[arin-ppml] Draft Policy ARIN-2015-3: Remove 30-Day Utilization Requirement in End-User IPv4 Policy

[Leif Sawyer]

Apologies to the list.  The actual text of draft ARIN-2015-3 did not attach correctly.

The current draft text can also be located at: https://www.arin.net/policy/proposals/2015_3.html

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Draft Policy ARIN-2015-3
Remove 30 day utilization requirement in end-user IPv4 policy

Date: 26 May 2015

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 removed.

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.

Policy statement:

Remove the 25% utilization criteria bullet point from NRPM 4.3.3.

Comments:

a.Timetable for implementation: Immediate

b.Anything else




-----Original Message-----
From: Leif Sawyer 
Sent: Tuesday, September 08, 2015 11:10 AM
To: arin-ppml at arin.net
Subject: Draft Policy ARIN-2015-3: Remove 30-Day Utilization Requirement in End-User IPv4 Policy

ARIN Legal and Staff have conducted a review of Draft Policy 2015-3.

ARIN Advisory Council are seeking any additional feedback on this draft policy, prior to public discussion at ARIN 36 in Montreal next month.


The text of the staff review is below:
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Date of Assessment:  18 August 2015
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1.  Summary (Staff Understanding)
 
This proposal would remove the 25% utilization (within 30 days of issuance) criteria bullet point from NRPM 4.3.3.

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2.  Comments
A.  ARIN Staff Comments
 
This policy would more closely align with the way staff applies the existing policy in relation to 8.3 transfers. Because there is no longer an IPv4 free pool and many IPv4 requests are likely to be satisfied by 8.3 transfers, the adoption of this policy should have no major impact on operations and could be implemented as written.
 
Note that both NRPM 4.3.3 and NRPM 4.2.3.6 contain references to obsolete RFC 2050.  Additionally, 4.2.3.6 references the 25% immediate use (within 30 days of issuance) requirement.
 
Staff suggests removing the first two sentences of 4.2.3.6 to remove the references to RFC 2050 and the 25% requirement.  Additionally, staff suggests removing the reference to the obsolete RFC 2050 in section 4.3.3.
 
B.  ARIN General Counsel – Legal Assessment

No material legal risk in this policy.

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3.  Resource Impact
 
This policy would have minimal resource impact from an implementation aspect.  It is estimated that implementation would occur immediately after ratification by the ARIN Board of Trustees. The following would be needed in order to implement:
 * Updated guidelines and internal procedures
 * Staff training
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