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ARIN-prop-215 Modification to Criteria for IPv6 Initial End-User Assignments

ARIN-prop-215 Modification to Criteria for IPv6 Initial End-User Assignments

Proposal Originator: Gary T. Giesen

Date: 18 February 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).

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