Boy, am I learning from this process. Please let me know if I am not defining these terms we are discussing below properly:

Allocation:  Directly receiving a block of IP addresses from ARIN.

Re-Allocation: Taking part of an Allocation from ARIN, and permitting another ISP/LIR to use this block for assignment to their end user customers.

Assignment: When the original ARIN blockholder assigns a block from their allocation to an end user customer for their use in networks, OR when another ISP without an ARIN allocation for the original block (re-allocation), assigns a portion of their re-allocation to the end user customers.

Reassignment: A superset of all the cases of Assignment, as well as all the cases of Re-allocation, which is not currently defined in the NRPM.

Ok, now that I have the terms out of the way, lets talk.

There seems to be a current disconnect identified in the policy between Re-allocation and assignment because the term "Reassignment" in 6.5.5 is not defined.

Many have identified that the minimum unit of assignment should be a /48 and ARIN policy should not change this fact by putting policies in place that would make it more likely that assignments of less than /48 will be made by ISPs/LIRs. Therefore I propose the following amendments to the draft to address the issues that have been identified:

Add new section 2.17 as follows:

2.17 Reassignment

The term shall mean all cases where an Internet Registry, as defined in section 2.1 assigns or Re-allocates a portion of the addresses received from ARIN or another Internet Registry, for the use by end users or another Internet Registry. This term shall include within it the terms assignment and Re-allocation.

Amend 6.5.5.1 as follows:

Change "Each static IPv6 assignment" to "Each static IPv6 reassignment".

Change the word "sub-delegation" to "reassignment".


Now some examples of how this draft policy will work with different size IPv6 blocks with the current global routing rules:

For sites with exactly /48, there will be two classes of sites:

1) Those sites with a /48 assigned to them, and using the same routing as the parent block (Allocation or Re-allocation) above them.

2) Those sites with a /48 assigned to them, where the entity with the /48 has made arrangements to have their /48 assignment routed differently than the parent block (Allocation or Re-allocation) above them.

It is the intent of the language proposed to require 2) above to be registered in SWIP (since they have different routing), and to exempt 1) above from the SWIP requirement, as they are using the standard routing of their parent block, and for the most part will be normal sites that use just a single IPv4 address which no SWIP requirement exists, and a single /48 assigned to them for their site which has been identified as the best practice for all sites.

I think this is the confusing part of the language, since a /48 can go either way, SWIP or no SWIP depending on independent routing, while anything larger is ALWAYS SWIP'ed and and everything smaller would under current best practices would never require SWIP.

Under the draft, For any reassignment with a /47 or More of addresses, ALL will require SWIP. This should cover ALL Re-allocation cases, as the reallocated block received must for technical reasons be large enough for the reallocator to have 1 or more /48's to assign to the customers below them.

Under the draft, For any site of any size, if the GRT policy is ever changed from a /48, all such sites smaller than the new limit that has independent routing MUST be registered in SWIP. The policy intent expressed is SWIP registration of all independently routed blocks, not a specific block size, since routing is not an ARIN decision. Since current best practice does not allow independent routing of less than a /48, all sites regardless of any attempts of independent routing that are smaller than /48 actually are not independently routed since those routes will not appear in the GRT, and thus are exempt from SWIP. This level of /48 could change in the future via processes outside of the control of ARIN.

Albert Erdmann
Network Administrator
Paradise On Line Inc.

On Sun, 23 Jul 2017, David Farmer wrote:

The rewrite is a pretty good step forward, and I support this policy as
written, but I also would like to see some additional changes.

The following is a summary of what I would like to see the overall policy
look like, it is not in policy language but provided as list of
requirement, with some additional notes, then I note what I think is
missing from the current proposed policy text;

Reallocations:
- All reallocations* MUST have a SWIP provided regardless of size.

Reassignments:
- For prefixes shorter than /48 a SWIP MUST be provided.
- For prefixes at /48 or longer a SWIP is provided at the discretion** of
the ISP, except;
 - If requested by the end-user, then a SWIP MUST be provided, or;
 - If intended to appear in global routing table, then a SWIP SHOULD*** be
provided.

