[arin-ppml] Revised - Draft Policy ARIN-2020-3: IPv6 Nano-allocations

[ARIN]

The following Draft Policy has been revised:

* ARIN-2020-3: IPv6 Nano-allocations

Revised text is below and can be found at:

https://www.arin.net/participate/policy/drafts/2020_3/

You are encouraged to discuss all Draft Policies on PPML. The AC will 
evaluate the discussion in order to assess the conformance of this Draft 
Policy with ARIN's Principles of Internet number resource policy as 
stated in the Policy Development Process (PDP). Specifically, these 
principles are:

* Enabling Fair and Impartial Number Resource Administration
* Technically Sound
* Supported by the Community

The PDP can be found at:
https://www.arin.net/participate/policy/pdp/

Draft Policies and Proposals under discussion can be found at:
https://www.arin.net/participate/policy/drafts/

Regards,

Sean Hopkins
Policy Analyst
American Registry for Internet Numbers (ARIN)




Draft Policy ARIN-2020-3: IPv6 Nano-allocations

AC Assessment of Conformance with the Principles of Internet Number 
Resource Policy:

Recommended Draft Policy ARIN-2020-3 provides for small IPv6 allocations 
to ISPs. This policy would allow the smallest ISP organizations to 
obtain a /40 of IPv6 addresses. This recommended draft is technically 
sound, supported by the community and enables fair and impartial 
administration of number resources by providing the smallest 
organizations the opportunity to obtain an IPv6 allocation without a fee 
increase under the current fee schedule.

Problem Statement:

ARIN’s ISP registration services fee structure has graduated fee 
categories based upon the total amount of number resources held within 
the ARIN registry.

In the case of the very smallest ISPs, if a 3X-Small ISP (with a /24 or 
smaller of IPv4) gets the present minimal-sized IPv6 allocation (a /36), 
its annual fees will double from $250 to $500/year.

According to a Policy Experience Report presented by Registration 
Services to the AC at its annual workshop in January 2020, this 
represents a disincentive to IPv6 adoption with a substantial fraction 
of so-situated ISPs saying “no thanks” and abandoning their request for 
IPv6 number resources when informed of the impact on their annual fees.

This can be addressed by rewriting subsection 6.5.2.1(b). Initial 
Allocation Size to allow allocation of a /40 to only the smallest ISPs 
upon request, and adding a new clause 6.5.2.1(g) to cause an automatic 
upgrade to at least a /36 in the case where the ISP is no longer 3X-Small.

Reserving /40s only for organizations initially expanding into IPv6 from 
an initial sliver of IPv4 space will help to narrowly address the 
problem observed by Registration Services while avoiding unintended 
consequences by accidentally giving a discount for undersized allocations.

Policy Statement:

Replace the current 6.5.2.1(b) with the following:

b. In no case shall an LIR receive smaller than a /32 unless they 
specifically request a /36 or /40.

In order to be eligible for a /40, an ISP must meet the following 
requirements:

- Hold IPv4 direct allocations totaling a /24 or less (to include zero)
- Hold IPv4 reassignments/reallocations totaling a /22 or less (to 
include zero)

In no case shall an ISP receive more than a /16 initial allocation.

Add 6.5.2.1(g) as follows:

g. An LIR that requests a smaller /36 or /40 allocation is entitled to 
expand the allocation to any nibble aligned size up to /32 at any time 
without renumbering or additional justification. /40 allocations shall 
be automatically upgraded to /36 if at any time said LIR’s IPv4 direct 
allocations exceed a /24. Expansions up to and including a /32 are not 
considered subsequent allocations, however any expansions beyond /32 are 
considered subsequent allocations and must conform to section 6.5.3. 
Partial returns of any IPv6 allocation that results in less than a /36 
of holding are not permitted regardless of the ISP’s current or former 
IPv4 number resource holdings.

Timetable for Implementation: Immediate

Comments:

The intent of this policy proposal is to make IPv6 adoption at the very 
bottom end expense-neutral for the ISP and revenue-neutral for ARIN. The 
author looks forward to a future era wherein IPv6 is the dominant 
technology and IPv4 is well in decline and considered optional leading 
the Community to conclude that sunsetting this policy is prudent in the 
interests of avoiding an incentive to request undersized IPv6 allocations.

Timetable for implementation: ImmediateARIN’s ISP registration services 
fee structure has graduated fee categories based upon the total amount 
of number resources held within the ARIN registry.

In the case of the very smallest ISPs, if a 3X-Small ISP (with a /24 or 
smaller of IPv4) gets the present minimal-sized IPv6 allocation (a /36), 
its annual fees will double from $250 to $500/year.

According to a Policy Experience Report presented by Registration 
Services to the AC at its annual workshop in January 2020, this 
represents a disincentive to IPv6 adoption with a substantial fraction 
of so-situated ISPs saying “no thanks” and abandoning their request for 
IPv6 number resources when informed of the impact on their annual fees.

This can be addressed by rewriting subsection 6.5.2.1(b). Initial 
Allocation Size to allow allocation of a /40 to only the smallest ISPs 
upon request, and adding a new clause 6.5.2.1(g) to cause an automatic 
upgrade to at least a /36 in the case where the ISP is no longer 3X-Small.

Reserving /40s only for organizations initially expanding into IPv6 from 
an initial sliver of IPv4 space will help to narrowly address the 
problem observed by Registration Services while avoiding unintended 
consequences by accidentally giving a discount for undersized allocations.