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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