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

Fri May 6 05:58:29 EDT 2016

I support the policy proposal as written.

regards,
elvis

On 5/5/16 6:45 PM, David Farmer wrote:
> As shepherd for this policy I welcome any additional last call
> feedback for this policy.  It is especially important to speak up if
> you feel there are any issues remaining that need to be considered.
> But, even if you simply support the policy as written that is
> important and useful feedback as well.
>
> The last call period formally continues through, Monday, May 9th, and
> the AC will consider the feedback during its scheduled call on
> Thursday, May 19th.
>
> Thanks
>
> On Mon, Apr 25, 2016 at 1:38 PM, ARIN <info at arin.net> wrote:
>> 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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>
>