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

[Karl Brumund]

Makes sense to me. +1

…karl

> On Dec 24, 2014, at 11:21 AM, ARIN <info at arin.net> wrote:
> 
> Recommended Draft Policy ARIN-2014-17
> Change Utilization Requirements from last-allocation to total-aggregate
> 
> On 18 December 2014 the ARIN Advisory Council (AC) recommended
> ARIN-2014-17 for adoption, making it a Recommended 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 Draft Policy 2014-17 on the PPML prior to
> the upcoming ARIN Public Policy Consultation at NANOG 63 in San Antonio in February 2015. Both the discussion on the list and at the meeting will be used by the ARIN Advisory Council to determine the community consensus for adopting this as policy.
> 
> The ARIN Policy Development Process 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)
> 
> 
> ## * ##
> 
> 
> Recommended Draft Policy ARIN-2014-17
> Change Utilization Requirements from last-allocation to total-aggregate
> 
> Date: 19 October 2014
> 
> AC's assessment of conformance with the Principles of Internet Number Resource Policy:
> 
> This proposal enables fair and impartial number resource administration by removing an impediment to additional allocations seen by some organizations due to the shortening of the assignment window to three months and the gradual reduction of minimum block size over the past 5 years. This draft proposal applies equally to all organizations and now requires that any netblock show at least 50% utilization before an additional block can be allocated or assigned. The policy is clear and implementable as written. This proposal is technically sound. There are no technical issues which are raised by changing the utilization definition within the NRPM. This proposal is supported by the community. Support for this draft proposal has been growing as it has been discussed. Additional support from the community was seen as issues which were brought to the attention of the community by the first staff and legal assessment have been mitigated.
> 
> 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:
> 
> 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.
> 
> Timetable for implementation: Immediate
> 
> #####
> 
> ARIN STAFF ASSESSMENT
> 
> Draft Policy ARIN-2014-17
> Change Utilization Requirements from last-allocation to total-aggregate
> Date of Assessment: November 2014
> 
> 1. Summary (Staff Understanding)
> 
> This policy removes the current requirement to have efficiently utilized all previous allocations and assignments, and 80% of the most recent one, and replaces it with the requirement to have efficiently utilized all allocations and assignments in aggregate, to at least 80% overall, with at least a 50% utilization of every allocated or assigned block.
> 
> 2. Comments
> 
> A. ARIN Staff Comments
> 
> 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 could be implemented as written.
> 
> B. ARIN General Counsel - Legal Assessment
> 
> The policy does not present material legal issues. Allocation rules to address concerns of small ISP's indicate ARIN's continued attempts to balance the needs of stewardship with the needs of different sectors.
> 
> 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: 19 October 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:
> 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.
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