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

[Owen DeLong]

Personally, I oppose the proposal.

I do not believe this levels the playing field, but rather tilts it to the advantage of those holding space from their providers already.

An organization holding no space has nothing to efficiently utilize and is starting from zero, same as those other organizations presumably did back when they were able to obtain space from their upstream. They could have chosen to gett that initial space from ARIN, but opted for provider assigned space instead for whatever reason. In any case, they have space already and are either looking to expand or are looking to replace that provider assigned space. In the former case, they are on the same playing field as anyone looking to expand today. In the latter case, they have the advantage of being able to continue using their provider assigned space while waiting, so any disadvantage they may face is rather limited and is the result of their own past decisions.

Owen


> On Dec 16, 2020, at 2:17 PM, Amy Potter <amybpotter at gmail.com> wrote:
> 
> 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 <mailto: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/ <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/ <https://www.arin.net/participate/policy/pdp/>
> 
> Draft Policies and Proposals under discussion can be found at:
> https://www.arin.net/participate/policy/drafts/ <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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> 
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