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

[John Curran]

On Jul 15, 2014, at 1:04 PM, Matthew Kaufman <matthew at matthew.at> wrote:
> 
> Your theoretical argument assumes a certain kind of large ISP.

Agreed, but I'm not certain it is theoretical given that any larger ISP that has
received a request recently has already had to get record-keeping in order in
order to qualify for that last assignment (and we've had several recent large
allocations as noted in the arin-issued reports)

> 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.

Quite possible that this could occur for some ISPs, with the result being no
effective improvement in ability to obtain another allocation.

> 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.

They still had to supply the same information (to show that the prior blocks are fully 
utilized per present policy) so the above scenario is invalid.  This makes sense, as 
the policy change with regard to the aggregate utilization level and not definitions of 
how utilization is determined for specific technologies (as per your example)

> 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.

Yes.

> But for many others, it would make it harder. 

See above; if the intent of the policy proposal is to make it harder, then the policy text
should be made more explicit regarding the desired changes in policy.

Thanks!
/John

John Curran
President and CEO
ARIN