Recommended Draft Policy ARIN-2015-1: Modification to Criteria for IPv6 Initial End-User Assignments [Archived]

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Status: Implemented 17 February 2016

Tracking Information

Discussion Tracking

Mailing List:

Formal introduction on PPML on 24 March 2015

Origin - ARIN-prop-215

Draft Policy - 24 March 2015

Recommended Draft Policy - 23 June 2015

Revised - 1 September 2015

Last Call - 14-28 October 2015

AC recommended Board adopt - 24 November 2015

Adopted, to be implemented - 8 January 2016

Implemented 17 February 2016

Public Policy Mailing List

ARIN Public Policy Meeting:

ARIN 35
ARIN PPC at NANOG 64
ARIN 36

ARIN Advisory Council:

AC Shepherds:
Scott Leibrand, David Huberman

ARIN Board of Trustees:

10 December 2015

Revisions:

Implementation:

Implemented 17 February 2016

Recommended Draft Policy ARIN-2015-1
Modification to Criteria for IPv6 Initial End-User Assignments

Date: 27 August 2015

AC’s assessment of conformance with the Principles of Internet Number Resource Policy:

ARIN-2015-1 enables fair and impartial number resource administration by providing a concrete threshold (13 active sites) under which end-user organizations who have a large number of potentially geographically dispersed sites, or sites with low subnet and/or user counts, can be reasonably assured of receiving IPv6 address space from ARIN. This proposal is technically sound, in that it retains reasonable thresholds on obtaining IPv6 assignments from ARIN in order to support the aggregation of Internet number resources in a hierarchical manner to the extent feasible. It has been well supported by the community on PPML and at the ARIN PPC at NANOG in San Francisco, where nearly everyone agreed that this was a step in the right direction. To the extent that some in the community desire even more relaxed IPv6 assignment policy, the AC encourages those community members to discuss on PPML and/or submit as additional policy proposals any further changes they would like to see.

Problem Statement:

Current policy for assignment to end users excludes a class of users whose costs to renumber would far exceed what current policy is designed to mitigate.

Current measures designed to minimize the economic cost of renumbering per NRPM 6.5.8.1 (Initial Assignment Criteria) are:

c. By having a network that makes active use of a minimum of 2000 IPv6 addresses within 12 months, or;
d. By having a network that makes active use of a minimum of 200 /64 subnets within 12 months, or;

These two measures fail to take into account end users who have a large number of potentially geographically dispersed sites, or sites with low subnet and/or user counts. The economic costs for this class of end user would likely far exceed the costs that 6.5.8.1 c. and d. are designed to mitigate.

While an end user could possibly apply (and receive an assignment) under 6.5.8.1 e. (“By providing a reasonable technical justification indicating why IPv6 addresses from an ISP or other
LIR are unsuitable”), it fails to provide a concrete threshold under which this class of end-user can be reasonably assured of receiving address space.

Without having the reasonable assurance of IPv6 address number resource continuity that a direct assignment allows, many smaller enterprises are unlikely to adopt IPv6 (currently perceived as
an already tenuous proposition for most users given current cost/benefit); or are likely to adopt technical measures (such as using ULA addressing + NAT66) that are widely held to be damaging to the IPv6 Internet.

Policy Statement:

Renumber NRPM 6.5.8.1 Initial Assignment Criteria subsection e. to f. and and insert a new subsection e. with the following text:

By having a contiguous network that has a minimum of 13 active sites within 12 months, or;

Comments:
a. Timetable for implementation: Immediate
b. General Comments:

  • The threshold of 13 sites was chosen based on NRPM 6.5.8.2, which specifies 13 sites as the minimum number of sites required to receive a /40 initial assignment, to attempt to provide a balance
    between the costs of carrying the prefix vs. the costs to the end-user in renumbering.

