Policy Proposal 2001-6

[Member Services]

ARIN welcomes feedback and discussion about the following policy
proposal in the weeks leading to the ARIN Public Policy and Members
meetings in Miami, scheduled for October 28 - 31, 2001.  All feedback
received on the mailing lists about this policy proposal will be 
included in the discussions that will take place in Miami.

    The policy proposal stated below addresses how ARIN reviews
    IP address space requests from single organizations with large 
    multi-homed discrete networks.  This issue was discussed at the
    last ARIN public policy meeting and has since been discussed on
    the public policy mailing list.  The archives for this mailing
    list are located at http://www.arin.net/mailinglists/ppml/index.html 

This policy proposal discussion will continue to take place on the 
public policy mailing list (ppml at arin.net).  Subscription information 
is available at http://www.arin.net/members/mailing.htm

Richard Jimmerson
Director of Operations
American Registry for Internet Numbers


**Proposed Allocation Policy for:

  Single organizations with large multi-homed discrete networks 

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 routing policy.

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 of organizations.

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)

  * 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
    multi-homed networks.

  * The organization must have a compelling criteria for creating discrete
    networks.
    
    Examples: 1) regulatory restrictions for data transmission
              2) geographic distance and diversity between networks
              3) autonomous multi-homed discrete networks

  * The organization must apply for this policy to be applied to their
    account.

  * Organizations with 'multiple maintainers' should request that this
    policy apply to their accounts, their existing allocations merged, 
    and additional allocations will fall under this policy.

  * Upon adoption the use of 'multiple maintainers' for a single
    organization should not be permitted.  These organizations should 
    then use this policy to govern additional allocations.

    Requirements for additional allocations from RIR:

  * The organization must record allocations or assignments down to 
    the /29 level for all downstream networks via rWhois, SWIP, or 
    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.  The 
    allocation information should also be present in a public database 
    via a routing registry, rWhois, or via 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 anticipated.

  * 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.

  * 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 requests and network utilization documents for audits by 
    the RIR.