As for discussion of SWIP for /48's, some have suggested since these are the recommended minimum assignment for an end site, /48 should not trigger SWIP unless independently routed. Others believe all /48's be SWIP'ed. Thus the two main ideas for this proposal currently are:

1) SWIP all independently routed (in the GRT) networks regardless of size but in actual fact they must be at least a /48 to be in the GRT, and all other assignments greater than a /48. This is the "b)" language using /47 from the other day.

2) SWIP every /48 regardless of routing, smaller are exempt. This is the "/48 or more" language. Since the standard site size is /48, this catches a lot of small sites that are not independently routed but avoids setting the policy based on routing. If this is chosen many ISP's are likely to choose giving out /52 or less instead of /48's. As pointed out by others, a major cable ISP in the US already gives out only a /60 with their prefix delegation server. Although like the mobile networks, they do have a current valid argument against SWIP, since these are not "static".

We are in agreement that anything smaller than /48 including /56 should not require SWIP. I would be happy with either result, but am biased toward not requiring SWIP for /48 blocks not independently routed.

The inequality between v4 and v6 is why I drafted this proposal. The bus network I speak of operates today using a single static v4 address per bus. The wireless provider will no longer provide static v4 after the contract ends next year. There are currently two RFC1918 v4 subnets on each bus, one for administrative, and one for wifi. and each device on the bus is accessable from headquarters via forwarded ports from the bus router's static v4. There has never been a SWIP requirement for having a single static v4 address.

Now that we want to change the bus administrative network to v6 for lack of v4 static assignments from the contract wireless provider, we run into the ARIN 100% SWIP registration requirement of /64 or more in NRPM 6.5.5.1. as v6 does not use NAT. The policy of /64 or more is what I seek to change, to allow smaller v6 networks, like these busses to avoid a SWIP requirement. Switching the same size network with the same number of hosts from v4 to v6 should not change the SWIP requirement, but current policy does. This is where the debate is, where to draw that line.

The thing to remember is that currently a /48, according to the 2.15 of the NRPM is the recommended value for every end site, residential or commercial. Current ARIN policy would allow the transit agency to receive a /36 and assign each bus a /48. I have suggested they instead obtain a single end user /48 from either ARIN or a /48 assignment from a /32 block already controlled by state government for their bus use to avoid renumbering during contract provider changes, and use a /60 on each bus. Either saves money over getting a /36 from ARIN.

As far as public disclosure of CPNI, the size of an organization does not matter. In the example discussed here of that 69.0.0.0/29 block we have been talking of, unless AT&T has written permission from that customer, they have committed a CPNI violation by simply publishing the name and address of that customer in SWIP, and AT&T could in theory be fined for that disclosure, even though ARIN policy requires the information be disclosed in SWIP. If the FCC in fact takes action is a different story. The usefulness of this SWIP record is also in doubt, as staff at that location, even if contacted might be unable to deal with an "owned" box. It is better to have tech records with the contact info of actual technicians.

Albert Erdmann
Network Administrator
Paradise On Line Inc.

On Thu, 20 Jul 2017, Chris James wrote:

Well I think in the bus example you would swip to the overall authority.
But seriously this conversation has gone in so many different directions do
any of us remember the original point?

My vote as it applies to v6: Non-residential allocations of greater than or
equal to a /48.

If you as an ISP choose to allocate a /48 to a residential customer - then
have fun. But this does not affect the purpose of the policy as most use it
these days which is abuse management. Also as I understand it, there is an
exception to the CPNI as it applies to business customers as long as they
have an account manager and adequate language in the contract. How many of
the smaller ISPs have a customer deserving of a /48 or better that does not
have a larger account or spend? If a customer requests a large enough block
from us, regardless of v4 vs v6, they agree via email/ticketing/contract
that their business information will be made public. This is not difficult
to put in your signed agreements with your business customers thus making
the CPNI argument invalid.

-Chris



On Thu, Jul 20, 2017 at 2:28 PM, <hostmas...@uneedus.com> wrote:

My transit bus example is another example of SWIP difficulty.  Very hard
to provide a street address to SWIP a bus when it is mobile 16 hours a day.

Current policy says SWIP every /64 or more, which is every network in v6.

I did a check here, and in v4, only 1% of customers have more than 8 ip's,
and these customers are colocation customers who have a bunch of SSL
sites.  These are grandfathered. New customers are told to use 1 IPv4
address and SNI or better yet, IPv6, as we do not have the money to buy
more V4.  We would rather use our v4 inventory for access customers.

Yes, it is just a few pieces of information for SWIP.  However, we do not
have clerical staff to do it, because except for the SSL colocates, there
never has been v4 SWIP's required here. Why should the policy state that
just because we give each customer an assignment of v6, we must SWIP that
same small customer that did not require SWIP in v4? (Welcome to IPv6, now
fill out this form.....) Also noted is that the SWIP registration details
without written permission might get us in trouble with the FCC over CPNI.
As a WISP that has licensed microwave links, we do pay attention to Uncle
Charlie.

Albert Erdmann
Network Administrator
Paradise On Line Inc.

On Thu, 20 Jul 2017, Chris James wrote:

@Paul - The API key is to email it.

@Owen - Very difficult when you have dynamic ranges, and vps/container
platforms spanning tens of thousands of instances across these dynamic
ranges.


On Thu, Jul 20, 2017 at 1:51 PM, Paul McNary <pmcn...@cameron.net> wrote:

Owen

The reassignment policy page says IPv6 has to be done vi API.
Is that something else that is incorrect on the web site?

Paul


On 7/20/2017 3:16 PM, Owen DeLong wrote:

How can it be overly difficult to fill out an email template with your
customers???
Name, Address, Phone Number?

Really?

Owen

On Jul 19, 2017, at 23:48 , Pallieter Koopmans <pallie...@pallieter.org


wrote:

Hello,

ARIN could quantify and require rules for when to SWIP, but in the
end, there are going to be exceptions needed if the rules are to be
strictly followed. Many will not separately SWIP a separately routed
sub-block if it is too difficult or pointless to gather and share that
data back upstream to ARIN.

Thus a more fuzzy rule to require a best-effort and to add a
rule-based reason (preferably both a carrot and a stick) for block
owners to do their best to provide (only) useful data. In order to do
that, one needs to look back at why that data is needed. For a block
owner to assign the SWIP on a sub-block, he basically delegates tech
and abuse contact requests down to those that are probably more likely
to be able to actually act on the tech/abuse requests (and thus reduce
request-handling workload higher up and overall). But for that to
work, those tech/abuse contact requests need to be actually handled,
otherwise, it is better to leave them with the block owner.

In the end, the contact details should be as close to the "person"
that is actually capable to both handle (think: volume/languages/etc)
and act (think: authority) on the tech/abuse requests.

eBrain
Innovative Internet Ideas

Pallieter Koopmans
Managing Director

+31-6-3400-3800 (mon-sat 9-22 CET)
Skype: PallieterKoopmans
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