Hi Albert,

As a practical matter, I don’t think the NRPM overrides your ability to 
terminate your contract with ARIN should that become a business requirement.

Do you have alternative language to suggest that is clear, concise, and 
preserves the intent of narrowly boxing in nano-allocations for the tiniest of 
providers with IPv4 rather than incenting undersizing IPv6 allocations?  
Remember that the whole reason for the default /32 allocation is that we wish 
for IPv6 allocations to be the polar opposite of IPv4 slow-start - a 
one-and-done approach that minimizes both unnecessary routing table growth and 
the need to come back to ARIN for more space.

Thanks,

-r




> On Jul 21, 2020, at 11:26 AM, [email protected] wrote:
> 
> I have a problem with this language:
> 
> "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."
> 
> Downgrades include in my mind a return, and thus a downgrade to 0.  This 
> language seems to lock in anyone who has ever requested IPv6 space.
> 
> Does this make a request for IPv6 space from ARIN like the Hotel California, 
> where you can never leave....
> 
> If I were one of those ISP's with a /24 of IPv4, and I took the minimum 
> allocation of IPv6 which raised my fees to $500 from $250, does this language 
> make me continue to pay $500/yr even if I decide to return all my IPv6 
> resources to ARIN, and either get IPv6 space from my upstream or forgo use of 
> IPv6?
> 
> Albert Erdmann
> Network Administrator
> Paradise On Line Inc.
> 
> 
> On Tue, 21 Jul 2020, ARIN wrote:
> 
>> On 16 July 2020, the ARIN Advisory Council (AC) advanced the following Draft 
>> Policy to Recommended Draft Policy status:
>> 
>> ARIN-2020-3: IPv6 Nano-allocations
>> 
>> The text of the Recommended Draft Policy is below, and may also be found at:
>> 
>> https://www.arin.net/participate/policy/drafts/2020_3/
>> 
>> You are encouraged to discuss all Recommended Draft Policies on PPML prior 
>> to their presentation at the next ARIN Public Policy Consultation (PPC). 
>> PPML and PPC discussions are invaluable to the AC when determining community 
>> consensus.
>> 
>> 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
>> 
>> 
>> 
>> Recommended Draft Policy ARIN-2020-3: IPv6 Nano-allocations
>> 
>> AC Assessment of Conformance with the Principles of Internet Number Resource 
>> Policy:
>> 
>> Recommended Draft Policy ARIN-2020-3 provides for small IPv6 allocations to 
>> ISPs. This policy would allow the smallest ISP organizations to obtain a /40 
>> of IPv6 addresses. This recommended draft is technically sound, supported by 
>> the community and enables fair and impartial administration of number 
>> resources by providing the smallest organizations the opportunity to obtain 
>> an IPv6 allocation without a fee increase under the current fee schedule.
>> 
>> 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.
>> 
>> Timetable for Implementation: Immediate
>> 
>> 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.
>> 
>> _______________________________________________
>> ARIN-PPML
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> _______________________________________________
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