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

[Andrew Dul]

Hello,

The staff and legal assessment below noted some concerns regarding this
policy.  To alleviate some of these concerns we have thought about the
following three changes to the draft policy.

1. Delay implementation of the policy, such that the free pool was small
enough that a large organization could not obtain additional allocations
primarily though the implementation of this policy.  Triggers considered
include, largest block in free pool being a /16 or total amount of
address space in the free pool < /12.

2. Add a requirement that any one block must be utilized to at least 50%.

3. Limiting this policy to organizations which have less than an
aggregate /18 equivalent.

Do you support any of these additions?  Please also state if you support
the current policy draft.

Thanks,
Andrew

On 9/19/2014 1:05 PM, ARIN wrote:
> Draft Policy ARIN-2014-17
> Change Utilization Requirements from last-allocation to total-aggregate
>
> Here is the staff assessment of ARIN-2014-17.
>
> Regards,
>
> Communications and Member Services
> American Registry for Internet Numbers (ARIN)
>
>
> ## * ##
>
>
> ARIN STAFF ASSESSMENT
> Date of Assessment: 26 August 2014
>
> Draft Policy ARIN-2014-17
> Change Utilization Requirements from last-allocation to total-aggregate
>
> 1. Summary (Staff Understanding)
>
> This policy removes the current requirement to have efficiently
> utilized all previous allocations, and 80% of the most recent one and
> replaces it with the requirement to have efficiently utilized all
> allocations, in aggregate, to at least 80% overall.
>
> 2. Comments
>
> A. ARIN Staff Comments
>
> · The intent of the policy seems to be to make it easier for all ISPs
> to qualify for additional allocations by requiring an 80% utilization
> rate of all blocks (in aggregate) rather than 80% of the most recent
> block.
>
> o 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 gives ISPs no incentive to efficiently utilize their
> IPv4 resources beyond the minimum 80% overall requirement.
>
> · This policy would allow larger, well established ISPs with many
> allocations from ARIN to be able to qualify for additional IP address
> space without ever having used their last allocation at all.
>
> o For example, an ISP that is currently close to 100% utilization of
> its multiple prefixes totaling 25,000 /24s justifies and receive an
> additional /16 would immediately qualify for more space even though
> they used 0% of their last allocation.
> o Another example would be this same ISP with 25,000 /24s at 80%
> utilization could request an additional /16 even though they still
> have 5,000 /24s free (which could include up to approximately 20
> unused /16s).
>
> · This proposal could be implemented as written.
>
> B. ARIN General Counsel - Legal Assessment
>
> "I have a single material legal concern about the draft policy.
> Community standards for allocation policies should adequately address
> the fairness of their criterion and impact on all market segments:
> large, medium and small companies. This proposed policy would make a
> major change in how a bedrock allocation evaluation criteria, changing
> how utilization is measured for everyone, in order to address the
> occasional ‘corner’ case where a small company might have to make an
> allocation that it has insufficient allocated resources to provide.
> but cannot get over the 80% utilization as currently measured. While
> the small company problem is potentially worthy of review and action,
> the proposed policy has the unintended but clear impact of creating
> additional new allocation entitlements where none exist for larger
> companies. While ARIN still has resources remaining in the IPv4 free
> pool, larger companies will gain significant benefit from this change
> compared to the number of small company corner cases that it will
> close. From a legal standpoint it would be more attractive for the
> community to reach a better balance in this area."
>
>
>
> 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: 14 July 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:
> Update Section 4.2.4.1
> ISPs must have efficiently utilized all allocations, in aggregate, to
> at least 80% in order to receive additional space. This includes all
> space reassigned to their customers.
> Update Section 4.3.6.1
> End-users must have efficiently utilized all assignments, in
> aggregate, to at least 80% in order to receive additional space, and
> must provide ARIN with utilization details.
>
>
>
>
>
> On 7/14/14, 2:53 PM, 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 is below and can be found at:
>> https://www.arin.net/policy/proposals/2014_17.html
>>
>> You are encouraged to discuss the merits and your concerns of Draft
>> Policy 2014-17 on the Public Policy Mailing List.
>>
>> The AC will evaluate the discussion in order to assess the conformance
>> of this draft policy with ARIN's Principles of Internet Number Resource
>> Policy as stated in the PDP. Specifically, these principles are:
>>
>>    * Enabling Fair and Impartial Number Resource Administration
>>    * Technically Sound
>>    * Supported by the Community
>>
>> The ARIN Policy Development Process (PDP) 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)
>>
>>
>> ## * ##
>>
>>
>> Draft Policy ARIN-2014-17
>> Change Utilization Requirements from last-allocation to total-aggregate
>>
>> Date: 14 July 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:
>>
>> Update Section 4.2.4.1
>>
>> ISPs must have efficiently utilized all allocations, in aggregate, to at
>> least 80% in order to receive additional space. This includes all space
>> reassigned to their customers.
>>
>> Update Section 4.3.6.1
>>
>> End-users must have efficiently utilized all assignments, in aggregate,
>> to at least 80% in order to receive additional space, and must provide
>> ARIN with utilization details.
>>
>> Comments:
>> a. Timetable for implementation: Immediate
>> b.
>
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