[arin-ppml] Last call 2015-3

Wed Apr 27 07:10:48 EDT 2016

I am in support of this draft: Remove 30 day utilization requirement in
end-user IPv4 policy.
RD
On Apr 26, 2016 11:48 PM, <arin-ppml-request at arin.net> wrote:

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> Today's Topics:
>
>    1. Advisory Council Meeting Results - April 2016 (ARIN)
>    2. LAST CALL for Recommended Draft Policy ARIN-2015-3: Remove 30
>       day utilization requirement in end-user IPv4 policy (ARIN)
>
>
> ----------------------------------------------------------------------
>
> Message: 1
> Date: Mon, 25 Apr 2016 14:38:35 -0400
> From: ARIN <info at arin.net>
> To: arin-ppml at arin.net
> Subject: [arin-ppml] Advisory Council Meeting Results - April 2016
> Message-ID: <571E642B.5000101 at arin.net>
> Content-Type: text/plain; charset=utf-8; format=flowed
>
> In accordance with the ARIN Policy Development Process (PDP), the ARIN
> Advisory Council (AC) met on 20 April 2016.
>
> The AC moved the following to last call (to be posted separately to last
> call):
>
>    Draft Policy ARIN-2015-3: Remove 30 day utilization requirement in
> end-user IPv4 policy
>
> The AC abandoned the following:
>
>    Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for
> Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks
>
> The AC provided the following statement. "The ARIN AC abandoned 2015-9
> because there was insufficient community support to bring the proposal
> forward and there did not appear to be any potential changes to the
> proposal that were likely to significantly improve the level of support."
>
> The AC is continuing to work on:
>
>    Draft Policy ARIN-2015-2: Modify 8.4 (Inter-RIR Transfers to
> Specified Recipients)
>    Draft Policy ARIN-2015-7: Simplified requirements for demonstrated
> need for IPv4 transfers
>    Draft Policy ARIN-2016-1: Reserved Pool Transfer Policy
>
> The AC abandoned 2015-9. Anyone dissatisfied with this decision may
> initiate a petition. The deadline to begin a petition will be five
> business days after the AC's draft meeting minutes are published. For
> more information on starting and participating in petitions, see PDP
> Petitions at:
> https://www.arin.net/policy/pdp_petitions.html
>
> Draft Policy and Proposal texts are available at:
> https://www.arin.net/policy/proposals/index.html
>
> The ARIN Policy Development Process can be found at:
> https://www.arin.net/policy/pdp.html
>
> Regards,
>
> Communications and Member Services
> American Registry for Internet Numbers (ARIN)
>
>
> ------------------------------
>
> Message: 2
> Date: Mon, 25 Apr 2016 14:38:49 -0400
> From: ARIN <info at arin.net>
> To: arin-ppml at arin.net
> Subject: [arin-ppml] LAST CALL for Recommended Draft Policy
>         ARIN-2015-3: Remove 30 day utilization requirement in end-user IPv4
>         policy
> Message-ID: <571E6439.7010801 at arin.net>
> Content-Type: text/plain; charset=utf-8; format=flowed
>
> The ARIN Advisory Council (AC) met on 20 April 2016 and decided to
> send the following to last call:
>
>    Recommended Draft Policy ARIN-2015-3: Remove 30 day utilization
> requirement in end-user IPv4 policy
>
> Feedback is encouraged during the last call period. All comments should
> be provided to the Public Policy Mailing List. This last call will
> expire on 9 May 2016. After last call the AC will conduct their
> last call review.
>
> The draft policy text is below and available at:
> https://www.arin.net/policy/proposals/
>
> The ARIN Policy Development Process is available at:
> https://www.arin.net/policy/pdp.html
>
> Regards,
>
> Communications and Member Services
> American Registry for Internet Numbers (ARIN)
>
>
> ## * ##
>
>
> Recommended Draft Policy ARIN-2015-3
> Remove 30 day utilization requirement in end-user IPv4 policy
>
> AC's assessment of conformance with the Principles of Internet Number
> Resource Policy:
>
> ARIN 2015-3 contributes to fair and impartial number resource
> administration by removing from the NRPM text that is operationally
> unrealistic for the reasons discussed in the problem statement. This
> proposal is technically sound, in that the removal of the text will more
> closely align with the way staff applies the existing policy in relation
> to 8.3 transfers. There was strong community support for the policy on
> PPML and at ARIN 36, which was confirmed at ARIN 37. There was a
> suggestion to replace this text with an alternate requirement. However,
> the community consensus was to move forward with the removal alone.
>
> The staff and legal review also suggested removing RFC2050 references
> and pointed out that 4.2.3.6 has an additional 25% immediate use clause,
> community feedback was to deal with those issues separately.
>
> 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.
>
> Resulting text:
>
> 4.3.3. Utilization rate
>
> Utilization rate of address space is a key factor in justifying a new
> assignment of IP address space. Requesters must show exactly how
> previous address assignments have been utilized and must provide
> appropriate details to verify their one-year growth projection.
>
> The basic criterion that must be met is a 50% utilization rate within
> one year.
>
> A greater utilization rate may be required based on individual network
> requirements. Please refer to RFC 2050 for more information on
> utilization guidelines.
>
> Comments:
>
> a.Timetable for implementation: Immediate
>
> b.Anything else
>
> #####
>
> ARIN STAFF ASSESSMENT
>
> Draft Policy ARIN-2015-3
> Remove 30 day utilization requirement in end-user IPv4 policy
> Date of Assessment: 16 February 2016
>
> ___
> 1. Summary (Staff Understanding)
>
> This proposal would remove the 25% utilization (within 30 days of
> issuance) criteria bullet point from NRPM 4.3.3.
>
> ___
> 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.
>
> ___
> 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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> End of ARIN-PPML Digest, Vol 130, Issue 34
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