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

Thu Jan 28 16:52:04 EST 2016

I support the removal of the 30 day utilization as it is unreasonable for
any larger end-site, who may have a real need for say a /16, with 65,000
desktops arriving on a loading doc next week, but an inability to unbox,
configure and deploy 16,384 to the various office locations in 30 days.

However, this is the only provision that has a real, tangible, and
verifiable claim.  Without this check justified need for end users simply
becomes a 1 year future looking projection, and with sufficient arm waving
an easy end run around justified need for any end user with no IP space or
if they are efficiently using what they currently hold.

I could get on board if the maximum sized block permitted on a purely
future looking projection was a /24 and you had to use it prior to getting
more.

I could certainly get on board if there were some other tangible and
verifiable claim to show there was a real commitment to use half the
address space within one year.

__Jason

On Thu, Jan 28, 2016 at 8:55 AM, Brian Jones <bjones at vt.edu> wrote:

> Looks good to me Dave. I am okay with using criteria or criterion, however
> using the strict definition it looks as though criterion is the proper
> singular form.
>
> --
> Brian
>
> On Wed, Jan 27, 2016 at 5:54 PM, David Farmer <farmer at umn.edu> wrote:
>
>> The following is the proposed update for ARIN-2015-3: Remove 30-Day
>> Utilization Requirement in End-User IPv4 Policy based on strong support in
>> Montreal.
>>
>> Beyond deleting the 25% bullet as the policy says, their are editorial
>> changes as follows to the remaining text;
>>
>> - It looks weird to have single item bullet list, so merge the two
>> remaining sentence fragments into a single sentence.
>> - Change "are" to "is", since there is only one remaining criteria
>> - Use of "criteria" as a singular is common usage, even though
>> technically it's plural.
>> - Resulting in "The basic criteria that must be met is a 50% utilization
>> rate within one year."
>>
>> The remaining and resulting text for 4.3.3 is now included in the policy
>> text, for editorial clarity.  The original staff and legal suggested
>> removing the RFC2050 reference and also pointed out that
>> 4.2.3.6 also has a 25% immediate use clause and a RFC2050 reference.
>>
>> Feedback in Montreal was that deleting the 25% immediate use was a nice
>> bite-sized change, and we shouldn't try to do more than that with this
>> change, so those changes are not included at this time.
>>
>> Any additional feedback or comments are appreciated.
>>
>> Thanks
>>
>> ---------
>>
>> Draft Policy ARIN-2015-3: Remove 30 day utilization requirement in
>> end-user IPv4 policy
>>
>> Date: 27 January 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.
>>
>> 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 criteria 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
>>
>> --
>> ================================================
>> David Farmer               Email: farmer at umn.edu
>> Office of Information Technology
>> University of Minnesota
>> 2218 University Ave SE     Phone: 1-612-626-0815
>> Minneapolis, MN 55414-3029  Cell: 1-612-812-9952
>> ================================================
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>
>
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-- 
_______________________________________________________
Jason Schiller|NetOps|jschiller at google.com|571-266-0006
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