Clarifications of Sub-Assignments

Original Language Español Date Published 20/03/2018 Last Modified 11/11/2018
Last Call for Comments Period Does not apply Date Ratified Does not apply Implementation Date Does not apply
Status Under discussion Download TXT PDF XML DOCX
See other versions 1.0 2.0 3.0 4.0 5.0 (compare)

Authors

Name: Jordi Palet Martinez
Email: jordi.palet@consulintel.es
Organization: The IPv6 Company

Proposal Data

Policy Type: LACNIC
Id: LAC-2018-7
Last version: 5
Presentations:

Summary

The IPv4 policy on direct assignments by LACNIC to end users addresses sub-delegations (2.3.3.4) and specifically prohibits sub-delegating to third parties.

The IPv6 policy contains no such explicit prohibition, except in the case of micro-assignments (LACNIC shall not make micro-assignments, 4.5.5).

However, section 1.9 “Definitions” – which applies to all LACNIC policies – explicitly prohibits such assignments, stating that “Assignments... are not to be sub-assigned to other parties.”

This proposal seeks to clarify the text of the IPv6 policy in this regard and better define the concept, particularly considering new uses for IPv6 (RFC 8273).

It also clarifies that the use of sub-assignments for ISPs, datacenters and similar organizations is not allowed.

Finally, in Spanish, prefixes (e.g., sub, micro, etc.) should not be hyphenated. The policy Policy Manual, however, contains cases where they are hyphenated and others where they are not. The proposal seeks to harmonize the Spanish spelling of the Manual, removing all unnecessary hyphens.

Rationale

When the policy was designed, the concept of assignments/sub-assignments did not consider a practice that is very common in IPv4 and that is replicated and even amplified in IPv6: the use of IP addresses for point-to-point links or VPNs.

In the case of IPv4, the use of NAT is widespread, so there are no implications. However, institutions not using NAT have the same problem as in IPv6.

In the case of IPv6, instead of unique addresses, the use of unique prefixes (/64) is increasingly common.

Likewise, the policy failed to consider the use of IP addresses in hotspots (when these are not ISPs, e.g., when they are associations or community networks), the use of IP addresses by guests or employees (Bring Your Own Device, BYOD), and other similar cases.

Another example is the case of an end user who hires another company to provide certain services for which they must deploy their own devices, including their own servers, network equipment, etc. For example, a security surveillance service might require their clients to provide their own cameras, their own recording systems, and even their own firewalls and /or their own router for a dedicated VPN, etc. Of course, in many cases, this video surveillance system may require using the end user's address space.

Finally, the IETF has recently approved the use of a unique /64 prefix per interface/host (RFC8273) instead of a unique address. This, for example, allows users to connect to a hotspot, receive a /64 such that they are “isolated” from other users (for reasons of security, regulatory requirements, etc.) and they can also use multiple virtual machines on their devices with a unique address for each one (within the same /64).

In addition, hyphenation of prefixes is used in parts of the Spanish version of the Manual (“-sub”, “-micro” and others). The idea is to harmonize the spelling.

Text

Current text:

1.9 Assignments
To assign means to delegate address space to an end user, to be specifically used within the Internet infrastructure said end user operates. Assignments must only be made for specific purposes documented by specific organizations, and are not to be sub-assigned to other parties.

New text:

1.9 Assignments
To assign means to delegate address space to an end user, to be exclusively used within the infrastructure operated by said end user, as well as for interconnection purposes.

The assigned address space must only be used by the original recipient of the assignment, as well as for third-party devices provided they are operating within said infrastructure.

Therefore, sub-assignments to third parties outside said infrastructure (for example, the use of end-user assignments for ISPs or similar clients) and providing addresses to third parties in data centers (and others) are not allowed.

To avoid duplications and confusion, the last sentence of the first paragraph of section 2.3.3.4 (Assignments to End-Users) is deleted: “...but not for sub-delegation outside their organization.”

To avoid duplications and confusion, the last paragraph of section 4.5.5 (Micro-Assignments in IPv6) is deleted: “Organizations receiving micro-assignments shall not sub-assign these IP addresses.”

Likewise, LACNIC staff will harmonize the spelling (hyphenation) of words beginning with the prefixes “micro”, “sub” and others throughout the Spanish version of the manual.

