[address-policy-wg] Re: [policy-announce] 2006-02 New Policy Proposal (IPv6 Address Allocation and Assignment Policy)

Jordi,

Unlurking from the sidelines and speaking only for myself, some  
comments on your proposal:

> It is clear that there are small Internet Service providers (ISPs)  
> that do not currently have 200 customers, consequently is not  
> feasible for them to make “at least 200 /48” assignments in two  
> years. It is, however, unfair that these ISPs have no access to  
> IPv6 address space.

I'm confused.  According to RIPE-267 (section 5.1.1), the existing  
policy doesn't require requesters to have 200 customers.  All that it  
requires is that an LIR not be an end site, provide IPv6  
connectivity, and "have a plan for making at least 200 /48  
assignments to other organisations within two years."

Note it says "a plan".  An organization incapable of coming up with  
_a plan_ to allocate 200 /48s has more significant problems than not  
having IPv6 space.

> In some cases, organisations may have a small number of sites, but  
> still need their own block so that they can avoid future  
> renumbering, if they change their upstream provider or identify a  
> need to become Multihomed.

Can you identify an organization that does not want to avoid  
renumbering or which might not identify a need to be multihomed?

> b) plan to provide IPv6 connectivity to other organisations or to  
> its own/related departments/entities/sites to which it will assign / 
> 48s by advertising that connectivity through a single aggregated  
> address allocation
>
> and
> c) have a plan for making a reasonable number of /48 assignments  
> within two years

I have a couple of LANs at my house.  A /48 for each LAN sounds  
reasonable to me.  Does that justify an IPv6 /32?

More seriously, impositions of subjective evaluations like figuring  
out what is "reasonable" are generally things to be avoided.  Also,  
vagueness of terms such as "own/related departments/entities/sites"  
are just begging for abuse.  A person is an entity.  Should an  
organization with a "reasonable" number of people justify a /32?

> a. Arguments Supporting the Proposal
...
> The difficulty encountered in receiving IPv6 address space by some  
> big entities that have a need to use IPv6 is a clear barrier for  
> its deployment.

The lack of transparent renumbering, scalable multi-homing, or IPv6- 
only applications is a much more significant barrier to deployment.   
You are attempting to fix a technology problem by hacking policy in a  
way that would exacerbate the technology problem.  This seems  
suboptimal to me.  But that's probably just me.

> By setting up this policy, we would avoid creating an unfair  
> situation among different RIR service regions. Other RIRs have  
> already modified the original IPv6 common policy to avoid these  
> barriers.

http://www.bumperart.com/ProductDetails.aspx? 
SKU=2004011203&productID=523

> We could possibly say that an arbitrary number of sites in order to  
> qualify for an allocation could be considered illegal in some  
> countries. The RIPE community cannot set policies that could prove  
> unlawful as this could have important implications.

If you have documentary proof of potential illegality, it would  
probably be worthwhile to provide it.  If not, this sentence is  
merely FUD and should be stricken.  Even if you do have evidence that  
some country's law is being broken, it isn't clear to me how that  
should affect RIPE policy.  For example, I believe a country in the  
RIPE region has passed a law (or is in the process of passing a law)  
that requires IP address space to be allocated by that country's  
government.  Should RIPE therefore only allocate address space to  
governments?

> b. Arguments Opposing the Proposal
>
> One possible effect of this proposal would be a growth of global  
> routing tables. This is only to be expected when new allocations  
> are made possible under this proposal.

Too simplistic.  This proposal, like all PI oriented allocation  
policies, changes routing scalability from O(number of service  
providers) to O(number of organizations).  Pretending this is "only  
to be expected" is simply wrong.  You can argue that technology will  
permit O(number of organizations) in the default free routing system,  
but that is a different argument than "it is to be expected".

> Opposing arguments should avoid being unfair to smaller ISPs that  
> could not justify a fixed number of assignments.

Is it unfair that carriers that fly Boeing 747s get more revenues  
than carriers that fly Saab 340s?

A fixed number of assignments was an attempt to quantify a  
"reasonable" level of aggregation.  Given the routing technology used  
in IPv6 depends on aggregatability to scale, there is an implicit  
assumption that those who cannot provide aggregation of leaves should  
themselves become a leaf under some other aggregator.

> Such a policy could be seen as irrational

"In an insane world the sane man must appear insane" -- Spock

> and might be comparable with imposing a similar requirement for  
> IPv4 address space allocations, which the community would be  
> unlikely to accept.

In at least one region, initial allocations of PI IPv4 required  
demonstration of utilization of half the initial PI allocation, so in  
essence, there was an implicit requirement to meet a fixed number to  
justify an allocation.  Of course, this wasn't in the RIPE region,  
but weren't you the one arguing that the other regions have a similar  
policy to what you propose as justification for your proposal?

Rgds,
-drc