Proposal for review

[CJW]

I sent this a while back and have gotten no comments.  Please send me
your comments on this.  This topic generated quite a bit of discussion
at the last policy meeting and I can't believe that no one on this list
has an opinion or comment

Thanks bunches!
---CJ


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Date:    Wed, 04 Jul 2001 13:00:22 -0700
From:    "CJW" <cjw at groovy.com>
To:      ppml at arin.net
Subject: Proposal for discussion

This was written by some folks at Internap.  The address council has
been discussing it and your input is an integral part of the process.
Please review and send your comments to the list.

Thanks so much!
---CJ

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                     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.


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