Additional Information

-

Timetable

Immediate implementation

References

A similar proposal was discussed in the RIPE region and the change was approved, although there is no consensus regarding the changes specified in this proposal, as the texts are different. However, a version equivalent to this proposal is under discussion. Likewise, equivalent texts are being discussed in the AfrtiNIC and APNIC regions

Public Comments by LACNIC Staff

LACNIC STAFF´S IMPACT ANALYSIS - Proposal LAC-2018-7 - version 5

LACNIC Staff's Interpretation of the Proposal
---------------------------------------------

Applicability
------------
This proposal would apply to the analysis of initial requests for IPv6 and IPv4 blocks by End Users.

Modifications to the current text
---------------------------------
The Policy Manual would be modified as follows:

• Modification of Section 1.9. Assign.
• The last sentence of Section 2.3.3.4. Assignments to End Users would be eliminated.
• The last item of section 4.5.5. IPv6 Micro-Assignments would be eliminated.
• The hyphenation (spelling) of the Spanish version of the manual would be corrected.

LACNIC Staff Comments:
------------------------
• Regarding the current text of this proposal:
- It redefines the term “assign” so that to assign would now mean to delegate address space to an end user for its use exclusively within their own infrastructure or for interconnection purposes, instead of for its use in their Internet infrastructure.
- Therefore, sub-assignments to third parties outside this infrastructure would not be allowed.

• The new version takes into account the staff's recommendations on considering the text in Sections 1.9. Assign and 2.3.3.4. Assignments to End Users.

Impact of the policy on the registration system and address management
-------------------------------------------------------------------------
This proposal would not require any changes to the registration system.

LACNIC STAFF´S IMPACT ANALYSIS - Proposal LAC-2018-7 - version 3

LACNIC Staff's Interpretation of the Proposal
---------------------------------------------
Applicability
------------
This proposal would apply to initial IPv6 assignments to end users.

Modifications to the current text
--------------------------------
The Policy Manual would be modified as follows:

• New paragraph after existing paragraph 4.5.4. (Direct Assignments to End Sites).

The same paragraph after the last paragraph of 4.5.5. (IPv6 Micro-Assignments).

Providing address space to third-party devices, including addresses for point-to-point links, and/or providing non-permanent address space to third parties for use in a network managed and operated by the original recipient of the assignment will not be considered a sub-assignment.

Providing address space for (semi-) permanent connectivity services, such as broadband services, is still considered a sub-assignment.

LACNIC Staff Comments
-------------------------
LACNIC understands that sub-assignments will not be considered for the cases mentioned in the text.

In addition, the following concepts are observed in the manual:
1.9 Assign
To assign means to delegate address space to an end user, for specific use within the Internet infrastructure they operate. Assignments must only be made for specific purposes documented by specific organizations and are not to be sub-assigned to other parties.

2.3.3.4. Assignments to End Users
LACNIC shall assign IPv4 address blocks to end users requiring IPv4 address space for internal use, for the operation of their networks, but not for sub-delegation outside their organization.

Therefore, LACNIC understands that with this statement the end user could assign IPv6 space in specific conditions, but there could be cases in which it is not clear which section apply 1.9 and 2.3.3.4 (currently in the manual) or the text of the new proposal, to determine if sub-allocations would be allowed or not.

Impact of the policy on the registration system and address management
-------------------------------------------------------------------------
This proposal would not require any changes to the registration system.

LACNIC STAFF´S IMPACT ANALYSIS - Proposal LAC-2018-7 - version 1

LACNIC Staff's Interpretation of the Proposal
---------------------------------------------
Applicability
------------
This proposal would apply to initial IPv6 assignments to end users.

Modifications to the current text
--------------------------------
The Policy Manual would be modified as follows:

• Addition of the following paragraph in sections 4.5.4 (Direct Assignments to End Sites) and 4.5.5 (IPv6 Micro-Assignments):

The fact that a unique address or even a unique /64 prefix is non-permanently provided to third parties, on a link operated by the original receiver of the assignment, shall not be considered a sub-assignment. This includes, for example, guests or employees (devices or servers), hotspots and point-to-point links or VPNs.

The provision of addressing for permanent connectivity or broadband services is still considered a sub-assignment and is therefore not allowed. Only the addressing of the point-to-point link itself can be permanent and that addressing can't be used (neither directly or indirectly) for the actual communication.

LACNIC Staff Comments
-------------------------
No negative impacts have been observed.

Impact of the policy on the registration system and address management
-------------------------------------------------------------------------
This proposal would not require any changes to the registration system.

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