Discussion Paper: Provider Independent Assignment Policy

Problem Definition

A proposal for an amended PI assignment policy

1. Motivation

APNIC is frequently approached by organisations stating that they require an assignment of provider independent (PI) address space. The reasons most frequently cited include lack of IP address space available from upstream providers; plans to multihome; and a perception that PI space will provide redundancy and resilience for their site.

APNIC currently makes PI assignments to end users in one of two ways:

• Through the non-member assignment policy, which is open to any applicant (and involves a one-time fee payment of US$8,192).
• Through a request submitted by a current APNIC member on behalf of the applicant (in which case there is no direct charge to the member or applicant; however, any PI address space assigned is added to the member's total pool of address space from which membership categories are calculated). This is an informal policy.

Clearly there is a significant inconsistency between these two mechanisms for dealing with PI requests. So, in February 2000, at the APNIC meeting in Korea, APNIC presented the need for a clearer policy framework for this issue [ppt | pdf]

At that time there was no specific input from the community, but there was consensus that a change in policy was needed. Therefore, this proposal is submitted for discussion at the October meeting in Brisbane.

2. Background

CIDR promotes a hierarchical routing structure through provider aggregatable (PA) assignments to end-sites, which reduces pressure on the global routing table size.

Excessive use of PI assignments - where providers are asked to announce and route prefixes from outside their own PA allocated ranges - has the opposite effect, increasing the size of the global routing table.

More than 50% of today's routing table comprises /24 announcements and, contrary to expectation, this percentage appears to be increasing not decreasing. Currently, there are more than 50,000 /24 routes in the routing table compared to 5,840 /19s and 3,575 /20s.

Furthermore, in recent months, the rate of growth in the size of the routing table has increased. The number of entries has increased from 73,648 in February 2000 to 87,480 during September 2000. By comparison, in October 1999, the routing table held 64,019 prefixes (source: Philip Smith BGP Routing Analysis at http://thyme.apnic.net/ and Tony Bates' CIDR report). These figures represent a 36% increase in one year.

It is clearly the ISPs who determine what to route and how they choose to it. Allocation and assignment policies are not the only determinant of these routing statistics, but they do have a significant impact.

The response from APNIC members in 1997 was to recommend the non-member PI assignment policy be priced sufficiently high as to discourage applications.

Since the time of that decision, policy b) has been introduced, borrowed largely from the RIPE NCC.

3. Current status - RIR Policies

APNIC

As above. A member can request a PI assignment on behalf of a customer. The organisation must give a technical reason for the request, such as multihoming.

Alternatively, an organisation can request a PI assignment directly from APNIC once they have paid the non-member fee of US$8,192.

RIPE NCC

RIPE NCC only makes PI assignments through members on behalf of customers. The requesting organisation must give specific reasons to the member explaining why PI is required. There is no minimum assignment size and no cost to the member or end-user.

More information about this policy is available at http://www.ripe.net/ripe/docs/ripe-185.html

ARIN

The requesting organisation can apply to ARIN directly. The organisation must be multihomed and should have already efficiently utilised a /21 and demonstrate the need for /20 to be used within 3 months. The requesting organisation must agree to renumber from prior address space. No sub-assignments are permitted.

It is worth noting here that these conditions are very similar to the conditions imposed on ARIN members in order to qualify for an allocation directly from ARIN. An allocation to members is effectively a portable address block that will appear in the global routing table, as will the PI assignment under this policy.

ARIN has also defined exceptions to the policy in that they make assignments to "essential infrastructure", classified as gTLDs, ccTLDs, RIRs, and ICANN. Assignments are also made for exchange point infrastructure. However, in these exceptional cases, the assignment comes with terms and conditions, and must not be publicly routed on the Internet.

ARIN makes no PI assignments smaller than a /24.

All PI assignments attract a fee and recipients are required to sign a 'Registration Services Agreement'

More information on ARIN policies is available at http://www.arin.net/regserv/ip-assignment.html

4. Discussion and recommendations

This issue requires consideration on technical, administrative, and financial grounds.

