Makes sense to me. +1

…karl

> On Dec 24, 2014, at 11:21 AM, ARIN <[email protected]> wrote:
> 
> Recommended Draft Policy ARIN-2014-17
> Change Utilization Requirements from last-allocation to total-aggregate
> 
> On 18 December 2014 the ARIN Advisory Council (AC) recommended
> ARIN-2014-17 for adoption, making it a Recommended 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 Draft Policy 2014-17 on the PPML prior to
> the upcoming ARIN Public Policy Consultation at NANOG 63 in San Antonio in 
> February 2015. Both the discussion on the list and at the meeting will be 
> used by the ARIN Advisory Council to determine the community consensus for 
> adopting this as policy.
> 
> The ARIN Policy Development Process 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)
> 
> 
> ## * ##
> 
> 
> Recommended Draft Policy ARIN-2014-17
> Change Utilization Requirements from last-allocation to total-aggregate
> 
> Date: 19 October 2014
> 
> AC's assessment of conformance with the Principles of Internet Number 
> Resource Policy:
> 
> This proposal enables fair and impartial number resource administration by 
> removing an impediment to additional allocations seen by some organizations 
> due to the shortening of the assignment window to three months and the 
> gradual reduction of minimum block size over the past 5 years. This draft 
> proposal applies equally to all organizations and now requires that any 
> netblock show at least 50% utilization before an additional block can be 
> allocated or assigned. The policy is clear and implementable as written. This 
> proposal is technically sound. There are no technical issues which are raised 
> by changing the utilization definition within the NRPM. This proposal is 
> supported by the community. Support for this draft proposal has been growing 
> as it has been discussed. Additional support from the community was seen as 
> issues which were brought to the attention of the community by the first 
> staff and legal assessment have been mitigated.
> 
> 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:
> 
> Replace Section 4.2.4.1
> 
> ISPs must have efficiently utilized all allocations, in aggregate, to at 
> least 80% and at least 50% of every allocation in order to receive additional 
> space. This includes all space reassigned to their customers.
> 
> Replace Section 4.3.6.1
> 
> End-users must have efficiently utilized all assignments, in aggregate, to at 
> least 80% and at least 50% of every assignment in order to receive additional 
> space, and must provide ARIN with utilization details.
> 
> Timetable for implementation: Immediate
> 
> #####
> 
> ARIN STAFF ASSESSMENT
> 
> Draft Policy ARIN-2014-17
> Change Utilization Requirements from last-allocation to total-aggregate
> Date of Assessment: November 2014
> 
> 1. Summary (Staff Understanding)
> 
> This policy removes the current requirement to have efficiently utilized all 
> previous allocations and assignments, and 80% of the most recent one, and 
> replaces it with the requirement to have efficiently utilized all allocations 
> and assignments in aggregate, to at least 80% overall, with at least a 50% 
> utilization of every allocated or assigned block.
> 
> 2. Comments
> 
> A. ARIN Staff Comments
> 
> 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 could be implemented as written.
> 
> B. ARIN General Counsel - Legal Assessment
> 
> The policy does not present material legal issues. Allocation rules to 
> address concerns of small ISP's indicate ARIN's continued attempts to balance 
> the needs of stewardship with the needs of different sectors.
> 
> 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: 19 October 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:
> Replace Section 4.2.4.1
> ISPs must have efficiently utilized all allocations, in aggregate, to at 
> least 80% and at least 50% of every allocation in order to receive additional 
> space. This includes all space reassigned to their customers.
> Replace Section 4.3.6.1
> End-users must have efficiently utilized all assignments, in aggregate, to at 
> least 80% and at least 50% of every assignment in order to receive additional 
> space, and must provide ARIN with utilization details.
> _______________________________________________
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