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

Tue Mar 21 15:19:19 EDT 2017

I don't believe the originator still owns the text, but I would personally
accept
the insertion of alternatively.

This was indeed meant to be in addition, to other ways that you may try to
explain a two year need, here is a a tried and true way that ARIN will
accept
under very clear and measurable metrics.

Rather than "alternatively" it might be useful to clarify that this is "one
way"
demonstrate a two year need.  It isn't really an alternate mechanism.
But this is more of a nit than anything else, and I believe "alternatively"
will still yield the right behavior.

___Jason

On Tue, Mar 21, 2017 at 2:14 PM, Scott Leibrand <scottleibrand at gmail.com>
wrote:

> It seems that this could be read as more restrictive than current policy.
> To make sure it isn't, we could do something like add the word
> "Alternatively," before "organizations may demonstrate a 24 month future
> projection" at the beginning of the newly added text.
>
> Scott
>
> > On Mar 21, 2017, at 10:34 AM, ARIN <info at arin.net> wrote:
> >
> > 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
> > _______________________________________________
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-- 
_______________________________________________________
Jason Schiller|NetOps|jschiller at google.com|571-266-0006
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