  • Further constraints were added in that the sites must be in a contiguous network, to further attempt to reduce the costs of carrying the prefix

  • By introducing this new threshold, we attempt to restore equivalency of number resources for those end-users whose economic costs to renumber are equal to that of other end-users who would qualify
    for a direct assignment under 6.5.8.1 c. and d.

c. Example:

Example of an end-user who would not qualify under 6.5.8.2 c. or d.:

  • 50 locations (IPVPN) spread across the country/continent
  • 10 staff per location (average; 500 total)
  • 20 devices per location (average; 1000 total)
  • 2 subnets (voice & data) per location (average, 100 total)
  • Not multihomed
  • Currently using RFC1918 IPv4 space + NAT

This end-user only benefits minimally from IPv6 multihoming as they are using an IPVPN, and multihoming provides benefit only for Internet transit, not within their IPVPN. As such requiring the end-user to multihome under NRPM 6.5.8.2 b. is wasteful.

This end user currently uses RFC1918 IPv4 address space + a relatively small amount of IPv4 GUA + NAT (currently accepted industry practice for IPv4). Changing providers involves only renumbering the small amount of IPv4 GUA. Forcing the end-user to acquire an IPv4 direct assignment under NRPM 6.5.8.2 a. in order to be able to get a direct IPv6 assignment is incredibly wasteful of a valuable and limited number resource. It also forces the customer occupy more routing table space, as now an IPv4 PI prefix must be routed in addition to an IPv6 PI prefix, instead of using IPv4 PA + IPv6 PI (where only space for an IPv6 PI prefix is required).

#####

ARIN STAFF ASSESSMENT

Draft Policy ARIN-2015-1
Modification to Criteria for IPv6 Initial End-User Assignments
https://www.arin.net/policy/proposals/2015_1.html

Date of Assessment: June 11, 2015

  1. Summary (Staff Understanding)
    This proposal would add a criteria item to 6.5.8.1 (Initial Assignment Criteria). Because each of the existing criteria items in that section can independently qualify an organization for IPv6 address space from ARIN, this new criteria item adds an additional qualification criteria. It makes it easier for some organizations to qualify, and does not make it more difficult for anyone. In particular, it creates a new criteria point that allows any end-user organization large enough to have 13 sites to immediately qualify for IPv6 address space from ARIN.
  1. Comments
    A. ARIN Staff Comments
    This proposal can be implemented as written. Minimal staff training and preparation would be needed to implement this if it were to become policy. We see no negative impacts.

B. ARIN General Counsel – Legal Assessment
Counsel sees no material legal issues in this policy.

  1. Resource Impact
    This policy would require minimal staff training and preparation. We see no negative impacts.
  1. Proposal / Draft Policy Text Assessed

Draft Policy ARIN-2015-1
Modification to Criteria for IPv6 Initial End-User Assignments

Date: 24 March 2015

Problem Statement:
Current policy for assignment to end users excludes a class of users whose costs to renumber would far exceed what current policy is designed to mitigate.

Current measures designed to minimize the economic cost of renumbering per NRPM 6.5.8.1 (Initial Assignment Criteria) are:

c. By having a network that makes active use of a minimum of 2000 IPv6 addresses within 12 months, or;
d. By having a network that makes active use of a minimum of 200 /64 subnets within 12 months, or;

These two measures fail to take into account end users who have a large number of potentially geographically dispersed sites, or sites with low subnet and/or user counts. The economic costs for this class of end user would likely far exceed the costs that 6.5.8.1 c. and d. are designed to mitigate.

While an end user could possibly apply (and receive an assignment) under 6.5.8.1 e. (“By providing a reasonable technical justification indicating why IPv6 addresses from an ISP or other
LIR are unsuitable”), it fails to provide a concrete threshold under which this class of end-user can be reasonably assured of receiving address space.

Without having the reasonable assurance of IPv6 address number resource continuity that a direct assignment allows, many smaller enterprises are unlikely to adopt IPv6 (currently perceived as
an already tenuous proposition for most users given current cost/benefit); or are likely to adopt technical measures (such as using ULA addressing + NAT66) that are widely held to be damaging to the IPv6 Internet.

