I support the policy as written. > -----Original Message----- > From: arin-ppml-boun...@arin.net [mailto:arin-ppml-boun...@arin.net] On > Behalf Of ARIN > Sent: September 1, 2015 1:21 PM > To: arin-ppml@arin.net > Subject: [arin-ppml] Recommended Draft Policy ARIN-2015-1: Modification to > Criteria for IPv6 Initial End-User Assignments > > ARIN-2015-1 has been revised to show only the proposed addition to the > policy. > > ARIN-2015-1 is below and can be found at: > https://www.arin.net/policy/proposals/2015_1.html > > You are encouraged to discuss Draft Policy 2015-1 on the PPML prior to the > ARIN Public Policy Consultation at ARIN 36 in Montreal in October 2015. Both > the discussion on the list and at the meeting will be used by the ARIN > Advisory Council to determine the community consensus for adopting this as > policy. > > ARIN-2015-1 is below and can be found at: > https://www.arin.net/policy/proposals/2015_1.html > > Regards, > > Communications and Member Services > American Registry for Internet Numbers (ARIN) > > > ## * ## > > > Recommended Draft Policy ARIN-2015-1 > Modification to Criteria for IPv6 Initial End-User Assignments > > Date: 27 August 2015 > > AC's assessment of conformance with the Principles of Internet Number > Resource Policy: > > ARIN-2015-1 enables fair and impartial number resource administration by > providing a concrete threshold (13 active sites) under which end-user > organizations who have a large number of potentially geographically > dispersed sites, or sites with low subnet and/or user counts, can be > reasonably assured of receiving IPv6 address space from ARIN. This proposal > is technically sound, in that it retains reasonable thresholds on obtaining > IPv6 > assignments from ARIN in order to support the aggregation of Internet > number resources in a hierarchical manner to the extent feasible. It has been > well supported by the community on PPML and at the ARIN PPC at NANOG in > San Francisco, where nearly everyone agreed that this was a step in the right > direction. To the extent that some in the community desire even more > relaxed IPv6 assignment policy, the AC encourages those community > members to discuss on PPML and/or submit as additional policy proposals > any further changes they would like to see. > > Problem Statement: > > Current policy for assignment to end users excludes a class of users whose > costs to renumber would far exceed what current policy is designed to > mitigate. > > Current measures designed to minimize the economic cost of renumbering > per NRPM 6.5.8.1 (Initial Assignment Criteria) are: > > c. By having a network that makes active use of a minimum of 2000 IPv6 > addresses within 12 months, or; d. By having a network that makes active use > of a minimum of 200 /64 subnets within 12 months, or; > > These two measures fail to take into account end users who have a large > number of potentially geographically dispersed sites, or sites with low subnet > and/or user counts. The economic costs for this class of end user would likely > far exceed the costs that 6.5.8.1 c. and d. are designed to mitigate. > > While an end user could possibly apply (and receive an assignment) under > 6.5.8.1 e. ("By providing a reasonable technical justification indicating why > IPv6 addresses from an ISP or other LIR are unsuitable"), it fails to provide > a > concrete threshold under which this class of end-user can be reasonably > assured of receiving address space. > > Without having the reasonable assurance of IPv6 address number resource > continuity that a direct assignment allows, many smaller enterprises are > unlikely to adopt IPv6 (currently perceived as an already tenuous proposition > for most users given current cost/benefit); or are likely to adopt technical > measures (such as using ULA addressing + NAT66) that are widely held to be > damaging to the IPv6 Internet. > > Policy Statement: > > Renumber NRPM 6.5.8.1 Initial Assignment Criteria subsection e. to f. > and and insert a new subsection e. with the following text: > > By having a contiguous network that has a minimum of 13 active sites within > 12 months, or; > > Comments: > a. Timetable for implementation: Immediate b. General Comments: > > - The threshold of 13 sites was chosen based on NRPM 6.5.8.2, which > specifies 13 sites as the minimum number of sites required to receive a > /40 initial assignment, to attempt to provide a balance between the costs of > carrying the prefix vs. the costs to the end-user in renumbering. > > - Further constraints were added in that the sites must be in a contiguous > network, to further attempt to reduce the costs of carrying the prefix > > - By introducing this new threshold, we attempt to