While I support this in principle, what is to prevent someone from violating the
intent by getting a /40 and assigning /56's to 40,000 customers, instead of
/48's to no more than 250 customers?
On 6/23/2020 10:24 AM, ARIN wrote:
The following Draft Policy has been revised:
* ARIN-2020-3: IPv6 Nano-allocations
Revised text is below and can be found at:
https://www.arin.net/participate/policy/drafts/2020_3/
You are encouraged to discuss all Draft Policies on PPML. The AC will evaluate
the discussion in order to assess the conformance of this Draft Policy with
ARIN's Principles of Internet number resource policy as stated in the Policy
Development Process (PDP). Specifically, these principles are:
* Enabling Fair and Impartial Number Resource Administration
* Technically Sound
* Supported by the Community
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 (ARIN)
Draft Policy ARIN-2020-3: IPv6 Nano-allocations
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.
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.
Timetable for implementation: Immediate
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John Santos
Evans Griffiths & Hart, Inc.
781-861-0670 ext 539
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