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

[Andrew Dul]

On 7/15/2014 10:04 AM, Matthew Kaufman wrote:
> On 7/14/2014 6:44 PM, John Curran wrote:
>> On Jul 14, 2014, at 9:06 PM, Jeffrey Lyon
>> <jeffrey.lyon at blacklotus.net <mailto:jeffrey.lyon at blacklotus.net>> wrote:
>>>
>>> It applies to all but is of zero benefit to large orgs with
>>> contiguous space. This idea that it allows big orgs to horde space
>>> is a red herring.
>>>
>> Jeffrey - 
>>  
>>   For sake of argument, imagine a large ISP which over the course of
>> time has
>>   ended up with a /8, two /16, and a /14 IPv4 blocks (with the /14
>> being the most
>>   recently issued block because of nearly full utilization of all
>> prior blocks at the
>>   time.)
>>  
>>   Under present policy, the ISP cannot request address space until
>> they have 
>>   brought the utilization of the most recently issued block (the /14)
>> up to 80%.
>>   
>>   Under the proposed policy, the ISP is immediately eligible to
>> request space,
>>   since their aggregate utilization (even with a completely unused
>> /14) is going 
>>   to be very high (potentially as much as 97% due to the fully-used
>> /8 block.)
>>
>>   The proposed policy allows organizations to request space so long
>> as their 
>>   aggregate utilization is higher than 80%, and this means many existing 
>>   organization with large IPv4 holdings will suddenly qualify to
>> receive an 
>>   additional allocation if they choose to request it.  Whether that
>> is desirable
>>   or not is a matter for the community to decide.
>>
>>
>
> Your theoretical argument assumes a certain kind of large ISP. Let me
> propose a couple of alternative scenarios:
>
> Imagine a large ISP which over the course of time has ended up with a
> /8, two /16, and a /14 block with the /14 being the most recently
> issued block.
>
> Under present policy, they cannot get more space until the /14 is
> documented at 80% utilization, which they've got the documentation all
> ready for.
>
> Under the proposed policy, the ISP can't get any space, because their
> recordkeeping on the /8 is terrible. They got the /8 and the /16
> pre-ARIN, probably as two different entities than the one that got the
> /14, and now instead of submitting the detailed documentation they
> started keeping not long after they got that second /16 (so they could
> get the /14, and so they could get more when the /14 filled) they'd
> need to spend more time and effort than they have to dredge up
> utilization records for that /8 just to get another 3 months worth of
> space from ARIN (even though the scrap papers laying around and the
> routing tables strongly suggest that all that space really is in use,
> and isn't easily reclaimed to meet their pressing need). So they get
> nothing.
>
> Or imagine a large ISP which over the course of time has ended up with
> a /8, two /16 and a /14 with the /14 being the most recently issued block.
>
> Under present policy, they cannot get more space until the /14 is
> documented at 80% utilization, and they're all ready to do that.
>
> Under the proposed policy, the ISP can't get any space because while
> they've got great records for how the /8 and the two /16s are
> utilized, the customer and internal assignments they did back then are
> deemed to be inefficient by ARIN staff when they review the
> utilization records for everything. All those point-to-point links
> using whole /24s, and dialup pools that are sized for what was needed
> back in the days of dialup but nowadays only have a handful of
> customers on them aren't ok any more. So instead of being able to just
> pounce on some space because of this policy change, they're actually
> blocked from getting more.
>
> Overall, I think the answer is that for certain kinds of ISPs in
> certain kinds of growth patterns, the change in policy would make it
> easier for them to qualify. But for many others, it would make it harder.
>
> I am not in favor of pulling the rug out from under people at the last
> minute, and given how close we are to runout it would be exactly that
> to change IPv4 policy on them. So I oppose this policy as written, and
> any other attempts to make last-minute changes. For people who've
> planned ahead, stability is the best we can give them. For people who
> haven't planned ahead, they're screwed whether we change the policy or
> not.

Matthew,

Thank you for your detailed explanation of your arguments against this
policy as written.  Would you support this policy after the free pool
has been exhausted?  Some have suggested that this type of policy also
eases the transfer market because it refocuses an organization on their
entire address holdings and gives them a potentially larger buffer than
they could carry previously.

Thanks,
Andrew
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://lists.arin.net/pipermail/arin-ppml/attachments/20140715/2a72d9e6/attachment.htm>