I support the policy as amended. My primary concern was addressed by staff 
during discussion on the floor.

While I prefer should, the improvement this policy makes is significant enough 
that I support it moving forward with shall.

There is a cost to automation and there is a cost to manually SWIP’ing.

Based on the response from the floor (please correct me if I understood it 
incorrectly). I can charge a nominal fee where appropriate, as my business 
practice. If a client refuses the fee, that does not put me out of compliance 
with the policy.

Thanks,

Kevin Blumberg


From: ARIN-PPML [mailto:[email protected]] On Behalf Of Owen DeLong
Sent: Wednesday, October 11, 2017 7:30 PM
To: Carlton Samuels <[email protected]>
Cc: [email protected]
Subject: Re: [arin-ppml] LAST CALL - Recommended Draft Policy ARIN-2017-5: 
Improved IPv6 Registration Requirements

I’d like to request that if anyone objects to the change made in sending the 
recommended draft to last call (should->shall), they make that clear.

I believe we it is likely “Support as written” will actually be interpreted as 
“Support as amended and sent to last call”.

Sorry for being pedantic, but as an AC member, I’d like to make sure that we 
have the clearest possible understanding of community intent as we move forward.

Thanks,

Owen

On Oct 11, 2017, at 4:25 PM, Carlton Samuels 
<[email protected]<mailto:[email protected]>> wrote:

Support as written.

-CAS


==============================
Carlton A Samuels
Mobile: 876-818-1799
Strategy, Planning, Governance, Assessment & Turnaround
=============================

On Wed, Oct 11, 2017 at 2:16 PM, ARIN <[email protected]<mailto:[email protected]>> 
wrote:
The ARIN Advisory Council (AC) met on 6 October 2017 and decided to send the 
following to Last Call:

Recommended Draft Policy ARIN-2017-5: Improved IPv6 Registration Requirements

The AC provided the following statement to the community:

"Based on strong community support - on both the Public Policy Mailing List and 
in person at ARIN 40 during the policy consultation - for
replacing the "should" qualifier in section 6.5.5.4 with "shall", the Advisory 
Council, after careful review and discussion, has made the requested change to 
the text."

Feedback is encouraged during the Last Call period. All comments should be 
provided to the Public Policy Mailing List. This Last Call period will expire 
on 10 November 2017. After Last Call, the AC will conduct their Last Call 
review.

The full text is below and available at:
https://www.arin.net/policy/proposals/

The ARIN Policy Development Process is available at:
https://www.arin.net/policy/pdp.html

Regards,

Sean Hopkins
Policy Analyst
American Registry for Internet Numbers (ARIN)



AC's Statement of Conformance with ARIN's Principles of Internet Number 
Resource Policy:

This proposal is technically sound and enables fair and impartial number policy 
for easier IPv6 Registrations. The staff and legal review noted a single 
clarification issue which has been addressed. There is ample support for the 
proposal on PPML and no concerns have been raised by the community regarding 
the proposal.

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 
"assignment containing a /64 or more addresses" and change to "re-allocation, 
reassignment containing a /47 or more addresses, or subdelegation of any size 
that will be individually announced,”

and

2) Alter section 6.5.5.2. "Assignments visible within 7 days" of the NRPM to 
strike the text "4.2.3.7.1" and change to “6.5.5.1"

and

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

and

4) Add new section 6.5.5.4  "Registration Requested by Recipient" of the NRPM, 
to read: "If the downstream recipient of a static assignment of /64 or more 
addresses requests publishing of that assignment in ARIN's registration 
database, the ISP shall register that assignment as described in section 
6.5.5.1."

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.
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