ISPAI response to ICANN on proposed IPv6 address allocation policy

["ispai" <ispai@xxxxxxxxxxxxx>]

Hi,


ISP Association of India (www.ispai.in) is the representative body of Internet 
Service Providers (ISPs) in India and is a registered non-profit society and 
works closely with the government, the regulator and other stakeholders with 
the mission "Internet & Broadband for Eevryone's Benefit". Many members of 
ISPAI are members of APNIC, the regional RIR. It may be pertinent to mention 
herein that India has the second highest membership in the Asia Pacific Region, 
second only to Australia. 
ISPAI welcomes the ICANN/IANA decision to seek inputs from stakeholders on the 
proposed IPv6 address allocation policy document > 
http://www.icann.org/policies/proposed-ipv6-policy-14jul06.htm and hereby puts 
forth its feedback on the same:

Information & Communication Technologies (ICT) are recognized in India as 
essential tools not only for economic growth but also and more importantly so, 
to bring about a sea-change for health, education, governance and general 
well-being of its 1 billion plus population even as India is committed to 
achieve the Millennium Development Goals. 

Government of India is consciously aware of the potential of Internet to enable 
its  citizens make informed choices and create opportunities for learning and 
earning in a globally competitive economy.   Internet usage in India is growing 
rapidly and the government of India has set forth a target of at least 40 
million Internet subscribers in the country by 2010 (including at least 20 
million broadband ones) http://www.dot.gov.in/ntp/broadbandpolicy2004.htm .

Lack of adequate number of IP addresses is one major hindrance that the 
Governmnet of India is acutely aware of and is taking all plausible and 
effective steps to ensure that adequate IP addresses are available for usage in 
India. The very day our Hon'ble Minister of Communications & IT assumed the 
office in May 2004, he announced a Ten Point agenda 
http://www.mit.gov.in/tenpointagenda.asp , that inter alia, alluded to 
transition towards IPv6 in India in 2006 - the current year.

ISPAI supports the ICANN/IANA proposal to allocate sufficient IPv6 address 
space to the RIRs to support their registration needs starting with /12 address 
space, we would urge that the same be planned for a minimum period of 36 months 
rather than 18 months only.

While ISPAI does support strategies for effectiveness and efficiency in 
principle, nevertheless India strongly believes it may be necessary for IANA to 
define guidelines for RIR so that "reservation" does not amount to 
"conservation" as IPv6 conservation is not necessary even if it might have been 
so in the case of IPv4. India believes that a line be drawn between "prudent 
and facilitating allocation" and "over cautious allocation" in such a way that 
there are no intra-regional or inter-regional disparities in allocation 
policies adopted by different RIRs. 

ISPAI believes that the principle of justification arises only if there is a 
situation of scarcity (caused with IPv4 address space). This ought not to apply 
with respect to IPv6 address space. While it may be reasonable to seek high 
level outline of requirement and proposed usage, further probing and detailing 
would only obfuscate the procedure and vitiate the very rationale of developing 
IPv6.

ISPAI believes that it would be inappropriate for an RIR to ask for their 
respective plans (with infrastructure or applications or new services) for IPv6 
address usage as the same would tantamount to sharing commercially sensitive 
information.

Regards,

Deepak Maheshwari

Secretary - ISP Association of India