It seems that this could be read as more restrictive than current policy. To make sure it isn't, we could do something like add the word "Alternatively," before "organizations may demonstrate a 24 month future projection" at the beginning of the newly added text.
Scott > On Mar 21, 2017, at 10:34 AM, ARIN <[email protected]> wrote: > > On 16 March 2017, the ARIN Advisory Council (AC) accepted "ARIN-prop-237: > Clarify Slow Start for Transfers" as a Draft Policy. > > Draft Policy text is below and can be found at: > https://www.arin.net/policy/proposals/2017_1.html > > 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/policy/pdp.html > > Draft Policies and Proposals under discussion can be found at: > https://www.arin.net/policy/proposals/index.html > > Regards, > > Sean Hopkins > Policy Analyst > American Registry for Internet Numbers (ARIN) > > > > Draft Policy ARIN-2017-1: Clarify Slow Start for Transfers > > Date: 21 March 2017 > > With the adoption of 2015-5, transfer policy is severed from ARIN allocation > / assignment policy. It is no longer clear how slow start applies (if at > all) to justifying a transfer. Having a slow start algorithm available to > the transfer market will make for a more predictable and more right sized > blocks in line with organizational growth. > > Problem Discussion: > > In a pre-transfer world ISPs who are growing rapidly, or have no history of > utilization to support their IPv4 two year growth requirements, could qualify > under slow start. > > The initial block was either a small block (between /24 and /21), or double > what they efficiently used in the previous year. If thate space was used in > less than a year, they could get twice as much the next time. > > The implementation of Policy 2016-5 severs transfer policy form section 4 > where the slow start rules are defined. As a result it is unclear if the > slow start process can be used to justify a specified transfer. > > Additionally, the inability to complete regular transfers could lead to a > situation where lack of IPv4 addresses is rate limiting deployment. As a > result demonstrated utilization of the last 12 months may not be indicative > of actual growth. > > NRPM 8.5.3 / 8.5.4 (ARIN Policy 2016-4) supports an initial block of only a > /24 if there is no allocation or assignment. > > Policy Proposal 2016-3 (the sister policy to 2016-4) supports a larger block > (after demonstration of efficient utilization) equal to their current > holdings up to a /16 every 6 months. > > Because 2016-3 no longer permits using a /16 at a time and demonstrating > utilization before coming back for another, organizations who are growing at > more than a /15 a year are forced to use the two year forward looking > projected growth as justification. > > This prediction is difficult to measure, difficult to justify, difficult to > verify, and provides unpredictability to the amount of time a justification > requires to be processed, and the likelihood of approval. This process > favors organizations who more aggressively optimistic and has no penalty if > an organization fails to meet their plans. > > Problem solution: > > Permit organizations who demonstrate efficient utilization to use the > utilization of their most recent specified transfer(s) to extrapolate a two > year growth projection allowing a specified transfer of up to double the size > of the transfers used in the justification. > > Policy statement: > > Current policy: > > 8.5.5. Block size > > Organizations may qualify for the transfer of a larger initial block, or an > additional block, by providing documentation to ARIN which details the use of > at least 50% of the requested IPv4 block size within 24 months. An officer of > the organization shall attest to the documentation provided to ARIN. > > Proposed changes: > > Add the following to the end of 8.5.5: > > Organizations may demonstrate a 24 month future projection based on the > average amount of time required to efficiently utilize one or more of their > most recent specified transfers. > > The organization must show efficient utilization of at least 50% of all > specified transfers from the current date back to the the date of the > earliest specified transfer included in the request. The organization will > be pre-authorized for a two year window to complete one or more specified > transfers up to the total number of IPv4 addresses of the transfers included > in the request, divided by the number of days (no less than 90) since the > earliest specified transfer included in the request was completed, multiplied > by 730. > > Comments: > > Timetable for implementation: Immediate > _______________________________________________ > 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.
