[arin-ppml] Comments: Draft Policy ARIN-2025-7

[Lily Edinam Botsyoe]

Hi PPML,


In case you missed it, below is a summary of the feedback received for *“ARIN
Draft Policy ARIN-2025-7: Make Policy in 6.5.8.2 Match the Examples“* at
the just ended ARIN 56.


Here are the questions asked at the end of the presentation:


   - *Do you support this specific exception to the 75% allocation rule for
   single-site organizations (Why or why not?)*
   - *Which allocation size best serves the needs of a single-site
   end-user: A /48 (as allocated by the current examples and proposed by this
   policy) or a /44 (as strictly calculated by the existing 75% rule)? *
   - *Should the AC continue work on this policy?*

Here are comments that came following the presentation:


*Community Feedback on Single-Site Allocation Exception*


The following comments relate to the proposed exception to the 75%
utilization rule for single-site organizations and the appropriate
allocation size (/48 vs. /44).


*Comments regarding Policy Structure and Scarcity Concerns*



   - The policy structure should be reworked to state that a single-site
   organization *receives a /48*, and then the 75% formula applies to
   multi-site organizations, rather than framing the /48 as an exception.
   - Limiting single-site organizations to a /48 reintroduces a *scarcity
   model* mindset, which is not aligned with IPv6 principles.
   - Requiring an organization to return for an additional block means they
   could potentially consume multiple routing slots (more than one prefix),
   which should be avoided.
   - There's a need to rework the current policy *from the ground up* to
   reflect current needs and lessons learned, rather than making complex,
   piecemeal changes.


*Comments regarding **Allocation Size: /48 vs. /44 (and larger)*



   - *Default Allocation Size:* The default for end-users coming directly
   to ARIN should be *larger than a /48* to account for growth, even if the
   user initially only needs a /48.
   - *Preventing Fragmentation:* If end-users are initially given a /48,
   and later need more, there is a *high probability *that ARIN can
   accommodate the growth by swapping the /48 for a larger, continuous block
   (e.g., a /44) from the *sparse allocation pool*, mitigating some
   concerns about using multiple routing slots.
   - *ISP Context:* Historically, the smallest ISP allocation has been a
   /40 (down from /32), showing an evolution in sizing; the concern is that
   end-users are now being treated *too frugally* with a default /48.
   - *Single-Site Needs:* For a hosting provider, once they become an LIR
   (Local Internet Registry) and receive an ASN, they typically need more than
   a /48, with a */44* being more appropriate.


*Clarifications and Support*



   - *Policy Support:* One member explicitly stated *they do not support* the
   current proposed change, suggesting a more fundamental cleanup is needed.
   - *Current Policy:* Under existing policy, an end-user single-site
   allocation is a /48, while an ISP must receive at least a /40.
   - From Staff:
      - Historically, RSD has not experienced any problems with the
      existing policy text as the policy states that organizations may
receive an
      initial assignment of /48, and requests for larger than a /48
are based on
      the number of sites in the organization’s network.  It is understood the
      75% threshold applies only to requests larger than /48.
      - Currently, ARIN assigns IPv6 addresses *sparsely* by issuing a
      single /48 and effectively reserving the remaining /44 block for the
      customer's future growth. This strategy provides the best chance for
      customers to expand into consecutive blocks, though ARIN cannot guarantee
      the reserve will always be available indefinitely (as was the case with
      IPv4 depletion). According to ARIN's inventory oversight, they
have issued
      less than 1% of the total IPv6 space. ARIN has approximately one million
      /48s with reserved /44s available, which, at the current issuance rate,
      represents over 100 years of available space.
      - RSD shares that, if a hosting provider were to request space from
      ARIN, they would be reviewed under ISP/LIR policies from the
start, so they
      would justify a /40 minimum up to a /32.

*<End>*

Do share your thoughts, support or edits as you deem fit. Thank you.

Best regards,
Lily
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