Policy Statement:

Replace the contents of NRPM 6.5.8.1 with:

6.5.8.1. Initial Assignment Criteria

Organizations may justify an initial assignment for addressing devices directly attached to their own network infrastructure, with an intent for the addresses to begin operational use within 12 months, by meeting one of the following criteria:

a. Having a previously justified IPv4 end-user assignment from ARIN or one of its predecessor registries, or;
b. Currently being IPv6 Multihomed or immediately becoming IPv6 Multihomed and using an assigned valid global AS number, or;
c. By having a network that makes active use of a minimum of 2000 IPv6 addresses within 12 months, or;
d. By having a network that makes active use of a minimum of 200 /64 subnets within 12 months, or;
e. By having a contiguous network that has a minimum of 13 active sites within 12 months, or;
f. By providing a reasonable technical justification indicating why IPv6 addresses from an ISP or other LIR are unsuitable.

Examples of justifications for why addresses from an ISP or other LIR may be unsuitable include, but are not limited to:

> An organization that operates infrastructure critical to life safety or the functioning of society can justify the need for an assignment based on the fact that renumbering would have a broader than expected impact than simply the number of hosts directly involved. These would include: hospitals, fire fighting, police, emergency response, power or energy distribution, water or waste treatment, traffic management and control, etc.
> Regardless of the number of hosts directly involved, an organization can justify the need for an assignment if renumbering would affect 2000 or more individuals either internal or external to the organization.
> An organization with a network not connected to the Internet can justify the need for an assignment by documenting a need for guaranteed uniqueness, beyond the statistical uniqueness provided by ULA (see RFC 4193).
> An organization with a network not connected to the Internet, such as a VPN overlay network, can justify the need for an assignment if they require authoritative delegation of reverse DNS.

Comments:
a. Timetable for implementation: Immediate
b. General Comments:

  • Changes to NRPM 6.5.8.1 are to renumber subsection e. to f. and and insert a new subsection e. with the following text:

“By having a contiguous network that has a minimum of 13 active sites within 12 months, or;

  • The threshold of 13 sites was chosen based on NRPM 6.5.8.2, which specifies 13 sites as the minimum number of sites required to receive a /40 initial assignment, to attempt to provide a balance
    between the costs of carrying the prefix vs. the costs to the end-user in renumbering.

  • Further constraints were added in that the sites must be in a contiguous network, to further attempt to reduce the costs of carrying the prefix

  • By introducing this new threshold, we attempt to restore equivalency of number resources for those end-users whose economic costs to renumber are equal to that of other end-users who would qualify
    for a direct assignment under 6.5.8.1 c. and d.

c. Example:

Example of an end-user who would not qualify under 6.5.8.2 c. or d.:

  • 50 locations (IPVPN) spread across the country/continent
  • 10 staff per location (average; 500 total)
  • 20 devices per location (average; 1000 total)
  • 2 subnets (voice & data) per location (average, 100 total)
  • Not multihomed
  • Currently using RFC1918 IPv4 space + NAT

This end-user only benefits minimally from IPv6 multihoming as they are using an IPVPN, and multihoming provides benefit only for Internet transit, not within their IPVPN. As such requiring the end-user to multihome under NRPM 6.5.8.2 b. is wasteful.

This end user currently uses RFC1918 IPv4 address space + a relatively small amount of IPv4 GUA + NAT (currently accepted industry practice for IPv4). Changing providers involves only renumbering the small amount of IPv4 GUA. Forcing the end-user to acquire an IPv4 direct assignment under NRPM 6.5.8.2 a. in order to be able to get a direct IPv6 assignment is incredibly wasteful of a valuable and limited number resource. It also forces the customer occupy more routing table space, as now an IPv4 PI prefix must be routed in addition to an IPv6 PI prefix, instead of using IPv4 PA + IPv6 PI (where only space for an IPv6 PI prefix is required).

