[arin-ppml] Recommended Draft Policy ARIN-2014-17: Change Utilization Requirements from last-allocation to total-aggregate

[Leif Sawyer]

I fully support the draft policy as written below.  

Leif Sawyer

________________________________________
From: arin-ppml-bounces at arin.net [arin-ppml-bounces at arin.net] on behalf of ARIN [info at arin.net]
Sent: Wednesday, December 24, 2014 7:21 AM
To: arin-ppml at arin.net
Subject: [arin-ppml] Recommended Draft Policy ARIN-2014-17: Change Utilization Requirements from last-allocation to total-aggregate

Recommended Draft Policy ARIN-2014-17
Change Utilization Requirements from last-allocation to total-aggregate

On 18 December 2014 the ARIN Advisory Council (AC) recommended
ARIN-2014-17 for adoption, making it a Recommended Draft Policy.

ARIN-2014-17 is below and can be found at:
https://www.arin.net/policy/proposals/2014_17.html

You are encouraged to discuss Draft Policy 2014-17 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)


## * ##


Recommended Draft Policy ARIN-2014-17
Change Utilization Requirements from last-allocation to total-aggregate

Date: 19 October 2014

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

This proposal enables fair and impartial number resource administration
by removing an impediment to additional allocations seen by some
organizations due to the shortening of the assignment window to three
months and the gradual reduction of minimum block size over the past 5
years. This draft proposal applies equally to all organizations and now
requires that any netblock show at least 50% utilization before an
additional block can be allocated or assigned. The policy is clear and
implementable as written. This proposal is technically sound. There are
no technical issues which are raised by changing the utilization
definition within the NRPM. This proposal is supported by the community.
Support for this draft proposal has been growing as it has been
discussed. Additional support from the community was seen as issues
which were brought to the attention of the community by the first staff
and legal assessment have been mitigated.

Problem Statement:

Current ARIN policy calculates utilization on a per allocation basis
rather than in aggregate. This method of determining utilization may
cause some organizations to be unable to qualify for additional address
blocks despite attempting to use their resource allocations as best as
possible. This issue has been exacerbated in the past couple of years
due to the 3-month allocation window which causes organizations to
receive smaller non-expandable allocations rather than a larger aggregate.

For example, if an organization has 4 x /22 and 3 of them are utilized
100% and the fourth utilized at 75%, an additional allocation request
would be denied. However, an organization with a single /20 utilized at
80% would have less efficient utilization but would be eligible to
receive additional space.

Policy statement:

Replace Section 4.2.4.1

ISPs must have efficiently utilized all allocations, in aggregate, to at
least 80% and at least 50% of every allocation in order to receive
additional space. This includes all space reassigned to their customers.

Replace Section 4.3.6.1

End-users must have efficiently utilized all assignments, in aggregate,
to at least 80% and at least 50% of every assignment in order to receive
additional space, and must provide ARIN with utilization details.

Timetable for implementation: Immediate

#####

ARIN STAFF ASSESSMENT

Draft Policy ARIN-2014-17
Change Utilization Requirements from last-allocation to total-aggregate
Date of Assessment: November 2014

1. Summary (Staff Understanding)

This policy removes the current requirement to have efficiently utilized
all previous allocations and assignments, and 80% of the most recent
one, and replaces it with the requirement to have efficiently utilized
all allocations and assignments in aggregate, to at least 80% overall,
with at least a 50% utilization of every allocated or assigned block.

2. Comments

A. ARIN Staff Comments

Based on staff experience, the 80% utilization rate of the last block
has been periodically problematic for smaller ISPs, but not for medium
to larger ISPs. Staff has seen situations where a small ISP with a /22
may need to issue a /24 to a customer but not have any available, not be
at 80% utilized, and therefore, not be able to request additional space.

This policy could be implemented as written.

B. ARIN General Counsel - Legal Assessment

The policy does not present material legal issues. Allocation rules to
address concerns of small ISP's indicate ARIN's continued attempts to
balance the needs of stewardship with the needs of different sectors.

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

Draft Policy ARIN-2014-17 Change Utilization Requirements from
last-allocation to total-aggregate
Date: 19 October 2014
Problem Statement:
Current ARIN policy calculates utilization on a per allocation basis
rather than in aggregate. This method of determining utilization may
cause some organizations to be unable to qualify for additional address
blocks despite attempting to use their resource allocations as best as
possible. This issue has been exacerbated in the past couple of years
due to the 3-month allocation window which causes organizations to
receive smaller non-expandable allocations rather than a larger aggregate.
For example, if an organization has 4 x /22 and 3 of them are utilized
100% and the fourth utilized at 75%, an additional allocation request
would be denied. However, an organization with a single /20 utilized at
80% would have less efficient utilization but would be eligible to
receive additional space.
Policy statement:
Replace Section 4.2.4.1
ISPs must have efficiently utilized all allocations, in aggregate, to at
least 80% and at least 50% of every allocation in order to receive
additional space. This includes all space reassigned to their customers.
Replace Section 4.3.6.1
End-users must have efficiently utilized all assignments, in aggregate,
to at least 80% and at least 50% of every assignment in order to receive
additional space, and must provide ARIN with utilization details.
_______________________________________________
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