[arin-ppml] Recommended Draft Policy ARIN-2014-19: New MDN Allocation Based on Past Utilization

[ARIN]

Recommended Draft Policy ARIN-2014-19
New MDN Allocation Based on Past Utilization

On 18 December 2014 the ARIN Advisory Council (AC) recommended
ARIN-2014-19 for adoption, making it a Recommended Draft Policy.

ARIN-2014-19 is below and can be found at:
https://www.arin.net/policy/proposals/2014_19.html

You are encouraged to discuss Draft Policy 2014-19 on the PPML prior to
the upcoming ARIN Public Policy Consultation at NANOG 63 in San Antonio 
in February 2015. Both the discussion on the list and at the meeting 
will be used by the ARIN Advisory Council to determine the community 
consensus for adopting this as policy.

The ARIN Policy Development Process can be found at:
https://www.arin.net/policy/pdp.html

Draft Policies and Proposals under discussion can be found at:
https://www.arin.net/policy/proposals/index.html

Regards,

Communications and Member Services
American Registry for Internet Numbers (ARIN)


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Recommended Draft Policy ARIN-2014-19
New MDN Allocation Based on Past Utilization

Date: 16 December 2014

AC's assessment of conformance with the Principles of Internet Number 
Resource Policy:

This draft policy enables fair and impartial number resource 
administration by removing an impediment to additional allocations seen 
by some organizations due to the recent policy changes under 
ARIN-2013-08. This draft policy applies equally to all organizations and 
allows for MDN organizations to use previous utilization of a site to 
justify a new allocation for an MDN network site. The policy is clear 
and implementable as written. This proposal is technically sound. There 
are no technical issues which are raised by allowing a new criteria set 
to justify a new MDN network allocation. This proposal is supported by 
the community. Specifically, the draft policy is supported by 
organizations which use the MDN policy for their network allocation.

Problem Statement:
The previous MDN policy was too limiting in that a new MDN could only 
qualify under immediate need. This was extended by ARIN-2013-8 where the 
minimum allocation will now be assigned unless immediate need for more 
can be demonstrated.

Unfortunately, this policy did not go far enough. There may be some 
cases where there is a one year utilization history that is applicable 
to a new MDN. For example, imagine a network that is divided into four 
regions, each an MDN. Three of the four MDNs have been growing at a /20 
per year. The fourth MDN has been growing at a /19 per year, it is over 
80% utilized, and the region is too large. The region will be divided in 
half, which half of the current customers and their addresses to be 
migrated into a new MDN (Region 5). It is also anticipated that half of 
Region 4's growth will be shifted to Region 5. With Region 4 and Region 
5 each above 80%, both should qualify for subsequent allocations at half 
of what was Region 4's growth rate.

Policy statement:

replace section 4.5.4 created by 2013-8:

Upon verification that the organization has shown evidence of deployment 
of the new discrete network site, the new network(s) shall be allocated 
the minimum allocation size under section 4.2.1.5 unless the 
organization can demonstrate additional need using the immediate need 
criteria (4.2.1.6).

with:

Upon verification that the organization has shown

evidence of deployment of the new discrete network site, the new 
network(s) shall be allocated one of the following:

- the minimum allocation size under section 4.2.1.5

- more than the minimum if the organization can demonstrate additional 
need using the immediate need criteria (4.2.1.6)

- a 3-month supply of address space may be requested if the new MDN can 
show a demonstrated one-year utilization history.

Timetable for implementation: Immediate

Comment:

The third bullet was changed from:

"- a three month supply if there is an applicable one year utilization 
rate, specific to the use to be covered by the new MDN, on which to base 
a three month supply on as per 4.2."

to:

"- a 3-month supply of address space may be requested if the new MDN can 
show a demonstrated one-year utilization history."

#####

ARIN STAFF ASSESSMENT

Date of Assessment: 22 October 2014

1. Summary (Staff Understanding)

This policy proposes to change existing NRPM 4.5, “Multiple Discrete 
Networks” bullet 7 to add an additional qualifying criteria. Currently 
new sites applying under MDN will qualify for the minimum allocation 
size specified in 4.2.1.5 or under immediate need. This proposal adds 
the option for new MDNs with at least a year’s worth of historical 
utilization data to request up to a 3 month supply of addresses.

2. Comments

A. ARIN Staff Comments

· If implemented, staff would require the organization to show a direct 
correlation between the demonstrated 1-year utilization rate and the new 
discrete network’s 3 month need.

· The policy requires an “applicable 1 year utilization rate” in 
order to qualify under this criteria. If implemented, staff would 
require that there be at least a full year of utilization data in order 
to qualify for a 3-month supply of address space.

· The stated criterion is unclear. Staff would suggest restating as 
follows:

o A 3-month supply of address space may be requested if the new MDN can 
show a demonstrated one-year utilization history.

B. ARIN General Counsel - Legal Assessment

This proposal does not create any material legal issue.

3. Resource Impact

This policy would have minimal resource impact from an implementation 
aspect. It is estimated that implementation would occur within 3 months 
after ratification by the ARIN Board of Trustees. The following would be 
needed in order to implement:
· Updated guidelines and internal procedures
· Staff training

4. Proposal/Draft Policy Text Assessed
Date: 3 September 2014
Problem Statement:
The previous MDN policy was too limiting in that a new MDN could only 
qualify under immediate need. This was extended by ARIN-2013-8 where the 
minimum allocation will now be assigned unless immediate need for more 
can be demonstrated.
Unfortunately, this policy did not go far enough. There may be some 
cases where there is a one year utilization history that is applicable 
to a new MDN. For example, imagine a network that is divided into four 
regions, each an MDN. Three of the four MDNs have been growing at a /20 
per year. The fourth MDN has been growing at a /19 per year, it is over 
80% utilized, and the region is too large. The region will be divided in 
half, which half of the current customers and their addresses to be 
migrated into a new MDN (Region 5). It is also anticipated that half of 
Region 4’s growth will be shifted to Region 5. With Region 4 and 
Region 5 each above 80%, both should qualify for subsequent allocations 
at half of what was Region 4’s growth rate.
Policy statement:
replace section 4.5.4 created by 2013-8:
“Upon verification that the organization has shown evidence of 
deployment of the new discrete network site, the new network(s) shall be 
allocated the minimum allocation size under section 4.2.1.5 unless the 
organization can demonstrate additional need using the immediate need 
criteria (4.2.1.6).“
with:
Upon verification that the organization has shown
evidence of deployment of the new discrete network site, the new 
network(s) shall be allocated one of the following:
- the minimum allocation size under section 4.2.1.5
- more than the minimum if the organization can demonstrate additional 
need using the immediate need criteria (4.2.1.6)
- a three month supply if there is an applicable one year utilization 
rate, specific to the use to be covered by the new MDN, on which to base 
a three month supply on as per 4.2.
Timetable for implementation: Immediate