[arin-ppml] ARIN-prop-126: Compliance Requirement

[Leo Bicknell]

In a message written on Tue, Jan 11, 2011 at 08:23:02AM -0500, ARIN wrote:
> ARIN-prop-126: Compliance Requirement

I love the concept, but I'm not so much a fan as-written.  The
critical element that is missing is a low water mark.

If I may oversimplify for a moment, giving more space when 80%
utilization is passed, and taking it away the organization drops
below 80% utilization can lead to thrashing.  Additionally, due to
the way IP blocks are allocated and used it's likely that someone
dropping below 80% would have to do significant renumbering to
return a contiguous block, and that block would then subdivide their
original allocation.

Rather, what is needed is something like you get more when reaching
80% utilization, and ARIN can require the return of space when
falling below 40% utilization.  This eliminates thrashing around the
mark, and insures a low enough utilization rate for the return that
renumbering should be minimized and large, useful blocks should be
returned.

Sadly though, my oversimplification is exactly that, this process
intersects with a number of sections of the NRPM.

I think it is also worth considering the probable targets of this
policy.  While I'm sure there are many cases an organization may
have extra space, I believe there are two significant cases that
cover 90% or more of the organizations with extra space.

The first is companies that have experienced a drop in business.
Indeed, I was involved with one organization that I believe dropped
below 80% utilization (and within a year exceeded it) and that was
due to a bankruptcy process.  I think this is important to realize
in that it may hinder ARIN's efforts to perform audits efficiently.
They are likely to be auditing groups under financial strain, perhaps
understaffed, and/or complicated by processes like bankruptcy.

The second is companies that obtained space prior to utilization
requirements.  For instance, folks who received space in the classful
days.  There are plenty of universities for instance that needed
more than a Class C, so they got a Class B, even though they only
need 25% of it even today.  This is going to lead to ARIN contacting
folks who have had pretty much no interaction with ARIN during the
intervening years, who probably don't have an RSA, and so on.

Unfortunately, while I like the concept I feel the practical concerns
make it of limited value in the IPv4 space.  I feel like the level
of staff effort is going to be high for minimal gain.  Also there
is a timing concern, audits take time, renumbering takes time,
blocks then sit around to "cool off" before being reissued.  Would
any IPv4 space get back in the game soon enough to make a meaningful
difference?  Even with the necessary changes of a high and low water
mark I'm not sure if I could really support the policy pragmatically.

However, I could support a policy like this in IPv6.  We can get
out in front of the problem, have it binding on folks under an RSA,
and have it documented well enough in advance that people can prepare
for the audits and return of space.  Basically by doing IPv6 right
early on we could avoid one of the areas of problem in IPv4 policy.

-- 
       Leo Bicknell - bicknell at ufp.org - CCIE 3440
        PGP keys at http://www.ufp.org/~bicknell/
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