Earlier version:

Recommended Draft Policy ARIN-2015-1
Modification to Criteria for IPv6 Initial End-User Assignments

Date: 23 June 2015

AC’s assessment of conformance with the Principles of Internet Number Resource Policy:

ARIN-2015-1 enables fair and impartial number resource administration by providing a concrete threshold (13 active sites) under which end-user organizations who have a large number of potentially geographically dispersed sites, or sites with low subnet and/or user counts, can be reasonably assured of receiving IPv6 address space from ARIN. This proposal is technically sound, in that it retains reasonable thresholds on obtaining IPv6 assignments from ARIN in order to support the aggregation of Internet number resources in a hierarchical manner to the extent feasible. It has been well supported by the community on PPML and at the ARIN PPC at NANOG in San Francisco, where nearly everyone agreed that this was a step in the right direction. To the extent that some in the community desire even more relaxed IPv6 assignment policy, the AC encourages those community members to discuss on PPML and/or submit as additional policy proposals any further changes they would like to see.

Problem Statement:

Current policy for assignment to end users excludes a class of users whose costs to renumber would far exceed what current policy is designed to mitigate.

Current measures designed to minimize the economic cost of renumbering per NRPM 6.5.8.1 (Initial Assignment Criteria) are:

c. By having a network that makes active use of a minimum of 2000 IPv6 addresses within 12 months, or;
d. By having a network that makes active use of a minimum of 200 /64 subnets within 12 months, or;

These two measures fail to take into account end users who have a large number of potentially geographically dispersed sites, or sites with low subnet and/or user counts. The economic costs for this class of end user would likely far exceed the costs that 6.5.8.1 c. and d. are designed to mitigate.

While an end user could possibly apply (and receive an assignment) under 6.5.8.1 e. (“By providing a reasonable technical justification indicating why IPv6 addresses from an ISP or other
LIR are unsuitable”), it fails to provide a concrete threshold under which this class of end-user can be reasonably assured of receiving address space.

Without having the reasonable assurance of IPv6 address number resource continuity that a direct assignment allows, many smaller enterprises are unlikely to adopt IPv6 (currently perceived as
an already tenuous proposition for most users given current cost/benefit); or are likely to adopt technical measures (such as using ULA addressing + NAT66) that are widely held to be damaging to the IPv6 Internet.

Policy Statement:

Replace the contents of NRPM 6.5.8.1 with:

6.5.8.1. Initial Assignment Criteria

Organizations may justify an initial assignment for addressing devices directly attached to their own network infrastructure, with an intent for the addresses to begin operational use within 12 months, by meeting one of the following criteria:

a. Having a previously justified IPv4 end-user assignment from ARIN or one of its predecessor registries, or;
b. Currently being IPv6 Multihomed or immediately becoming IPv6 Multihomed and using an assigned valid global AS number, or;
c. By having a network that makes active use of a minimum of 2000 IPv6 addresses within 12 months, or;
d. By having a network that makes active use of a minimum of 200 /64 subnets within 12 months, or;
e. By having a contiguous network that has a minimum of 13 active sites within 12 months, or;
f. By providing a reasonable technical justification indicating why IPv6 addresses from an ISP or other LIR are unsuitable.

Examples of justifications for why addresses from an ISP or other LIR may be unsuitable include, but are not limited to:

> An organization that operates infrastructure critical to life safety or the functioning of society can justify the need for an assignment based on the fact that renumbering would have a broader than expected impact than simply the number of hosts directly involved. These would include: hospitals, fire fighting, police, emergency response, power or energy distribution, water or waste treatment, traffic management and control, etc.
> Regardless of the number of hosts directly involved, an organization can justify the need for an assignment if renumbering would affect 2000 or more individuals either internal or external to the organization.
> An organization with a network not connected to the Internet can justify the need for an assignment by documenting a need for guaranteed uniqueness, beyond the statistical uniqueness provided by ULA (see RFC 4193).
> An organization with a network not connected to the Internet, such as a VPN overlay network, can justify the need for an assignment if they require authoritative delegation of reverse DNS.

OUT OF DATE?

Here in the Vault, information is published in its final form and then not changed or updated. As a result, some content, specifically links to other pages and other references, may be out-of-date or no longer available.