*  Reallocations are made to other ISPs which then can make reassignments,
for IPv6 it is RECOMMENDED that all ISPs obtain an allocation directly from
ARIN, however reallocations are still permitted. Further, reallocations for
prefixes /48 or longer are NOT RECOMMENDED.  SWIPs for reallocations need
to be required because the abuse and other POC for the down stream ISP need
to be know.

** There should be some guidance (NOT policy enforced by ARIN) to ISPs
making reassignments at /48 or longer: SWIPs for business customers,
especially those with information technology(IT) operations sophisticated
enough to handle their own abuse and/or technical incidents, are of
interest to the community. SWIPs for residential customers (individual
persons) are NOT normally of interest to the community.

*** This might be more appropriate as MUST, however as ARIN does not define
routing policy, therefore SHOULD seems more appropriate.

So, I think the following is missing from the current proposed policy text;

1. Any mention of reallocations, but this wasn't in the original policy
either
2. A requirement that SWIP is provided if requested by end-user
3. Guidance for SWIPs for /48 or longer, while these SWIPs aren't required,
some guidance still might be useful.

Thanks

On Fri, Jul 21, 2017 at 11:44 AM, Leif Sawyer <[email protected]> wrote:

Happy Friday, everybody.



As promised, here is the latest rewrite of the draft policy below,  and it
will soon be updated at:

https://www.arin.net/policy/proposals/2017_5.html



There are two changes noted in the policy statement: the first of which
reflects what seems to be the current

consensus of the PPML regarding netblock sizing; the second is to strike
language that may be read as either restrictive

or non-operational.



----



Problem Statement:

       Current ARIN policy has different WHOIS directory registration
requirements for IPv4 vs IPv6 address assignments.

       IPv4 registration is triggered for an assignment of any address
block equal to or greater than a /29 (i.e., eight IPv4 addresses).

       In the case of IPv6, registration occurs for an assignment of any
block equal to or greater than a /64, which constitutes one entire IPv6
subnet and is the minimum block size for an allocation.

       Accordingly, there is a significant disparity between IPv4 and IPv6
WHOIS registration thresholds in the case of assignments, resulting in more
work in the case of IPv6 than is the case for IPv4.

       There is no technical or policy rationale for the disparity, which
could serve as a deterrent to more rapid IPv6 adoption.

       The purpose of this proposal is to eliminate the disparity and
corresponding adverse consequences.



Policy statement:

       1) Alter section 6.5.5.1 "Reassignment information" of the NRPM to
strike "/64 or more addresses" and change to "/47 or more addresses, or
sub-delegation of any size that will be individually announced,"

and

       2) Alter section 6.5.5.3.1. "Residential Customer Privacy" of the
NRPM by deleting the phrase "holding /64 and larger blocks"



Comments:

a.    Timetable for implementation:

       Policy should be adopted as soon as possible.



b.    Anything else:

    Author Comments:

         IPv6 should not be more burdensome than the equivalent IPv4
network size.

         Currently, assignments of /29 or more of IPv4 space (8 addresses)
require registration

         The greatest majority of ISP customers who have assignments of
IPv4 space are of a single IPv4 address which do not trigger any ARIN
registration requirement when using IPv4.

         This is NOT true when these same exact customers use IPv6, as
assignments of /64 or more of IPv6 space require registration.

         Beginning with RFC 3177, it has been standard practice to assign
a minimum assignment of /64 to every customer end user site, and less is
never used.

         This means that ALL IPv6 assignments, including those customers
that only use a single IPv4 address must be registered with ARIN if they
are given the minimum assignment of /64 of IPv6 space.

         This additional effort may prevent ISP's from giving IPv6
addresses because of the additional expense of registering those addresses
with ARIN, which is not required for IPv4.

         The administrative burden of 100% customer registration of IPv6
customers is unreasonable, when such is not required for those customers
receiving only IPv4 connections.





---



Leif Sawyer

Advisory Council



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Networking & Telecommunication Services
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