[arin-ppml] ARIN-2015-3:(remove 30-day...) Staff interpretation needed

[John Curran]

On Apr 25, 2016, at 12:47 PM, Jason Schiller <jschiller at google.com<mailto:jschiller at google.com>> wrote:
...
I suspect the 30 days part does (to some extent) regulate outrageously large claims, as this is a real short term verifiable commitment.  Without a possibility of a 30 day check you simply fall back to an officer attestation of a two year projected need claim.

I am trying to figure out what is the likely impact of only requiring a two year projected need claim.  So my questions are regarding to what level of push back ARIN provides against two year projected need in general, and will that be sufficient to prevent outlandishly large claims.

Maybe another way to get at this is to compare end user transfer stats to ISP transfer stats.
- what percentage of ISP specified transfers are justified by past growth?  by a two year projection?
- what percentage of end user specified transfers are justified by past growth?  by a two year projection?
- what is the average size of ISP specified transfers that are justified by past growth?  by a two year projection?
- what is the average size of end user specified transfers that are justified by past growth?  by a two year projection?
- do we see a greater gap between average ISP size between specified transfers that are justified by past growth vs. by a two year projection?
- do we see a greater percentage of ISP transfers justified by a 2 year projection than end users?

Jason -

    While we dp collect statistics on the number of requests and outcomes, we do
    not have the instrumentation of the needs-assessment process that would be
    necessary to produce the type of statistics you request.  It is also not clear that
    such instrumentation would allow us to provide an exact percentage of requests
    that are approved based on past growth vs. projections because ARIN takes
    both factors into account when evaluating operational need.

    In order to provide some insight into how the needs-assessment process operates
    with respect to past growth versus projection, we’ve provided several examples on
    how the needs-assessment process would unfold for various 8.3 specified transfer
    scenarios detailed below.

    When an existing ARIN account, ISP or End-User, requests an 8.3 Recipient
    Transfer, ARIN will look at their historical utilization and determine the organizations
    average 24-month usage trend.  We will compare that to what they are currently
    requesting to have transferred and determine if that amount aligns with their prior
    utilization trend. If it does align directly, then we consider that the justification for
    their 24-month stated need, but often we have to also give some consideration to
    the information they provide regarding future plans and potential impact on growth
    rate.

=== Example A
An existing ARIN Organization requests a /16 transfer via 8.3 transfer process.
They previously received the following IPv4 address space:
/17 in December 2015
/17 in October 2015
/18 in July 2015
/19 in June 2015
/20 in May 2015
/20 in February 2015

In this example, ARIN would request 24-month projections AND utilization information from the organization. We would verify they have utilized their previously received IPv4 blocks in accordance with policy and determine their utilization trend. In this example, the organization has fully utilized their previous allocations and we note their historical utilization of 384 /24s over the past 18 months. Even though we are also taking their future plans into consideration, their prior utilization trend is heavily weighted in justifying the newly requested /16 and they are approved. Their prior 24 months of utilization exceeds what they are requesting for the next 24 months.

=== Example B
An existing ARIN Organization requests a /16 transfer via 8.3 transfer process.
They previously received the following IPv4 address space:
/19 in December 2015
/20 in October 2015
/21 in July 2015
/22 in June 2015
/23 in May 2015

In this example, ARIN would again request 24-month projections AND utilization information from the organization.  We would verify they have utilized their previously received IPv4 blocks in accordance with policy and determine their utilization trend.  In this example, the organization has fully utilized their previous allocations and we note their historical utilization trend of 62 /24s over the past 11 months. Their prior utilization suggests a utilization trend of 136 /24s over a 24-month period (62 / 11 * 24mos = 135.3 or 136).  The organization’s 24-month utilization trend does not meet or exceed the amount of IPv4 address space they are requesting for the next 24-month period, so the information they provide regarding their future plans/need is more heavily weighted by ARIN staff. The information provided regarding future need paired with their utilization trend allows for an approval for the requested size (/16).

=== Example C
An existing ARIN Organization requests a /16 transfer via 8.3 transfer process.

Without providing the further background details, the requesting organization in this example has utilized their previously received blocks in accordance with policy and has a 24-month utilization trend of 65 /24s. The organization’s 24-month utilization trend does not meet or exceed the amount of IPv4 address space they are requesting for the next 24-month period, so the information they provide regarding their future plans/need is more heavily weighted by ARIN staff. The future need projections only slightly increase expected future utilization over their prior utilization trend and a need for 100 /24s is determined for the next 24-month period. Unfortunately, the information provided regarding future need paired with their utilization trend does not allow for the approval of the requested /16, and a /17 (closest prefix size above their demonstrated need amount) is approved instead.
===

   Similarly, if a new organization comes to ARIN for an 8.3 Recipient Transfer we
   would base their approval on any provider assigned space they are currently using
   and their projections. We would do this similar to the examples noted above.

   It is important to note that if a new organization comes to ARIN and isn't using any
   provider assigned space, we are only be able to base their approval amounts based
   on their projections.

   When we ask organization for their forward projections, we also ask them to provide
   details to show how they've arrived at their projections. We take into account factors
   such as new networks, locations, products, services they plan on offering (and this
   includes consideration of anticipated address utilization within the first 30 days for
   end-users.)

   Given we take all of these factors into account (and noting that we don’t precisely track if
   they qualified more heavily on historical usage vs. projections), we would estimate between
   50-75% of the approval decisions made are more heavily weighted by historical utilization
   trend information. It is important to note that the historical utilization trend information often
   allows for an approval size equal to or greater than what is requested by most organizations.

While this is not the level of detail that you desire, I hope it provides some useful insight
into the role of the future projections in the needs-assessment process.

Best wishes on your policy development efforts!
/John

John Curran
President and CEO
ARIN




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