[arin-ppml] Draft Policy ARIN-2014-17: Change Utilization Requirements from last-allocation to total-aggregate
Owen DeLong
owen at delong.com
Tue Sep 30 21:40:59 EDT 2014
I would support option 3.
Owen
On Sep 30, 2014, at 11:06 , Leif Sawyer <lsawyer at gci.com> wrote:
> Delaying implementation until further down the run-out line doesn't help orgs with current needs.
>
>
> I think that as the "spirit" of this is to help out the smaller organizations,
> the argument could easily be made that limiting this to orgs with < 18 isn't
> needlessly hurtful toward larger orgs.
>
> And thus I would be in support of -that- modification.
>
>
> Additionally, I would also be in support of a "minimum utilization" of 50% for allocated blocks,
> as this makes it harder for larger orgs to game the system.
>
>
>
> -----Original Message-----
> From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On Behalf Of Andrew Dul
> Sent: Tuesday, September 30, 2014 9:01 AM
> To: arin-ppml at arin.net
> Subject: Re: [arin-ppml] Draft Policy ARIN-2014-17: Change Utilization Requirements from last-allocation to total-aggregate
>
> 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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