restore equivalency of > number resources for those end-users whose economic costs to renumber > are equal to that of other end-users who would qualify for a direct > assignment under 6.5.8.1 c. and d. > > c. Example: > > Example of an end-user who would not qualify under 6.5.8.2 c. or d.: > > - 50 locations (IPVPN) spread across the country/continent > - 10 staff per location (average; 500 total) > - 20 devices per location (average; 1000 total) > - 2 subnets (voice & data) per location (average, 100 total) > - Not multihomed > - Currently using RFC1918 IPv4 space + NAT > > This end-user only benefits minimally from IPv6 multihoming as they are > using an IPVPN, and multihoming provides benefit only for Internet transit, > not within their IPVPN. As such requiring the end-user to multihome under > NRPM 6.5.8.2 b. is wasteful. > > This end user currently uses RFC1918 IPv4 address space + a relatively small > amount of IPv4 GUA + NAT (currently accepted industry practice for IPv4). > Changing providers involves only renumbering the small amount of > IPv4 GUA. Forcing the end-user to acquire an IPv4 direct assignment under > NRPM 6.5.8.2 a. in order to be able to get a direct IPv6 assignment is > incredibly wasteful of a valuable and limited number resource. It also forces > the customer occupy more routing table space, as now an IPv4 PI prefix must > be routed in addition to an IPv6 PI prefix, instead of using IPv4 PA + IPv6 PI > (where only space for an IPv6 PI prefix is required). > > ##### > > ARIN STAFF ASSESSMENT > > Draft Policy ARIN-2015-1 > Modification to Criteria for IPv6 Initial End-User Assignments > https://www.arin.net/policy/proposals/2015_1.html > > Date of Assessment: June 11, 2015 > > ___ > 1. Summary (Staff Understanding) > This proposal would add a criteria item to 6.5.8.1 (Initial Assignment > Criteria). > Because each of the existing criteria items in that section can independently > qualify an organization for IPv6 address space from ARIN, this new criteria > item adds an additional qualification criteria. > It makes it easier for some organizations to qualify, and does not make it > more difficult for anyone. In particular, it creates a new criteria point that > allows any end-user organization large enough to have 13 sites to > immediately qualify for IPv6 address space from ARIN. > > ___ > 2. Comments > A. ARIN Staff Comments > This proposal can be implemented as written. Minimal staff training and > preparation would be needed to implement this if it were to become policy. > We see no negative impacts. > > B. ARIN General Counsel – Legal Assessment Counsel sees no material legal > issues in this policy. > > ___ > 3. Resource Impact > This policy would require minimal staff training and preparation. We see no > negative impacts. > > ___ > 4. Proposal / Draft Policy Text Assessed > > Draft Policy ARIN-2015-1 > Modification to Criteria for IPv6 Initial End-User Assignments > > Date: 24 March 2015 > > Problem Statement: > Current policy for assignment to end users excludes a class of users whose > costs to renumber would far exceed what current policy is designed to > mitigate. > > Current measures designed to minimize the economic cost of renumbering > per NRPM 6.5.8.1 (Initial Assignment Criteria) are: > > c. By having a network that makes active use of a minimum of 2000 IPv6 > addresses within 12 months, or; d. By having a network that makes active use > of a minimum of 200 /64 subnets within 12 months, or; > > These two measures fail to take into account end users who have a large > number of potentially geographically dispersed sites, or sites with low subnet > and/or user counts. The economic costs for this class of end user would likely > far exceed the costs that 6.5.8.1 c. and d. are designed to mitigate. > > While an end user could possibly apply (and receive an assignment) under > 6.5.8.1 e. ("By providing a reasonable technical justification indicating why > IPv6 addresses from an ISP or other LIR are unsuitable"), it fails to provide > a > concrete threshold under which this class of end-user can be reasonably > assured of receiving address space. > > Without having the reasonable assurance of IPv6 address number resource > continuity that a direct assignment allows, many smaller enterprises are > unlikely to adopt IPv6 (currently perceived as an already tenuous proposition > for most users given current cost/benefit); or are likely to adopt technical > measures (such as using ULA addressing + NAT66) that are widely held to be > damaging to the IPv6 Internet. > > Policy Statement: > > Replace the contents of NRPM 6.5.8.1 with: > > 6.5.8.1. Initial Assignment Criteria > > Organizations may justify an initial assignment