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

[Brian Jones]

I support as written.

--
Brian Jones
On May 5, 2016 11:45 AM, "David Farmer" <farmer at umn.edu> 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
> > _______________________________________________
> > PPML
> > You are receiving this message because you are subscribed to
> > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
> > Unsubscribe or manage your mailing list subscription at:
> > http://lists.arin.net/mailman/listinfo/arin-ppml
> > Please contact info at arin.net if you experience any issues.
>
>
>
> --
> ===============================================
> David Farmer               Email:farmer at umn.edu
> Networking & Telecommunication Services
> Office of Information Technology
> University of Minnesota
> 2218 University Ave SE        Phone: 612-626-0815
> Minneapolis, MN 55414-3029   Cell: 612-812-9952
> ===============================================
> _______________________________________________
> PPML
> You are receiving this message because you are subscribed to
> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
> Unsubscribe or manage your mailing list subscription at:
> http://lists.arin.net/mailman/listinfo/arin-ppml
> Please contact info at arin.net if you experience any issues.
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://lists.arin.net/pipermail/arin-ppml/attachments/20160510/eefc7831/attachment.htm>