[arin-ppml] Draft Policy ARIN-2017-1: Clarify Slow Start for Transfers

[ARIN]

On 16 March 2017, the ARIN Advisory Council (AC) accepted 
"ARIN-prop-237: Clarify Slow Start for Transfers" as a Draft Policy.

Draft Policy text is below and can be found at:
https://www.arin.net/policy/proposals/2017_1.html

You are encouraged to discuss all Draft Policies on PPML. The AC will 
evaluate the discussion in order to assess the conformance of this draft 
policy with ARIN's Principles of Internet Number Resource Policy as 
stated in the Policy Development Process (PDP). Specifically, these 
principles are:

  * Enabling Fair and Impartial Number Resource Administration
  * Technically Sound
  * Supported by the Community

The PDP can be found at:
https://www.arin.net/policy/pdp.html

Draft Policies and Proposals under discussion can be found at:
https://www.arin.net/policy/proposals/index.html

Regards,

Sean Hopkins
Policy Analyst
American Registry for Internet Numbers (ARIN)



Draft Policy ARIN-2017-1: Clarify Slow Start for Transfers

Date: 21 March 2017

With the adoption of 2015-5, transfer policy is severed from ARIN 
allocation / assignment policy.  It is no longer clear how slow start 
applies (if at all) to justifying a transfer.  Having a slow start 
algorithm available to the transfer market will make for a more 
predictable and more right sized blocks in line with organizational growth.

Problem Discussion:

In a pre-transfer world ISPs who are growing rapidly, or have no history 
of utilization to support their IPv4 two year growth requirements, could 
qualify under slow start.

The initial block was either a small block (between /24 and /21), or 
double what they efficiently used in the previous year.  If thate space 
was used in less than a year, they could get twice as much the next time.

The implementation of Policy 2016-5 severs transfer policy form section 
4 where the slow start rules are defined.  As a result it is unclear if 
the slow start process can be used to justify a specified transfer.

Additionally, the inability to complete regular transfers could lead to 
a situation where lack of IPv4 addresses is rate limiting deployment. As 
a result demonstrated utilization of the last 12 months may not be 
indicative of actual growth.

NRPM 8.5.3 / 8.5.4 (ARIN Policy 2016-4) supports an initial block of 
only a /24 if there is no allocation or assignment.

Policy Proposal 2016-3 (the sister policy to 2016-4) supports a larger 
block (after demonstration of efficient utilization) equal to their 
current holdings up to a /16 every 6 months.

Because 2016-3 no longer permits using a /16 at a time and demonstrating 
utilization before coming back for another, organizations who are 
growing at more than a /15 a year are forced to use the two year forward 
looking projected growth as justification.

This prediction is difficult to measure, difficult to justify, difficult 
to verify, and provides unpredictability to the amount of time a 
justification requires to be processed, and the likelihood of approval. 
  This process favors organizations who more aggressively optimistic and 
has no penalty if an organization fails to meet their plans.

Problem solution:

Permit organizations who demonstrate efficient utilization to use the 
utilization of their most recent specified transfer(s) to extrapolate a 
two year growth projection allowing a specified transfer of up to double 
the size of the transfers used in the justification.

Policy statement:

Current policy:

8.5.5. Block size

Organizations may qualify for the transfer of a larger initial block, or 
an additional block, by providing documentation to ARIN which details 
the use of at least 50% of the requested IPv4 block size within 24 
months. An officer of the organization shall attest to the documentation 
provided to ARIN.

Proposed changes:

Add the following to the end of 8.5.5:

Organizations may demonstrate a 24 month future projection based on the 
average amount of time required to efficiently utilize one or more of 
their most recent specified transfers.

The organization must show efficient utilization of at least 50% of all 
specified transfers from the current date back to the the date of the 
earliest specified transfer included in the request.  The organization 
will be pre-authorized for a two year window to complete one or more 
specified transfers up to the total number of IPv4 addresses of the 
transfers included in the request, divided by the number of days (no 
less than 90) since the earliest specified transfer included in the 
request was completed, multiplied by 730.

Comments:

Timetable for implementation: Immediate