for addressing devices > directly > attached to their own network infrastructure, with an intent for the > addresses to begin operational use within 12 months, by meeting one of the > following criteria: > > a. Having a previously justified IPv4 end-user assignment from ARIN or one > of its predecessor registries, or; b. Currently being IPv6 Multihomed or > immediately becoming IPv6 Multihomed and using an assigned valid global > AS number, or; c. By having a network that makes active use of a minimum of > 2000 IPv6 addresses within 12 months, or; d. By having a network that makes > active use of a minimum of 200 /64 subnets within 12 months, or; e. By > having a contiguous network that has a minimum of 13 active sites within 12 > months, or; f. By providing a reasonable technical justification indicating > why > IPv6 addresses from an ISP or other LIR are unsuitable. > > Examples of justifications for why addresses from an ISP or other LIR may be > unsuitable include, but are not limited to: > > > An organization that operates infrastructure critical to life safety > or the functioning of society can justify the need for an assignment based on > the fact that renumbering would have a broader than expected impact than > simply the number of hosts directly involved. These would > include: hospitals, fire fighting, police, emergency response, power or energy > distribution, water or waste treatment, traffic management and control, etc. > > Regardless of the number of hosts directly involved, an organization > can justify the need for an assignment if renumbering would affect 2000 or > more individuals either internal or external to the organization. > > An organization with a network not connected to the Internet can > justify the need for an assignment by documenting a need for guaranteed > uniqueness, beyond the statistical uniqueness provided by ULA (see RFC > 4193). > > An organization with a network not connected to the Internet, such as > a VPN overlay network, can justify the need for an assignment if they require > authoritative delegation of reverse DNS. > > Comments: > a. Timetable for implementation: Immediate b. General Comments: > > - Changes to NRPM 6.5.8.1 are to renumber subsection e. to f. and and insert > a new subsection e. with the following text: > > "By having a contiguous network that has a minimum of 13 active sites within > 12 months, or; > > - The threshold of 13 sites was chosen based on NRPM 6.5.8.2, which > specifies 13 sites as the minimum number of sites required to receive a > /40 initial assignment, to attempt to provide a balance between the costs of > carrying the prefix vs. the costs to the end-user in renumbering. > > - Further constraints were added in that the sites must be in a contiguous > network, to further attempt to reduce the costs of carrying the prefix > > - By introducing this new threshold, we attempt to restore equivalency of > number resources for those end-users whose economic costs to renumber > are equal to that of other end-users who would qualify for a direct > assignment under 6.5.8.1 c. and d. > > c. Example: > > Example of an end-user who would not qualify under 6.5.8.2 c. or d.: > > - 50 locations (IPVPN) spread across the country/continent > - 10 staff per location (average; 500 total) > - 20 devices per location (average; 1000 total) > - 2 subnets (voice & data) per location (average, 100 total) > - Not multihomed > - Currently using RFC1918 IPv4 space + NAT > > This end-user only benefits minimally from IPv6 multihoming as they are > using an IPVPN, and multihoming provides benefit only for Internet transit, > not within their IPVPN. As such requiring the end-user to multihome under > NRPM 6.5.8.2 b. is wasteful. > > This end user currently uses RFC1918 IPv4 address space + a relatively small > amount of IPv4 GUA + NAT (currently accepted industry practice for IPv4). > Changing providers involves only renumbering the small amount of > IPv4 GUA. Forcing the end-user to acquire an IPv4 direct assignment under > NRPM 6.5.8.2 a. in order to be able to get a direct IPv6 assignment is > incredibly wasteful of a valuable and limited number resource. It also forces > the customer occupy more routing table space, as now an IPv4 PI prefix must > be routed in addition to an IPv6 PI prefix, instead of using IPv4 PA + IPv6 PI > (where only space for an IPv6 PI prefix is required). > _______________________________________________ > PPML > You are receiving this message because you are subscribed to the ARIN > Public Policy Mailing List (ARIN-PPML@arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact i...@arin.net if you experience any issues.
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