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

[Amy Potter]

Hi ppml,

We haven't seen a lot of support for ARIN 2020-10 since it's introduction.
This proposal arose out of a policy experience report, but we've seen very
little said about it from anyone that thinks this is a problem that needs
to be solved or that the current text of NRPM here is negatively impacting
their organization. We've heard from a few members of the community who are
opposed to the proposal, and those who believe the current distinction
between organizations that already have reassignments/reallocations from
their upstreams and organizations with no space at all makes sense.  We'd
like to give the community one last chance to speak out in favor of this
proposal before abandoning it. If you think this is a problem that needs to
be solved, please let us know.

Best,

Amy

***

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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