4.1 Technical considerations

i) Does the size of site matter? If yes,

• Should PI assignments be available for end-user sites which are sufficiently large?
• If yes, what size should be considered large enough?
  APNIC proposes that PI assignments should be available, but in order to discourage growth in the /24 range, end-sites should be sufficiently large. "Sufficiently large" is defined as sites that have utilised a /21 from their upstream ISP or are able to demonstrate that they plan to use a /21 immediately (up to 3 months). It is proposed that the "minimum" assignment should be related to APNIC's "minimum allocation". In routing terms, there is no practical difference between a /20 assignment and a /20 allocation. Therefore sites that qualify under this policy should be able to demonstrate utilisation of a /20 in a year.

ii) Does the type of connectivity matter?

• Should it be mandatory that the organisation is multihomed and running BGP to at least two different upstream ISPs?
  APNIC proposes that organisations must be multihomed or plan to multihome within 3 months in order to qualify for a PI assignment. Singly-homed organisations should use address space from their upstream ISP. Organisations that are multihomed will inject prefixes into the global routing tables.

4.2 Administrative considerations

Currently, in the case of non-member resource assignments, there is no formal relationship or contract with APNIC, with the result that it is impossible to apply changes in resource management policies to historical assignments.

Furthermore, although APNIC has no formal link to the requesting organisation, APNIC is still required to provide services to them free of charge in the form of in-addr.arpa service and whois maintenance.

It is therefore recommended that the informal procedures of requesting PI address space through members is discontinued and that APNIC establishes a direct contractual relationship with end-users who request PI assignments.

4.3 Financial considerations

It is proposed that requesting organisations are charged a fee consistent with APNIC's existing fee structure, which has a minimum fee US$2,500 and an administration fee of US$1,000. However, under APNIC's taxation arrangements, fees from organisations that are not APNIC members are treated as taxable company income. Therefore, the non-member fee should include provision for taxation, which is estimated at 34%. A maintenance fee of 10% of the annual fee will also be charged.

In summary, the proposed fees are as follows:

5. Recommendations

APNIC is seeking feedback from the community in the development of a more consistent and equitable framework to address these issues

Based on the issues discussed in this paper, and drawing on the policy developed by ARIN, APNIC proposes that PI assignments should only be made subject to all of the following criteria:

• the requesting organisation must be multihomed or have plans to multihome within 3 months
• the requesting organisation must have used a /21 from its upstream provider or, if it is not yet multihomed then it must provide detailed plans to both multihome and use a /21 within 3 months
• the requesting organisation must provide detailed plans to use a /20 within one year
• the minimum assignment size is /20 (to be assigned from 202/7)
• the PI assignment must be routed as one aggregate and must not be further assigned to other organisations if they are not administratively related to that organisation
• a maintenance fee of 10% of the assignment fee will be payable each year

6. Implementation Proposal

6.1 Implementation date

It is proposed that APNIC implement a new policy 3 months after consensus has been reached. At that time, the existing 'non-member' IP address assignment procedures, both formal and informal, will be deprecated.

All necessary supporting documents will be prepared by APNIC before the implementation date. These will include a PI contract and a fee structure document. The existing 'end-user' address request form will be reviewed and modified accordingly. Every effort will be made to inform the community of the changes in advance of the changeover date through the APNIC web site and related mailing lists.

6.2 NIRs

There is an expectation that NIRs will implement the criteria for multihomed assignments outlined in this policy proposal. However, as only APNIC is authorised to make PI assignments from the APNIC address ranges (see section 7.12.1 of the APNIC policy document 'Policies for address space management in the Asia Pacific region'), NIRs will forward approved requests to APNIC for actual assignment from the 202/7 address ranges. It is expected that where NIRs offer this service contractual relationships will be established between the NIR and the requesting organisation.

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