Draft Policy ARIN-2014-17
Change Utilization Requirements from last-allocation to total-aggregate
Here is the staff assessment of ARIN-2014-17.
Regards,
Communications and Member Services
American Registry for Internet Numbers (ARIN)
## * ##
ARIN STAFF ASSESSMENT
Date of Assessment: 26 August 2014
Draft Policy ARIN-2014-17
Change Utilization Requirements from last-allocation to total-aggregate
1. Summary (Staff Understanding)
This policy removes the current requirement to have efficiently utilized
all previous allocations, and 80% of the most recent one and replaces it
with the requirement to have efficiently utilized all allocations, in
aggregate, to at least 80% overall.
2. Comments
A. ARIN Staff Comments
· The intent of the policy seems to be to make it easier for all ISPs to
qualify for additional allocations by requiring an 80% utilization rate
of all blocks (in aggregate) rather than 80% of the most recent block.
o Based on staff experience, the 80% utilization rate of the last block
has been periodically problematic for smaller ISPs, but not for medium
to larger ISPs. Staff has seen situations where a small ISP with a /22
may need to issue a /24 to a customer but not have any available, not be
at 80% utilized, and therefore, not be able to request additional space.
· This policy gives ISPs no incentive to efficiently utilize their IPv4
resources beyond the minimum 80% overall requirement.
· This policy would allow larger, well established ISPs with many
allocations from ARIN to be able to qualify for additional IP address
space without ever having used their last allocation at all.
o For example, an ISP that is currently close to 100% utilization of its
multiple prefixes totaling 25,000 /24s justifies and receive an
additional /16 would immediately qualify for more space even though they
used 0% of their last allocation.
o Another example would be this same ISP with 25,000 /24s at 80%
utilization could request an additional /16 even though they still have
5,000 /24s free (which could include up to approximately 20 unused /16s).
· This proposal could be implemented as written.
B. ARIN General Counsel - Legal Assessment
"I have a single material legal concern about the draft policy.
Community standards for allocation policies should adequately address
the fairness of their criterion and impact on all market segments:
large, medium and small companies. This proposed policy would make a
major change in how a bedrock allocation evaluation criteria, changing
how utilization is measured for everyone, in order to address the
occasional corner case where a small company might have to make an
allocation that it has insufficient allocated resources to provide. but
cannot get over the 80% utilization as currently measured. While the
small company problem is potentially worthy of review and action, the
proposed policy has the unintended but clear impact of creating
additional new allocation entitlements where none exist for larger
companies. While ARIN still has resources remaining in the IPv4 free
pool, larger companies will gain significant benefit from this change
compared to the number of small company corner cases that it will close.
From a legal standpoint it would be more attractive for the community
to reach a better balance in this area."
3. Resource Impact
This policy would have minimal resource impact from an implementation
aspect. It is estimated that implementation would occur within 3 months
after ratification by the ARIN Board of Trustees. The following would be
needed in order to implement:
· Updated guidelines and internal procedures
· Staff training
4. Proposal/Draft Policy Text Assessed
Draft Policy ARIN-2014-17 Change Utilization Requirements from
last-allocation to total-aggregate
Date: 14 July 2014
Problem Statement:
Current ARIN policy calculates utilization on a per allocation basis
rather than in aggregate. This method of determining utilization may
cause some organizations to be unable to qualify for additional address
blocks despite attempting to use their resource allocations as best as
possible. This issue has been exacerbated in the past couple of years
due to the 3-month allocation window which causes organizations to
receive smaller non-expandable allocations rather than a larger aggregate.
For example, if an organization has 4 x /22 and 3 of them are utilized
100% and the fourth utilized at 75%, an additional allocation request
would be denied. However, an organization with a single /20 utilized at
80% would have less efficient utilization but would be eligible to
receive additional space.
Policy statement:
Update Section 4.2.4.1
ISPs must have efficiently utilized all allocations, in aggregate, to at
least 80% in order to receive additional space. This includes all space
reassigned to their customers.
Update Section 4.3.6.1
End-users must have efficiently utilized all assignments, in aggregate,
to at least 80% in order to receive additional space, and must provide
ARIN with utilization details.
On 7/14/14, 2:53 PM, ARIN wrote:
Draft Policy ARIN-2014-17
Change Utilization Requirements from last-allocation to total-aggregate
ARIN-2014-17 has been revised.
Draft Policy ARIN-2014-17 is below and can be found at:
https://www.arin.net/policy/proposals/2014_17.html
You are encouraged to discuss the merits and your concerns of Draft
Policy 2014-17 on the Public Policy Mailing List.
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 PDP. Specifically, these principles are:
* Enabling Fair and Impartial Number Resource Administration
* Technically Sound
* Supported by the Community
The ARIN Policy Development Process (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,
Communications and Member Services
American Registry for Internet Numbers (ARIN)
## * ##
Draft Policy ARIN-2014-17
Change Utilization Requirements from last-allocation to total-aggregate
Date: 14 July 2014
Problem Statement:
Current ARIN policy calculates utilization on a per allocation basis
rather than in aggregate. This method of determining utilization may
cause some organizations to be unable to qualify for additional address
blocks despite attempting to use their resource allocations as best as
possible. This issue has been exacerbated in the past couple of years
due to the 3-month allocation window which causes organizations to
receive smaller non-expandable allocations rather than a larger aggregate.
For example, if an organization has 4 x /22 and 3 of them are utilized
100% and the fourth utilized at 75%, an additional allocation request
would be denied. However, an organization with a single /20 utilized at
80% would have less efficient utilization but would be eligible to
receive additional space.
Policy statement:
Update Section 4.2.4.1
ISPs must have efficiently utilized all allocations, in aggregate, to at
least 80% in order to receive additional space. This includes all space
reassigned to their customers.
Update Section 4.3.6.1
End-users must have efficiently utilized all assignments, in aggregate,
to at least 80% in order to receive additional space, and must provide
ARIN with utilization details.
Comments:
a. Timetable for implementation: Immediate
b.
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