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

[ARIN]

The ARIN Advisory Council (AC) met on 19 February 2015 and decided to
send the following to last call:

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

Feedback is encouraged during the last call period. All comments should
be provided to the Public Policy Mailing List. This last call will
expire on 10 March 2015. After last call the AC will conduct their
last call review.

The draft policy text is below and available at:
https://www.arin.net/policy/proposals/

The ARIN Policy Development Process is available at:
https://www.arin.net/policy/pdp.html

Regards,

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


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Recommended

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

Date: 19 October 2014

AC's assessment of conformance with the Principles of Internet Number 
Resource Policy:

This proposal enables fair and impartial number resource administration 
by removing an impediment to additional allocations seen by some 
organizations due to the shortening of the assignment window to three 
months and the gradual reduction of minimum block size over the past 5 
years. This draft proposal applies equally to all organizations and now 
requires that any netblock show at least 50% utilization before an 
additional block can be allocated or assigned. The policy is clear and 
implementable as written. This proposal is technically sound. There are 
no technical issues which are raised by changing the utilization 
definition within the NRPM. This proposal is supported by the community. 
Support for this draft proposal has been growing as it has been 
discussed. Additional support from the community was seen as issues 
which were brought to the attention of the community by the first staff 
and legal assessment have been mitigated.

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:

Replace Section 4.2.4.1

ISPs must have efficiently utilized all allocations, in aggregate, to at 
least 80% and at least 50% of every allocation in order to receive 
additional space. This includes all space reassigned to their customers.

Replace Section 4.3.6.1

End-users must have efficiently utilized all assignments, in aggregate, 
to at least 80% and at least 50% of every assignment in order to receive 
additional space, and must provide ARIN with utilization details.

Timetable for implementation: Immediate

#####

ARIN STAFF ASSESSMENT

Draft Policy ARIN-2014-17
Change Utilization Requirements from last-allocation to total-aggregate
Date of Assessment: November 2014

1. Summary (Staff Understanding)

This policy removes the current requirement to have efficiently utilized 
all previous allocations and assignments, and 80% of the most recent 
one, and replaces it with the requirement to have efficiently utilized 
all allocations and assignments in aggregate, to at least 80% overall, 
with at least a 50% utilization of every allocated or assigned block.

2. Comments

A. ARIN Staff Comments

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 could be implemented as written.

B. ARIN General Counsel - Legal Assessment

The policy does not present material legal issues. Allocation rules to 
address concerns of small ISP's indicate ARIN's continued attempts to 
balance the needs of stewardship with the needs of different sectors.

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: 19 October 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:
Replace Section 4.2.4.1
ISPs must have efficiently utilized all allocations, in aggregate, to at 
least 80% and at least 50% of every allocation in order to receive 
additional space. This includes all space reassigned to their customers.
Replace Section 4.3.6.1
End-users must have efficiently utilized all assignments, in aggregate, 
to at least 80% and at least 50% of every assignment in order to receive 
additional space, and must provide ARIN with utilization details.