[arin-ppml] Draft Policy 2010-14: Standardize IP Reassignment Registration Requirements

[Chris Grundemann]

On Tue, Sep 21, 2010 at 08:10, ARIN <info at arin.net> wrote:
>
> A. ARIN Staff Comments
>
> • This proposal would replace the 3 existing qualifying criteria of the
> Cable Policy (NRPM section 4) with the single criterion of must
> show >50% utilization.
>  o It is staff’s observation that the existing cable policy works well
> for cable providers as is and staff cannot discern what problem this
> section of the proposal is attempting to solve.

I tried to answer this concern in the rationale and I think you
captured the purpose quite well in your bullet below: "it would likely
be beneficial for many of ARIN’s customers who share very similar
technologies to the cable industry, but have never been able to apply
under the cable policy (technologies like dsl, fiber to the home,
etc.)."

Additionally, the current 4.2.6. is laced with SWIP/RWHOIS
requirements and I believe that it makes more sense to consolidate all
registration requirements into one section, to enhance clarity within
the NRPM.

>  o The current cable policy requires 80% of the ISP’s address space to
> be provisioned to hardware and to be reassigned, with a 50 – 80%
> utilization rate. This new proposal removes the 80% requirement, which
> would allow a provider to provision and reassign only 50% of their most
> recent allocation. The result seems to be lowered efficiency of overall
> address space usage.
>  o The text in this section is somewhat unclear and confusing as written.

My intent was not to lower the efficiency but only to simplify the
policy. Current policy already holds all ISPs to an 80% utilization
requirement for subsequent allocations (see 4.2.4.1. Utilization
percentage (80%)). Thus, I found re-stating the 80% requirement
somewhat redundant and unnecessary and chose to only specify the
exception to that rule (>50% utilization on the most recent
allocation).

If this is unclear, I think that it can be easily cleared up with a
minor editorial change after the meeting (since the text is already
frozen now).

> • Because this proposal would apply to all residential dynamic
> addressing pools (in addition to cable), it would likely be beneficial
> for many of ARIN’s customers who share very similar technologies to the
> cable industry, but have never been able to apply under the cable policy
> (technologies like dsl, fiber to the home, etc.).
> • This proposal provides a well-defined explanation of what a
> residential customer is and will be beneficial to both the community and
> to the staff.  The existing definition of  “residential customer” has
> caused some confusion for customers.

Thank you for the great feedback (as always)!

~Chris

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@ChrisGrundemann
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www.burningwiththebush.com
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