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

Owen DeLong owen at delong.com
Tue Jan 11 20:58:18 EST 2011

On Jan 11, 2011, at 4:05 PM, Stephen Sprunk wrote:

> On 11 Jan 2011 10:18, Leo Bicknell wrote:
>> 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.
> That scenario is exactly why NRPM 12.4.a says "an organization may remain out of compliance ... as appropriate so as to avoid forcing returns which will result in near-term additional requests".
>> 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.
> Similarly, that scenario is exactly why NRPM 12.4.b says "Partial address blocks shall be returned in such a way that the portion retained will comprise a single aggregate block."  Note the word "retained".
> Let's say you have a /16.  Under NRPM 12, you cannot return a /18, because that would leave you with a /17 and a /18, nor can ARIN revoke a single /18 because their only authority to do so is NRPM 12.5, which requires them to follow the same rule by reference.  The registrant could do so voluntarily under another section that allows otherwise, but ARIN cannot require it.  This was not an accident.
>> 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.
> As John noted, the "low water mark" is currently 50%.  That's not exactly what the policy says, but it seems reasonable enough--and probably takes a lot less work to enforce.
>> 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.
> That is part of the point, if we can ever agree that NRPM 12 does, in fact, extend to legacy resources.  I think it does, but Owen thinks it doesn't, hence the word "additional" in 12.8, which makes the text compatible with both views.
To be clear here....

In my opinion, NRPM 12 cannot grant ARIN new authority to revoke space ARIN did not previously have the ability to revoke for other reasons, such as non-payment of fees. NRPM 12 is intended to consider legacy space utilization when contemplating the justification for retaining other address space covered under an RSA. For example, say an organization had a /16 of legacy space which they fully utilized and obtained an additional /20 from ARIN under RSA. Later, it is discovered through NRPM 12 auditing that the organization is now using approximately 1/2 of it's /16 and still using all of its /20. In that case, NRPM 12 would give ARIN the authority and responsibility to reclaim the /20 and the organization would be expected to renumber into the legacy /16.

Now, later when the organization further reduces their utilization and is only using 25% of their legacy /16, ARIN would have no new authority under NRPM 12 to partially reclaim that /16. To date, it has not been established that ARIN does or does not have the ability and/or authority to revoke or partially revoke legacy resources which are not voluntarily abandoned by the resource holder. NRPM 12 does not change that in any way. If it is later found that ARIN does have such ability and authority, then, I would presume that NRPM 12 would apply to it. OTOH, if it is found that ARIN does not have such ability and authority, then, we can't change that fact through ARIN policy changes.
>> 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?
> There are many other reasons for reclamation; extending the lifetime of IPv4 is not an important one.

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