check here, and in v4, only 1% of customers have more than 8 ip's,
>> and these customers are colocation customers who have a bunch of SSL
>> sites.  These are grandfathered. New customers are told to use 1 IPv4
>> address and SNI or better yet, IPv6, as we do not have the money to buy
>> more V4.  We would rather use our v4 inventory for access customers.
>>
>> Yes, it is just a few pieces of information for SWIP.  However, we do not
>> have clerical staff to do it, because except for the SSL colocates, there
>> never has been v4 SWIP's required here. Why should the policy state that
>> just because we give each customer an assignment of v6, we must SWIP that
>> same small customer that did not require SWIP in v4? (Welcome to IPv6, now
>> fill out this form.....) Also noted is that the SWIP registration details
>> without written permission might get us in trouble with the FCC over CPNI.
>> As a WISP that has licensed microwave links, we do pay attention to Uncle
>> Charlie.
>>
>> Albert Erdmann
>> Network Administrator
>> Paradise On Line Inc.
>>
>> On Thu, 20 Jul 2017, Chris James wrote:
>>
>> @Paul - The API key is to email it.
>>>
>>> @Owen - Very difficult when you have dynamic ranges, and vps/container
>>> platforms spanning tens of thousands of instances across these dynamic
>>> ranges.
>>>
>>>
>>> On Thu, Jul 20, 2017 at 1:51 PM, Paul McNary <pmcnary at cameron.net> wrote:
>>>
>>> Owen
>>>>
>>>> The reassignment policy page says IPv6 has to be done vi API.
>>>> Is that something else that is incorrect on the web site?
>>>>
>>>> Paul
>>>>
>>>>
>>>> On 7/20/2017 3:16 PM, Owen DeLong wrote:
>>>>
>>>> How can it be overly difficult to fill out an email template with your
>>>>> customers’
>>>>> Name, Address, Phone Number?
>>>>>
>>>>> Really?
>>>>>
>>>>> Owen
>>>>>
>>>>> On Jul 19, 2017, at 23:48 , Pallieter Koopmans <Pallieter at pallieter.org
>>>>>>
>>>>>
>>>>>> wrote:
>>>>>>
>>>>>> Hello,
>>>>>>
>>>>>> ARIN could quantify and require rules for when to SWIP, but in the
>>>>>> end, there are going to be exceptions needed if the rules are to be
>>>>>> strictly followed. Many will not separately SWIP a separately routed
>>>>>> sub-block if it is too difficult or pointless to gather and share that
>>>>>> data back upstream to ARIN.
>>>>>>
>>>>>> Thus a more fuzzy rule to require a best-effort and to add a
>>>>>> rule-based reason (preferably both a carrot and a stick) for block
>>>>>> owners to do their best to provide (only) useful data. In order to do
>>>>>> that, one needs to look back at why that data is needed. For a block
>>>>>> owner to assign the SWIP on a sub-block, he basically delegates tech
>>>>>> and abuse contact requests down to those that are probably more likely
>>>>>> to be able to actually act on the tech/abuse requests (and thus reduce
>>>>>> request-handling workload higher up and overall). But for that to
>>>>>> work, those tech/abuse contact requests need to be actually handled,
>>>>>> otherwise, it is better to leave them with the block owner.
>>>>>>
>>>>>> In the end, the contact details should be as close to the "person"
>>>>>> that is actually capable to both handle (think: volume/languages/etc)
>>>>>> and act (think: authority) on the tech/abuse requests.
>>>>>>
>>>>>> eBrain
>>>>>> Innovative Internet Ideas
>>>>>>
>>>>>> Pallieter Koopmans
>>>>>> Managing Director
>>>>>>
>>>>>> +31-6-3400-3800 (mon-sat 9-22 CET)
>>>>>> Skype: PallieterKoopmans
>>>>>> _______________________________________________
>>>>>> PPML
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> E-mails are not secure and cannot be guaranteed to be error free as they
> can be intercepted, amended, or contain viruses. Anyone who communicates
> with us by e-mail is deemed to have accepted these risks. This company is
> not responsible for errors or omissions in this message and denies any
> responsibility for any damage arising from the use of e-mail. Any opinion
> and other statement contained in this message and any attachment are solely
> those of the author and do not necessarily represent those of the company.
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