Call for Comment: Policy Proposal 2001-6
memsvcs at arin.net
Mon Nov 12 14:36:20 EST 2001
The ARIN Advisory Council voted to forward to the ARIN Board of
Trustees the following policy.
This a last call for community comment on this policy prior to the
ARIN Board of Trustees review of the proposed policy. This policy
will be posted on the ARIN website and the ARIN Public Policy email
list. Please send your comments to ppml at arin.net. This last call
will expire at 23:59 EST on November 23, 2001.
American Registry for Internet Numbers (ARIN)
*** Last Call - Policy Proposal 2001-6 ***
ARIN currently has an allocation policy that is 'blind' to route
Filtering and global routablity, yet in order for address space to
be usable it must be accepted and routed by the community at large.
This fact can create allocation concerns for organizations that
have multiple discrete multi-homed networks. Organizations may
design their networks in this manner for a number of reasons
including regulatory restrictions (Federal FCC mandated inter-lata
restrictions), geographic diversity/distance between networks, and
Current RIR allocation policy requires that before a single
organization can obtain additional address space it must show 80%
utilization (through SWIP or rWhois) per RFC 2050.
Currently, some organizations have circumvented this requirement
by Creating "multiple maintainers" with ARIN and request address
space for networks as though they were separate organizations. This
practice creates both practical and financial concerns for ARIN. In
practice it appears that organizations can just 'buy' additional
address space without regard to utilization on other networks and
this in turn increases ARIN's revenue dependence on a small number
Current allocation requirements can become unreasonable when
operating a set of discrete networks for organizations which intend
on following the current allocations policy. Discrete networks must
often have separate unique globally routable address space and will
often grow at different rates. This growth differential can lead to
a situation where one discrete network is completely allocated but
another network has not yet been fully utilized.
Under the current allocation policy the organization would need to
Request additional address space from the RIR; however, given a
strict interpretation of the existing policy, the RIR may not be
able to grant additional address space to the organization, due to
the 80% utilization requirement.
This constraint can easily be seen when you consider an
organization with two geographically discrete autonomous networks.
The organization initially requested a /19 from the RIR for its
two networks with the intent to route a single /20 from each
network. Network A's utilization grows considerably faster than
Network B. Network A is currently showing 90% utilization and needs
additional address space for new customers being added to this
network. Network B's address space is being utilized but currently
only shows 40% utilization. This would produce an allocation
utilization percentage of 65% which is below the requirement for
additional address space by a RIR.
We propose for organizations which meet the following criteria to
be granted the opportunity to request additional address space under
the requirements listed below.
Criteria for the application of this policy:
* The organization should be a single entity, and not a consortium
of smaller independent entities. (Example: Not a group of
independent network operators who form a group specifically for
* This policy applies only to organizations that have been
previously granted address space by an RIR. This policy does not
apply to organizations with only legacy address space.
* The organization must have multiple (at least two) discrete
* The organization should have compelling criteria for creating
Examples: 1) regulatory restrictions for data transmission
2) geographic distance and diversity between networks
3) autonomous multi-homed discrete networks
* An organization which would like to use this policy must apply
for this policy to be applied to their maintainer account.
Requirements for additional allocations from RIR:
* The organization must record allocations or assignments down to
the current RIR bit boundary (currently /29 for ARIN) and record
them in an approved RIR public database.
* The organization must keep detailed records of how it has
allocated space to each discrete network. This should include
the block allocated, any reserved blocks, and date of
allocation/reservation. The discrete network allocation
information should also be present in a public database
(Example: routing registry, rWhois, or SWIP).
* The organization must not allocate additional space to a
discrete network unless all the blocks allocated to that network
show utilization greater than 80% individually and as a whole.
* The organization must not allocate a CIDR block larger than the
current minimum assignment size of the RIR (currently /20 for
ARIN) to a new network.
* The organization must not allocate an additional CIDR block larger
than the current minimum assignment size of the RIR (currently /20
for ARIN) to an existing network, unless previous growth rates for
that network indicate that it is likely to utilize a larger CIDR
block before the time the organization will be requesting an
additional block from the RIR. The suggested minimum allocation
size for an additional block for a network is the current minimum
assignment size of the RIR.
* When allocating a block larger than the minimum assignment size
to an existing network the organization should use the smallest
allocation possible out of a larger reserved block. This
requirement is to reduce the number of routes the organization
will announce from that autonomous system. Example: A fast
growing network is allocated a /20 out of a reserved /19, when
the /20 is 80% utilized the announcement is expanded to a /19
and the /20 announcement is removed. This practice also allows
the reserved /20 to be used by another discrete network should
the 'fast growing network' not use the address space as
* When applying for additional address space, from an RIR, for
new networks or additional space for existing networks the
organization must show greater than 50% utilization for the last
block granted by the RIR and their allocations as a whole. Any
reserved blocks must be allocated to a discrete network before
the RIR will grant additional address space.
* The organization must follow guidelines of RFC 2050 (or its
replacement)and the policy of the granting RIR for allocations
that are assigned or allocated to downstream networks. This
includes record keeping of allocation and reassignment requests
and network utilization documents for audits by the RIR.
* Current members presently managing multiple maintainer accounts
should contact the ARIN Hostmaster if they wish for this policy
to apply to one or more of their current accounts.
More information about the ARIN-announce