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Draft Policies and Proposals

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

Under discussion

 
Discussion Tracking
Mailing List:
Formal introduction on PPML on 23 May 2017

Origin - ARIN-prop-240

Draft Policy - 23 May 2017

Revised - 7 June 2017

Revised - 21 July 2017

Revised - 15 August 2017

Revised - 22 August 2017

Revised - 18 September 2017

Public Policy Mailing List
ARIN Public Policy Meeting:
ARIN Advisory Council:

AC Shepherds:
Leif Sawyer, Chris Tacit

ARIN Board of Trustees:
Revisions Implementation

Version Date: 18 September 2017

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 should 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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Earlier Version

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Version Date: 22 August 2017

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 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 must 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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ARIN STAFF & LEGAL ASSESSMENT

Draft Policy ARIN-2017-05

Improved IPv6 Registration Requirements

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

Date of Assessment: 30 August 2017

 ___

1.  Summary (Staff Understanding)

 Draft Policy 2017-05 will change the requirement for IPv6 registration from /64 or more addresses to a /47 or more addresses, or sub-delegation of any size that will be individually announced. It corrects the pointer in 6.5.5.2 to point to 6.5.5.1 instead of 4.2.3.7.1 and adds a new requirement stating that a downstream recipient of a /64 or more addresses may request the publishing of their reassignment information by their upstream provider. The upstream provider must publish the information upon request of their customer.

 ___

2.  Comments

 A.  ARIN Staff Comments:

 * The change from a "/64 or more addresses" to a "/47 or more addresses, or sub-delegation of any size," is a straightforward change that could be implemented immediately as written.

 * The change to the pointer is an easy fix to the NRPM

 * If the wording in 6.5.5.4 is meant as a requirement for the ISP to register the reassignment as requested by the downstream then this may be out of scope for the NRPM as ARIN has no way to enforce it. Suggest changing the "…must publish…" to "…should publish…" or other wording that would indicate it is a desirable action on the part of the ISP.  If it is meant only that if the ISP agrees to register it, that it must register it in accordance with the guidelines in 6.5.5.1 then it could be implemented if the wording is clarified. As written it is unclear what the intent is.

 -----

B.  ARIN General Counsel – Legal Assessment

 * There are no material legal issues regarding this proposal.

___

3.  Resource Impact

Implementation of this policy would have minimal resource impact. It is estimated that implementation would occur within 3 months after ratification by the ARIN Board of Trustees. The following would be needed in order to implement:

 * Updated guidelines and internal procedures

 * Staff training

 ___

4. Proposal / Draft Policy Text Assessed

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

Version Date: 22 August 2017

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 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 must 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.

##### END

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Earlier Version

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Version Date: 15 August 2017

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 subdelegation 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"

and

3) Add new section 6.5.5.4 "Downstream Registration Requests" to the NRPM that reads "If the downstream recipient of a netblock ( a /64 or more addresses) requests publishing in ARIN's registration database, the ISP must register the netblock, regardless of size."

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.

##########

Earlier Version

##########

Version Date: 21 July 2017

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.

##########

Earlier Version

##########

Version Date: 7 June 2017

Problem Statement:

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 or less (CGnat), which do not trigger any ARIN registration requirement when using IPv4. This is NOT true when these same exact customers use IPv6.

Currently, 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.

IPv6 assignments are therefore treated stricter than IPv4 assignments. Policy should either treat both protocols the same, or provide incentive for the IPv6 future. A typical ISP serving residential and small business customers with both IPv4 and IPv6 would typically provide the following assignments to each customer site: /32 (one IP) of IPv4 and a /64 (one network) of IPv6. Under the current policy, that small network customer is exempt from registration for their IPv4 assignment, but the ISP would be required to register ALL IPv6 customers, even those of this smallest network size.

In actual fact, most ISP's that are providing their customers with a /64 or more of IPv6 space are not in fact registering this fact with ARIN, even though 6.5.5.1 clearly requires this.

It is my belief that these residential and small business customers should not require registration if they did not require registration for the same size IPv4 network, including routers with Vlan and other security support. and thus I propose to make the standard for registration only those customers that have more than 16 IPv6 /64 networks. This would treat IPv6 slightly better than IPv4, and provide additional encouragement for adoption.

