[arin-ppml] Draft Policy 2020-10: Requirement to Demonstrate Utilization of Reassignments and Reallocations for ISPs Seeking Initial Allocation from ARIN

[Amy Potter]

Hello ppml community!

I just wanted to recirculate Draft Policy ARIN 2020-10 for feedback. This
draft policy would remove the requirement that ISPs that already hold
reallocations or reassignments from upstream providers satisfy ARIN's
efficient utilization requirements for those reallocations/reassignments
before they are able to qualify for their initial allocation of space
directly from ARIN, and get on the waitlist to receive that space.

Under current policy a new ISP that does not have any reallocations or
reassignments qualifies for a /24 without having to establish efficient
utilization of any previous space. This allows new ISPs to get on the
waitlist sooner than ISPs holding reassignments/reallocations, despite the
fact that neither type of organization holds space directly from ARIN yet.

1.  Do you believe that NRPM's current distinction between ISPs holding
reassignments/reallocations and new ISPs without any
reallocations/reassignments still makes sense today?

2.  Is leveling the playing field by allowing all ISPs that do not
currently hold space directly from ARIN to qualify for a /24 without
demonstrating prior use--regardless of whether or not they hold
reallocations/reassignments--a fair solution that reflects the realities
faced by these organizations today?

Thanks!

Amy

On Tue, Nov 24, 2020 at 12:47 PM ARIN <info at arin.net> wrote:

> On 19 November 2020, the ARIN Advisory Council (AC) accepted
> "ARIN-prop-293: Requirement to Demonstrate Utilization of Reassignments and
> Reallocations for ISPs Seeking Initial Allocation from ARIN" as a Draft
> Policy.
>
> Draft Policy ARIN-2020-10 is below and can be found at:
>
> https://www.arin.net/participate/policy/drafts/2020_10/
>
> 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/participate/policy/pdp/
>
> Draft Policies and Proposals under discussion can be found at:
> https://www.arin.net/participate/policy/drafts/
>
> Regards,
>
> Sean Hopkins
> Policy Analyst
> American Registry for Internet Numbers (ARIN)
>
>
>
> Draft Policy 2020-10: Requirement to Demonstrate Utilization of
> Reassignments and Reallocations for ISPs Seeking Initial Allocation from
> ARIN
>
>
>
> Problem Statement:
>
>
>
> 4.2.2 seems to provide an unfair advantage to ISPs without any IP address
> holdings - that is, they don’t have any direct assignments or allocations,
> nor any reassignments or reallocations from another organization.
>
>
>
> If an ISP does already have holdings in the form of reassignments or
> reallocations, and they request a /24, or even a /29 as an initial
> allocation - they are required to provide utilization data. This slows
> their advancement to the waiting list compared to a new ISP without any
> holdings at all. An organization without reassignments or reallocations
> doesn’t need to provide any justification other than submitting the request
> and providing an officer attestation. This expedites their addition to the
> waiting list.
>
>
>
> Policy Statement:
>
>
>
> Replace 4.2.2 with the following:
>
>
>
> 4.2.2. Initial Allocation to ISPs
>
>
>
> All ISP organizations automatically qualify for a /24.These organizations
> may qualify for more than a /24 by documenting how the requested allocation
> will be utilized within the request size specified in 4.2.4.3.
>
>
>
> ISP organizations without direct assignments or allocations from ARIN
> qualify for an initial allocation of up to a /22, subject to ARIN’s minimum
> allocation size.
>
>
>
> Timetable for implementation: Immediate.
>
>
>
> Comments:
>
>
>
> This proposal was written as the result of a Policy Experience Report.
>
>
>
>
>
>
>
>
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