[ppml] Policy Proposal 2007-9 - Staff Assessment

[Member Services]

Policy Proposal 2007-9
Modernization of ISP Immediate Need Policy

ARIN Staff Assessment

The assessment of this proposal includes comments from ARIN staff and
the ARIN General Counsel. It contains analysis of procedural, legal, and
resource concerns regarding the implementation of this policy proposal
as it is currently stated. Any changes to the language of the proposal
may necessitate further analysis by staff and Counsel.

I.	Proposal

   Policy Proposal 2007-9 is available as Annex A below and at:
   http://www.arin.net/policy/proposals/2007_9.html

II.	Understanding of the proposal

   ARIN staff understands this proposal would change the immediate need
policy by reducing the minimum allocation from a fixed /20 IPv4 address
block to ARIN’s current minimum allocation as defined elsewhere in the
NRPM, and would set the maximum allocation size at a /16 IPv4 address
block. The policy also defines a 30 day utilization window of the IP
address space.

III.	Issues and concerns

   A.	ARIN Staff

     No comments at this time.

   B.	ARIN General Counsel

     The policy as proposed poses no significant legal risks for ARIN.
We also believe that this policy is beneficial because it prevents the
waste of resources.

IV.	Resource Impact - Minimum

The resource impact of implementing this policy is viewed as minimum.
Barring any unforeseen resource requirements, this policy could be
implemented within 90 days from the date of the ratification of the
policy by the ARIN Board of Trustees. Implementation would not require
the acquisition of staff personnel or equipment. It will require the
following:

- Revisions to registration guidelines
- Staff Training

Respectfully submitted,

Member Services
American Registry for Internet Numbers (ARIN)


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Annex A

Policy Proposal 2007-9
Modernization of ISP Immediate Need Policy

Proposal type: modify

Policy term: permanent

Policy statement:

Modify NRPM 4.2.1.6 to read: If an ISP has an immediate need for address
space, and can provide justification to show that the address space will
be utilized within 30 days of the request, ARIN may issue a block of
address space, not larger than a /16 nor smaller than ARIN's customary
minimum allocation, to that organization. These cases are exceptional.

Current text of 4.2.1.6: If an ISP has an immediate need for address
space, i.e., the need exists the day of the request, ARIN may issue a
/20 if the organization, such as a new company, shows justification.
However, these cases are exceptional.

Rationale:

ARIN staff and ARIN members have identified a few long-standing problems
with the Immediate Need policy. This policy proposal attempts to address
the following concerns:
     * The Immediate Need policy only allows ISPs to qualify for a /20
worth of space, when a larger size block may be necessary to provide
proper coverage for the proposed project. An example justifying larger
space is an MSOs for which a /20 is insufficient to put an address block
larger than a /29 or /30 on each CMTS in a metropolitan area).
     * Conversely, this policy was written before the current
multi-homed policy (which allows allocations of /21s and /22s). The
Immediate Need policy should allow assignment of smaller blocks of space
if those are justified.
     * The example used in the Immediate Need policy gives the
impression that an immediate need must exist the day of the request.
This seems both unfair and unreasonable and should probably be changed
to reflect a realistic timeframe.
Concerns expressed about the Immediate Need Policy but NOT addressed by
this policy proposal (but addressed in a subsequent policy proposal):
     * The policy as written allows ARIN to issue a /20 to an ISP only.
However, section 4.3.4. "Additional Considerations" of the End User
Policy in the NRPM states that "End-users may qualify for address space
under other policies such as Immediate need [4.2.1.6] or
Micro-allocation [4.4].". In order to be consistent, the Immediate Need
policy language should be changed to reflect the fact that both ISPs and
end-users can qualify under this policy.

Timetable for implementation: Immediate