Policy statement:

Amend 6.5.5.1 of the policy manual to strike "/64 or more" and change to "more than a /60".

Comments:

a.    Timetable for implementation:

Policy should be adopted as soon as possible, as the new administrative burden of 100% customer registration of IPv6 customers is unreasonable, when such is not required for those customers receiving only IPv4 connections. IPv6 should not be more burdensome than the equivalent IPv4 network size.

b.    Anything else:

The specific sizes chosen set the point of registration for each site to more than 16 networks or addresses, so that those with 16 or less IPv6 networks (/60)  have no registration requirement. This change will result in both protocols being treated exactly the same, and removes residential and small business accounts from any registration requirement with ARIN, and the burden that will create for all ISP's.

There are those that might argue that a residental customer will never have a need for more than a /64 of IPv6. Clearly this is false in an IOT and/or wireless world, as many routers already provide a separate address range for wired vs wireless to prevent wired hacking via the wireless space, and also may provide a guest wireless SSID apart from the one provided to the regular users of that same network. Such separation in the IPv4 world is currently done in RFC1918 space using NAT. In IPv6, the equivalent must be done with different /64 blocks. Since good security practices require use at least 2 /64 blocks for wireless and/or IOT isolation, this would require a minimum of a /60 of IPv6 space or up to 16 networks or vlans, an amount that is consistent with a residential or small business network. This type network does not trigger registration under the current IPv4 policy, and its equal should not trigger registration with ARIN based on the current IPv6 policy as is currently the case, and thus, this policy needs to be changed.

##########

Earlier Version

##########

Version Date: 20 April 2017

Problem Statement:

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 or less (CGnat), which do not trigger any ARIN registration requirement when using IPv4. This is NOT true when these same exact customers use IPv6.

Currently, 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.

IPv6 assignments are therefore treated stricter than IPv4 assignments. The policy should treat both protocols the same. A typical ISP serving residential and small business customers with both IPv4 and IPv6 would typically provide the following assignments to each customer site: /32 (one IP) of IPv4 and a /64 (one network) of IPv6. Under the current policy, that small network customer is exempt from registration for their IPv4 assignment, but the ISP would be required to register ALL IPv6 customers, even those of this smallest network size.

In actual fact, most ISP's that are providing their customers with a /64 or more of IPv6 space are not in fact registering this fact with ARIN, even though 6.5.5.1 clearly requires this.

It is my belief that these residential and small business customers should not require registration if they did not require registration for the same size IPv4 network, including routers with Vlan and other security support. and thus I propose to make the standard for registration only those customers that have more than 16 IPv4 addresses or 16 IPv6 /64 networks. This would treat IPv6 the same as IPv4.

Policy statement:

Amend 4.2.3.7.1 of the policy manual to strike "/29 or more" and change to "more than a /28".

Amend 6.5.5.1 of the policy manual to strike "/64 or more" and change to "more than a /60".

Comments:

a.    Timetable for implementation:

Policy should be adopted as soon as possible, as the new administrative burden of 100% customer registration of IPv6 customers is unreasonable, when such is not required for those customers receiving only IPv4 connections. IPv6 should not be more burdensome than the equivalent IPv4 network size.

b.    Anything else:

The specific sizes chosen set the point of registration for each site to more than 16 networks or addresses, so that those with 16 or less networks (IPv6 /60) or addresses (IPv4 /28) have no registration requirement. This change will result in both protocols being treated exactly the same, and removes residential and small business accounts from any registration requirement with ARIN, and the burden that will create for all ISP's.

There are those that might argue that a residental customer will never have a need for more than a /64 of IPv6. Clearly this is false in an IOT and/or wireless world, as many routers already provide a separate address range for wired vs wireless to prevent wired hacking via the wireless space, and also may provide a guest wireless SSID apart from the one provided to the regular users of that same network. Such separation in the IPv4 world is currently done in RFC1918 space using NAT. In IPv6, the equivalent must be done with different /64 blocks. Since good security practices require use at least 2 /64 blocks for wireless and/or IOT isolation, this would require a minimum of a /60 of IPv6 space or up to 16 networks or vlans, an amount that is consistent with a residential or small business network. This type network does not trigger registration under the current IPv4 policy, and its equal should not trigger registration with ARIN based on the current IPv6 policy as is currently the case, and thus, this policy needs to be changed.

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