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

hostmaster at uneedus.com hostmaster at uneedus.com
Sun Jul 23 14:23:06 EDT 2017

Boy, am I learning from this process.  Please let me know if I am not 
defining these terms we are discussing below properly:

Allocation:  Directly receiving a block of IP addresses from ARIN.

Re-Allocation:  Taking part of an Allocation from ARIN, and permitting 
another ISP/LIR to use this block for assignment to their end user 

Assignment:  When the original ARIN blockholder assigns a block from their 
allocation to an end user customer for their use in networks, OR when 
another ISP without an ARIN allocation for the original block 
(re-allocation), assigns a portion of their re-allocation to the end user 

Reassignment:  A superset of all the cases of Assignment, as well as 
all the cases of Re-allocation, which is not currently defined in the 

Ok, now that I have the terms out of the way, lets talk.

There seems to be a current disconnect identified in the policy between 
Re-allocation and assignment because the term "Reassignment" in 6.5.5 is 
not defined.

Many have identified that the minimum unit of assignment should be a /48 
and ARIN policy should not change this fact by putting policies in place 
that would make it more likely that assignments of less than /48 will be 
made by ISPs/LIRs.  Therefore I propose the following amendments to the 
draft to address the issues that have been identified:

Add new section 2.17 as follows:

2.17 Reassignment

The term shall mean all cases where an Internet Registry, as defined in 
section 2.1 assigns or Re-allocates a portion of the addresses received 
from ARIN or another Internet Registry, for the use by end users or 
another Internet Registry.  This term shall include within it the terms 
assignment and Re-allocation.

Amend as follows:

Change "Each static IPv6 assignment" to "Each static IPv6 reassignment".

Change the word "sub-delegation" to "reassignment".

Now some examples of how this draft policy will work with different size 
IPv6 blocks with the current global routing rules:

For sites with exactly /48, there will be two classes of sites:

1) Those sites with a /48 assigned to them, and using the same routing as 
the parent block (Allocation or Re-allocation) above them.

2) Those sites with a /48 assigned to them, where the entity with the /48 
has made arrangements to have their /48 assignment routed differently than 
the parent block (Allocation or Re-allocation) above them.

It is the intent of the language proposed to require 2) above to be 
registered in SWIP (since they have different routing), and to exempt 1) 
above from the SWIP requirement, as they are using the standard routing of 
their parent block, and for the most part will be normal sites that use 
just a single IPv4 address which no SWIP requirement exists, and a single 
/48 assigned to them for their site which has been identified as the best 
practice for all sites.

I think this is the confusing part of the language, since a /48 can go 
either way, SWIP or no SWIP depending on independent routing, while 
anything larger is ALWAYS SWIP'ed and and everything smaller would under 
current best practices would never require SWIP.

Under the draft, For any reassignment with a /47 or More of addresses, ALL 
will require SWIP.  This should cover ALL Re-allocation cases, as the 
reallocated block received must for technical reasons be large enough for 
the reallocator to have 1 or more /48's to assign to the customers below 

Under the draft, For any site of any size, if the GRT policy is ever 
changed from a /48, all such sites smaller than the new limit that has 
independent routing MUST be registered in SWIP. The policy intent 
expressed is SWIP registration of all independently routed blocks, not a 
specific block size, since routing is not an ARIN decision. Since current 
best practice does not allow independent routing of less than a /48, all 
sites regardless of any attempts of independent routing that are smaller 
than /48 actually are not independently routed since those routes will not 
appear in the GRT, and thus are exempt from SWIP.  This level of /48 could 
change in the future via processes outside of the control of ARIN.

Albert Erdmann
Network Administrator
Paradise On Line Inc.

On Sun, 23 Jul 2017, David Farmer wrote:

> The rewrite is a pretty good step forward, and I support this policy as
> written, but I also would like to see some additional changes.
> The following is a summary of what I would like to see the overall policy
> look like, it is not in policy language but provided as list of
> requirement, with some additional notes, then I note what I think is
> missing from the current proposed policy text;
> Reallocations:
> - All reallocations* MUST have a SWIP provided regardless of size.
> Reassignments:
> - For prefixes shorter than /48 a SWIP MUST be provided.
> - For prefixes at /48 or longer a SWIP is provided at the discretion** of
> the ISP, except;
>  - If requested by the end-user, then a SWIP MUST be provided, or;
>  - If intended to appear in global routing table, then a SWIP SHOULD*** be
> provided.
> *  Reallocations are made to other ISPs which then can make reassignments,
> for IPv6 it is RECOMMENDED that all ISPs obtain an allocation directly from
> ARIN, however reallocations are still permitted. Further, reallocations for
> prefixes /48 or longer are NOT RECOMMENDED.  SWIPs for reallocations need
> to be required because the abuse and other POC for the down stream ISP need
> to be know.
> ** There should be some guidance (NOT policy enforced by ARIN) to ISPs
> making reassignments at /48 or longer: SWIPs for business customers,
> especially those with information technology(IT) operations sophisticated
> enough to handle their own abuse and/or technical incidents, are of
> interest to the community. SWIPs for residential customers (individual
> persons) are NOT normally of interest to the community.
> *** This might be more appropriate as MUST, however as ARIN does not define
> routing policy, therefore SHOULD seems more appropriate.
> So, I think the following is missing from the current proposed policy text;
> 1. Any mention of reallocations, but this wasn't in the original policy
> either
> 2. A requirement that SWIP is provided if requested by end-user
> 3. Guidance for SWIPs for /48 or longer, while these SWIPs aren't required,
> some guidance still might be useful.
> Thanks
> On Fri, Jul 21, 2017 at 11:44 AM, Leif Sawyer <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
>> 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 "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 "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
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> -- 
> ===============================================
> David Farmer               Email:farmer at umn.edu
> Networking & Telecommunication Services
> Office of Information Technology
> University of Minnesota
> 2218 University Ave SE        Phone: 612-626-0815 <(612)%20626-0815>
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