[arin-ppml] LAST CALL for Recommended Draft Policy ARIN-2015-3: Remove 30 day utilization requirement in end-user IPv4 policy

[ARIN]

The ARIN Advisory Council (AC) met on 20 April 2016 and decided to
send the following to last call:

   Recommended Draft Policy ARIN-2015-3: Remove 30 day utilization 
requirement in end-user IPv4 policy

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 9 May 2016. 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-2015-3
Remove 30 day utilization requirement in end-user IPv4 policy

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

ARIN 2015-3 contributes to fair and impartial number resource 
administration by removing from the NRPM text that is operationally 
unrealistic for the reasons discussed in the problem statement. This 
proposal is technically sound, in that the removal of the text will more 
closely align with the way staff applies the existing policy in relation 
to 8.3 transfers. There was strong community support for the policy on 
PPML and at ARIN 36, which was confirmed at ARIN 37. There was a 
suggestion to replace this text with an alternate requirement. However, 
the community consensus was to move forward with the removal alone.

The staff and legal review also suggested removing RFC2050 references 
and pointed out that 4.2.3.6 has an additional 25% immediate use clause, 
community feedback was to deal with those issues separately.

Problem Statement:

End-user policy is intended to provide end-users with a one year supply 
of IP addresses. Qualification for a one-year supply requires the 
network operator to utilize at least 25% of the requested addresses 
within 30 days. This text is unrealistic and should be removed.

First, it often takes longer than 30 days to stage equipment and start 
actually using the addresses.

Second, growth is often not that regimented; the forecast is to use X 
addresses over the course of a year, not to use 25% of X within 30 days.

Third, this policy text applies to additional address space requests. It 
is incompatible with the requirements of other additional address space 
request justification which indicates that 80% utilization of existing 
space is sufficient to justify new space. If a block is at 80%, then 
often (almost always?) the remaining 80% will be used over the next 30 
days and longer. Therefore the operator cannot honestly state they will 
use 25% of the ADDITIONAL space within 30 days of receiving it; they're 
still trying to use their older block efficiently.

Fourth, in the face of ARIN exhaustion, some ISPs are starting to not 
give out /24 (or larger) blocks. So the justification for the 25% rule 
that previously existed (and in fact, applied for many years) is no 
longer germane.

Policy statement:

Remove the 25% utilization criteria bullet point from NRPM 4.3.3.

Resulting text:

4.3.3. Utilization rate

Utilization rate of address space is a key factor in justifying a new 
assignment of IP address space. Requesters must show exactly how 
previous address assignments have been utilized and must provide 
appropriate details to verify their one-year growth projection.

The basic criterion that must be met is a 50% utilization rate within 
one year.

A greater utilization rate may be required based on individual network 
requirements. Please refer to RFC 2050 for more information on 
utilization guidelines.

Comments:

a.Timetable for implementation: Immediate

b.Anything else

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ARIN STAFF ASSESSMENT

Draft Policy ARIN-2015-3
Remove 30 day utilization requirement in end-user IPv4 policy
Date of Assessment: 16 February 2016

___
1. Summary (Staff Understanding)

This proposal would remove the 25% utilization (within 30 days of 
issuance) criteria bullet point from NRPM 4.3.3.

___
2. Comments

A. ARIN Staff Comments
This policy would more closely align with the way staff applies the 
existing policy in relation to 8.3 transfers. Because there is no longer 
an IPv4 free pool and many IPv4 requests are likely to be satisfied by 
8.3 transfers, the adoption of this policy should have no major impact 
on operations and could be implemented as written.

Note that both NRPM 4.3.3 and NRPM 4.2.3.6 contain references to 
obsolete RFC 2050. Additionally, 4.2.3.6 references the 25% immediate 
use (within 30 days of issuance) requirement.

Staff suggests removing the first two sentences of 4.2.3.6 to remove the 
references to RFC 2050 and the 25% requirement. Additionally, staff 
suggests removing the reference to the obsolete RFC 2050 in section 4.3.3.

B. ARIN General Counsel – Legal Assessment
No material legal risk in this policy.

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3. Resource Impact

This policy would have minimal resource impact from an implementation 
aspect. It is estimated that implementation would occur immediately 
after ratification by the ARIN Board of Trustees. The following would be 
needed in order to implement:
* Updated guidelines and internal procedures
* Staff training