Call for Comment: Policy Proposal 2001-6

[Member Services]

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.

Ray Plzak
President
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 
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 should have 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

* 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 
  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.  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.