I would support option 3. Owen
On Sep 30, 2014, at 11:06 , Leif Sawyer <[email protected]> wrote: > Delaying implementation until further down the run-out line doesn't help orgs > with current needs. > > > I think that as the "spirit" of this is to help out the smaller organizations, > the argument could easily be made that limiting this to orgs with < 18 isn't > needlessly hurtful toward larger orgs. > > And thus I would be in support of -that- modification. > > > Additionally, I would also be in support of a "minimum utilization" of 50% > for allocated blocks, > as this makes it harder for larger orgs to game the system. > > > > -----Original Message----- > From: [email protected] [mailto:[email protected]] On > Behalf Of Andrew Dul > Sent: Tuesday, September 30, 2014 9:01 AM > To: [email protected] > Subject: Re: [arin-ppml] Draft Policy ARIN-2014-17: Change Utilization > Requirements from last-allocation to total-aggregate > > Hello, > > The staff and legal assessment below noted some concerns regarding this > policy. To alleviate some of these concerns we have thought about the > following three changes to the draft policy. > > 1. Delay implementation of the policy, such that the free pool was small > enough that a large organization could not obtain additional allocations > primarily though the implementation of this policy. Triggers considered > include, largest block in free pool being a /16 or total amount of address > space in the free pool < /12. > > 2. Add a requirement that any one block must be utilized to at least 50%. > > 3. Limiting this policy to organizations which have less than an aggregate > /18 equivalent. > > Do you support any of these additions? Please also state if you support the > current policy draft. > > Thanks, > Andrew > > On 9/19/2014 1:05 PM, ARIN wrote: >> 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. >> >> _______________________________________________ >> PPML >> You are receiving this message because you are subscribed to the ARIN >> Public Policy Mailing List ([email protected]). >> Unsubscribe or manage your mailing list subscription at: >> http://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact [email protected] if you experience any issues. > > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to the ARIN Public > Policy Mailing List ([email protected]). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact [email protected] if you experience any issues. > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List ([email protected]). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact [email protected] if you experience any issues. _______________________________________________ PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List ([email protected]). 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