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

[Brett Frankenberger]

On Thu, Nov 20, 2014 at 01:05:13PM -0500, ARIN wrote:
> Draft Policy ARIN-2014-17
> Change Utilization Requirements from last-allocation to total-aggregate
> 
> ARIN-2014-17 has been revised.
> 
> Draft Policy ARIN-2014-17 Change Utilization Requirements from
> last-allocation to total-aggregate
> 
> 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.

Strongly support.  Whether or not an organization is justified in
requesting more address space should not vary based on which parts of
their existing space they have allocated.  The current policy creates
perverse incentives to, for example, spend engineering resources
renumbering subnets from one block to another just to support
justification of additional space, or to make all new customer
assignments out of the newly issued block even with sound engineering
practice (for example, reasonable internal aggregation) would support
using other blocks.

I believe the 50% requirement added to the policy proposal adequately
addresses the concern that some providers or end users would make a
request and receive an allocation or assignment, and then immediately
be eligible to make another request with the same justification as the
first request.  (Of course, it creates the same type of perverse
incentives as the current policy, but to a much lesser degree

I also note that under current policy, organizations which remain 80%
utilized in aggregate after receiving an allocation could rearrange
their existing usage to achieve 80% utilization across all allocations,
and then qualify for additional space without having made any
additional usage.  While doing so would not be practical for all
organizations, some organizations would have enough space utilized in
dynamic pools that such a rearrangement would be doable in a short
amount of time.

(Also:  Oppose any attempt to make this about more than utilization
requirements.  I agree that better WHOIS data is a worthwhile goal, as
are many other things, but they should be addressed by a separate
policy proposal, so that the community can evaluate the merits of each
change independently.)

     -- Brett