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

[hostmaster at uneedus.com]

I have a problem with this language:

"Downgrades of any IPv6 allocation to less than a /36 are not permitted 
regardless of the ISP’s current or former IPv4 number resource holdings."

Downgrades include in my mind a return, and thus a downgrade to 0.  This 
language seems to lock in anyone who has ever requested IPv6 space.

Does this make a request for IPv6 space from ARIN like the Hotel 
California, where you can never leave....

If I were one of those ISP's with a /24 of IPv4, and I took the minimum 
allocation of IPv6 which raised my fees to $500 from $250, does this 
language make me continue to pay $500/yr even if I decide to return all my 
IPv6 resources to ARIN, and either get IPv6 space from my upstream or 
forgo use of IPv6?

Albert Erdmann
Network Administrator
Paradise On Line Inc.


On Tue, 21 Jul 2020, ARIN wrote:

> On 16 July 2020, the ARIN Advisory Council (AC) advanced the following Draft 
> Policy to Recommended Draft Policy status:
>
> ARIN-2020-3: IPv6 Nano-allocations
>
> The text of the Recommended Draft Policy is below, and may also be found at:
>
> https://www.arin.net/participate/policy/drafts/2020_3/
>
> You are encouraged to discuss all Recommended Draft Policies on PPML prior to 
> their presentation at the next ARIN Public Policy Consultation (PPC). PPML 
> and PPC discussions are invaluable to the AC when determining community 
> consensus.
>
> 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
>
>
>
> Recommended 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. 
> Downgrades of any IPv6 allocation to less than a /36 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.
>
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