[arin-ppml] Draft Policy ARIN-2014-17: Change Utilization Requirements from last-allocation to total-aggregate

[ARIN]

Draft Policy ARIN-2014-17
Change Utilization Requirements from last-allocation to total-aggregate

Here is the staff assessment of ARIN-2014-17.

Regards,

Communications and Member Services
American Registry for Internet Numbers (ARIN)


## * ##


ARIN STAFF ASSESSMENT
Date of Assessment: 26 August 2014

Draft Policy ARIN-2014-17
Change Utilization Requirements from last-allocation to total-aggregate

1. Summary (Staff Understanding)

This policy removes the current requirement to have efficiently utilized 
all previous allocations, and 80% of the most recent one and replaces it 
with the requirement to have efficiently utilized all allocations, in 
aggregate, to at least 80% overall.

2. Comments

A. ARIN Staff Comments

· The intent of the policy seems to be to make it easier for all ISPs to 
qualify for additional allocations by requiring an 80% utilization rate 
of all blocks (in aggregate) rather than 80% of the most recent block.

o Based on staff experience, the 80% utilization rate of the last block 
has been periodically problematic for smaller ISPs, but not for medium 
to larger ISPs. Staff has seen situations where a small ISP with a /22 
may need to issue a /24 to a customer but not have any available, not be 
at 80% utilized, and therefore, not be able to request additional space.

· This policy gives ISPs no incentive to efficiently utilize their IPv4 
resources beyond the minimum 80% overall requirement.

· This policy would allow larger, well established ISPs with many 
allocations from ARIN to be able to qualify for additional IP address 
space without ever having used their last allocation at all.

o For example, an ISP that is currently close to 100% utilization of its 
multiple prefixes totaling 25,000 /24s justifies and receive an 
additional /16 would immediately qualify for more space even though they 
used 0% of their last allocation.
o Another example would be this same ISP with 25,000 /24s at 80% 
utilization could request an additional /16 even though they still have 
5,000 /24s free (which could include up to approximately 20 unused /16s).

· This proposal could be implemented as written.

B. ARIN General Counsel - Legal Assessment

"I have a single material legal concern about the draft policy. 
Community standards for allocation policies should adequately address 
the fairness of their criterion and impact on all market segments: 
large, medium and small companies. This proposed policy would make a 
major change in how a bedrock allocation evaluation criteria, changing 
how utilization is measured for everyone, in order to address the 
occasional ‘corner’ case where a small company might have to make an 
allocation that it has insufficient allocated resources to provide. but 
cannot get over the 80% utilization as currently measured. While the 
small company problem is potentially worthy of review and action, the 
proposed policy has the unintended but clear impact of creating 
additional new allocation entitlements where none exist for larger 
companies. While ARIN still has resources remaining in the IPv4 free 
pool, larger companies will gain significant benefit from this change 
compared to the number of small company corner cases that it will close. 
 From a legal standpoint it would be more attractive for the community 
to reach a better balance in this area."



3. Resource Impact

This policy would have minimal resource impact from an implementation 
aspect. It is estimated that implementation would occur within 3 months 
after ratification by the ARIN Board of Trustees. The following would be 
needed in order to implement:

· Updated guidelines and internal procedures
· Staff training

4. Proposal/Draft Policy Text Assessed

Draft Policy ARIN-2014-17 Change Utilization Requirements from 
last-allocation to total-aggregate
Date: 14 July 2014

Problem Statement:
Current ARIN policy calculates utilization on a per allocation basis 
rather than in aggregate. This method of determining utilization may 
cause some organizations to be unable to qualify for additional address 
blocks despite attempting to use their resource allocations as best as 
possible. This issue has been exacerbated in the past couple of years 
due to the 3-month allocation window which causes organizations to 
receive smaller non-expandable allocations rather than a larger aggregate.
For example, if an organization has 4 x /22 and 3 of them are utilized 
100% and the fourth utilized at 75%, an additional allocation request 
would be denied. However, an organization with a single /20 utilized at 
80% would have less efficient utilization but would be eligible to 
receive additional space.

Policy statement:
Update Section 4.2.4.1
ISPs must have efficiently utilized all allocations, in aggregate, to at 
least 80% in order to receive additional space. This includes all space 
reassigned to their customers.
Update Section 4.3.6.1
End-users must have efficiently utilized all assignments, in aggregate, 
to at least 80% in order to receive additional space, and must provide 
ARIN with utilization details.





On 7/14/14, 2:53 PM, ARIN wrote:
> Draft Policy ARIN-2014-17
> Change Utilization Requirements from last-allocation to total-aggregate
>
> ARIN-2014-17 has been revised.
>
> Draft Policy ARIN-2014-17 is below and can be found at:
> https://www.arin.net/policy/proposals/2014_17.html
>
> You are encouraged to discuss the merits and your concerns of Draft
> Policy 2014-17 on the Public Policy Mailing List.
>
> The AC will evaluate the discussion in order to assess the conformance
> of this draft policy with ARIN's Principles of Internet Number Resource
> Policy as stated in the PDP. Specifically, these principles are:
>
>    * Enabling Fair and Impartial Number Resource Administration
>    * Technically Sound
>    * Supported by the Community
>
> The ARIN Policy Development Process (PDP) can be found at:
> https://www.arin.net/policy/pdp.html
>
> Draft Policies and Proposals under discussion can be found at:
> https://www.arin.net/policy/proposals/index.html
>
> Regards,
>
> Communications and Member Services
> American Registry for Internet Numbers (ARIN)
>
>
> ## * ##
>
>
> Draft Policy ARIN-2014-17
> Change Utilization Requirements from last-allocation to total-aggregate
>
> Date: 14 July 2014
>
> Problem Statement:
>
> Current ARIN policy calculates utilization on a per allocation basis
> rather than in aggregate. This method of determining utilization may
> cause some organizations to be unable to qualify for additional address
> blocks despite attempting to use their resource allocations as best as
> possible.  This issue has been exacerbated in the past couple of years
> due to the 3-month allocation window which causes organizations to
> receive smaller non-expandable allocations rather than a larger aggregate.
>
> For example, if an organization has 4 x /22 and 3 of them are utilized
> 100% and the fourth utilized at 75%, an additional allocation request
> would be denied.  However, an organization with a single /20 utilized at
> 80% would have less efficient utilization but would be eligible to
> receive additional space.
>
> Policy statement:
>
> Update Section 4.2.4.1
>
> ISPs must have efficiently utilized all allocations, in aggregate, to at
> least 80% in order to receive additional space. This includes all space
> reassigned to their customers.
>
> Update Section 4.3.6.1
>
> End-users must have efficiently utilized all assignments, in aggregate,
> to at least 80% in order to receive additional space, and must provide
> ARIN with utilization details.
>
> Comments:
> a. Timetable for implementation: Immediate
> b.