[arin-ppml] Draft Policy ARIN-2015-3: Remove 30 day utilization requirement in end-user IPv4 policy

[Jason Schiller]

I also find the 25% utilization in 30 days problematic for the simple
reason that renumbering out of PA space, or turning up new equipment often
takes more than 30 days.

Imagine a case were an end user has a real commitment to deploy five new
offices each with ~210 employees (each employee with a single desktop) over
the next quarter.  Office space is leased, computers are bought,
construction is on going for all five sites, and one site is scheduled to
go live in 45 days, 250 offers have been extended for the first site, 50
have accepted, another 200 candidates are in the interview pipeline for the
other two sites with a scheduled go live date in the next 60 days.

Based on this growth rate, it is likely that 20 sites with approximately
210 employees (and desktops) each will be deployed in the next 12 months.

It is anticipated that it will take 45 days to get the 210 computers at the
new site physically setup on desks, and connected to a working LAN, with
working Internet access.

The organization has on hand enough equipment to number 82% of five /24s.
With a real one year projection based on past growth for filling 82% of
twenty /24s over the next year.

One would think this should be sufficient justification for at least a /21
(five /24s round up to eight /24s or a /21) with a real commitment already
underway to use these addresses.  Once in service more than 50% of a /21
will be in use.

There are also a projection for a total of twenty /24s at 82% utilization
or 51% of
/19 over the next year.

This sounds like it should be a good justification for a /20 or a /19.

I think the 25% requirement in 30 days is unreasonable, especially when an
organization is already committed but the work will take longer than 30
days.  But 50% of a purely future looking projection is not strong enough.

I think a one year projection based and past one year growth with all
currently held subnets 50% full, or 80% usage of all space held, and a
commitment to plans to start using the space should be sufficient.

I don't know how to deal with initial allocation or slow start especially
in a transfer market, but we need to solve that problem wrt ISP, and
suspect that slow start mechanism could apply here.

___Jason


On May 26, 2015 5:25 PM, "William Herrin" <bill at herrin.us> wrote:

> On Tue, May 26, 2015 at 3:52 PM, David Huberman
> <David.Huberman at microsoft.com> wrote:
> > The 25% text applies not only to initial assignments, but to:
> > - additional assignments
> > - transfers
>
> Then change the 25% 30-day requirement to apply in aggregate across
> all direct assignments held by the organization instead of applying to
> just the most recent.
>
>
> > - criteria used by ISPs to determine justification for downstream
> assignments
>
> You are aware of an incident where an end-user could not get a
> reasonable IP addresses assignment from an ISP -solely- because they
> could not meet a 25% initial use requirement? Absent a case study, I'm
> not inclined to find that argument compelling.
>
> Regards.
> Bill Herrin
>
>
>
>
> --
> William Herrin ................ herrin at dirtside.com  bill at herrin.us
> Owner, Dirtside Systems ......... Web: <http://www.dirtside.com/>
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