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

[Scott Leibrand]

I don't think this changes that: current policy already allows it (for orgs materially out of compliance, which would mean more like <50% than <80%).

The only changes here, IIUIC, are to clarify that it applies to reassignment policy as well (requiring Whois to be kept current) and allowing ARIN to stop providing rDNS services before they take away someone's space. The latter may be considered an improvement on current policy with regard to the situation you outline. 

Scott

On Jan 11, 2011, at 8:18 AM, Leo Bicknell <bicknell at ufp.org> wrote:

> 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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