[arin-ppml] LAST CALL - Recommended Draft Policy ARIN-2017-5: Improved IPv6 Registration Requirements

hostmaster at uneedus.com hostmaster at uneedus.com
Thu Oct 12 12:52:09 EDT 2017 

I support the policy as written, with "shall".  I also support with 
"should", but would rather have shall.

As for discussion of what ARIN will do if an ISP decides not to follow the 
policy, I guess we can ask what ARIN is doing NOW.

Under CURRENT policy (6.5.5.1), a /64 or more of static IPv6 space "shall" 
be registered in SWIP, which is basically EVERY IPv6 static assignment, 
governed by the "shall" rule.  "Shall" is the status quo at this time. 
There is no choice regarding registration of static /64's or more, they 
"shall" be registered.

Under the Draft Policy, this "shall" requirement of "shall" of 
registration is greatly reduced.  As an ISP, I can now provide up to a /48 
of space to each site of each customer without triggering any registration 
requirement, as long as it is not independently routed, with one specific 
exception.  That exception is that the customer has actually ASKED me to
register their static assigment of /64 or more.

Since we started with a current policy that gave no choice and ALWAYS 
required registration, and we are moving toward a policy that only 
requires registration of that /64 or more upon request ONLY, I see this as 
a reduction of burden.

As to what ARIN will do if the "shall" requirement is not followed, I did 
ask early in the discussion if ARIN had ever pulled resources (its most 
extreme sanction) because of failure to register in SWIP those /64's that 
current policy say "shall" be registered.  I was told "no" to that 
question.

I have been working with IPv6 since 2006 or so, and went thru the days of 
the Federal Government requirement to have IPv6 in 2008 or so, my bread 
and butter.  In the last few years since the current registration policy 
was lowered from a /48 to a /64, I have looked up many of my customer's 
static IPv6 assignments, and with only the exception of a certain major 
tunnel broker (still kinda the last resort for v6 if native is not 
available), I have never found my static customer IPv6 assignments to 
ever been registered in SWIP.

Therefore, I have reached the conclusion that the /64 current requirement 
is totally ignored, and unenforced.  It is also unreasonable versus v4, 
thus why I proposed this draft.

I doubt that even with "shall", that ARIN will do anything other than talk 
to the customer regarding following number policy required by the RSA, and 
I have extreme doubts that any number resources will be ever pulled, 
regardless of the use either word "should" or "shall".

Albert Erdmann
Network Administrator
Paradise On Line Inc.



On Thu, 12 Oct 2017, Mike Burns wrote:

> +1 to "Should have stuck with should."
>
> I also oppose as written (amended) for the same reasons described below.
>
> Regards,
> Mike Burns
>
>
>
> -----Original Message-----
> From: ARIN-PPML [mailto:arin-ppml-bounces at arin.net] On Behalf Of Michael Winters
> Sent: Thursday, October 12, 2017 10:33 AM
> To: ARIN <info at arin.net>; arin-ppml at arin.net
> Subject: Re: [arin-ppml] LAST CALL - Recommended Draft Policy ARIN-2017-5: Improved IPv6 Registration Requirements
>
> Opposed as written (amended).
>
> As written, (IMHO) it is an incomplete and unenforceable policy (shall part anyway).
> If you are saying shall, what is the policy for ARIN to follow if there is noncompliance.
> In attempting to fix a potential problem that does not yet exist, due to the word shall, this policy creates a problem.
>
> Should have stuck with should.
>
> Thanks,
> Mike
>
> -----Original Message-----
> From: ARIN-PPML [mailto:arin-ppml-bounces at arin.net] On Behalf Of ARIN
> Sent: Wednesday, October 11, 2017 3:17 PM
> To: arin-ppml at arin.net
> Subject: [arin-ppml] LAST CALL - Recommended Draft Policy ARIN-2017-5: Improved IPv6 Registration Requirements
>
> The ARIN Advisory Council (AC) met on 6 October 2017 and decided to send the following to Last Call:
>
> Recommended Draft Policy ARIN-2017-5: Improved IPv6 Registration Requirements
>
> The AC provided the following statement to the community:
>
> "Based on strong community support - on both the Public Policy Mailing List and in person at ARIN 40 during the policy consultation - for replacing the "should" qualifier in section 6.5.5.4 with "shall", the Advisory Council, after careful review and discussion, has made the requested change to the text."
>
> Feedback is encouraged during the Last Call period. All comments should be provided to the Public Policy Mailing List. This Last Call period will expire on 10 November 2017. After Last Call, the AC will conduct their Last Call review.
>
> The full text is below and available at:
> https://www.arin.net/policy/proposals/
>
> The ARIN Policy Development Process is available at:
> https://www.arin.net/policy/pdp.html
>
> Regards,
>
> Sean Hopkins
> Policy Analyst
> American Registry for Internet Numbers (ARIN)
>
>
>
> AC's Statement of Conformance with ARIN's Principles of Internet Number Resource Policy:
>
> This proposal is technically sound and enables fair and impartial number policy for easier IPv6 Registrations. The staff and legal review noted a single clarification issue which has been addressed. There is ample support for the proposal on PPML and no concerns have been raised by the community regarding the proposal.
>
> 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 "assignment containing a /64 or more addresses" and change to "re-allocation, reassignment containing a /47 or more addresses, or subdelegation of any size that will be individually announced,”
>
> and
>
> 2) Alter section 6.5.5.2. "Assignments visible within 7 days" of the NRPM to strike the text "4.2.3.7.1" and change to “6.5.5.1"
>
> and
>
> 3) Alter section 6.5.5.3.1. "Residential Customer Privacy" of the NRPM by deleting the phrase "holding /64 and larger blocks"
>
> and
>
> 4) Add new section 6.5.5.4  "Registration Requested by Recipient" of the NRPM, to read: "If the downstream recipient of a static assignment of
> /64 or more addresses requests publishing of that assignment in ARIN's registration database, the ISP shall register that assignment as described in section 6.5.5.1."
>
> 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.
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