[arin-ppml] Policy to remove 25% in 30 days language

[David Huberman]

I am planning on submitting the following policy template to ARIN in the coming days.  I'd like feedback please.

Template: ARIN-POLICY-PROPOSAL-TEMPLATE-3.0
1.Policy Proposal Name: Remove 30 day utilization requirement in end-user IPv4 policy

4.Problem Statement:   End-user policy is intended to provide end-users with a one year supply of IP addresses.  Qualification for a one-year supply requires the network operator to utilize at least 25% of the requested addresses within 30 days. This text is unrealistic and should be remove.

First, it often takes longer than 30 days to stage equipment and start actually using the addresses.  
Second, growth is often not that regimented; the forecast is to use X addresses over the course of a year, not to use 25% of X within 30 days.  
Third, this policy text applies to additional address space requests. It is incompatible with the requirements of other additional address space request justification which indicates that 80% utilization of existing space is sufficient to justify new space. If a block is at 80%, then often (almost always?) the remaining 80% will be used over the next 30 days and longer.  Therefore the operator cannot honestly state they will use 25% of the ADDITIONAL space within 30 days of receiving it; they're still trying to use their older block efficiently.
Fourth, in the face of ARIN exhaustion, some ISPs are starting to not give out /24 (or larger) blocks.  So the justification for the 25% rule that previously existed (and in fact, applied for many years) is no longer germane.

5.Policy statement: Remove the 25% utilization criteria bullet point from NRPM 4.3.3.
6.Comments:
a.Timetable for implementation: Immediate
b.Anything else

END OF TEMPLATE

Thank you,
David

David R Huberman
Principal, Global IP Addressing
Microsoft Corporation