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ARIN-prop-212 Transfer policy slow start and simplified needs verification

ARIN-prop-212 Transfer policy slow start and simplified needs verification

Proposal Originator: Jason Schiller and Mike Joseph

Date: 20 August 2014

Problem Statement:

As IPv4 depletion occurs, it will become difficult for organization to get IP addresses. This will impact one of the two ways an organization can get an initial allocation.

Background on current policy

For ISPs to get an initial allocation from ARIN, they must demonstrate efficient utilization of a /20 (or between a /23 to a /21 for multi-homed) from their upstream ISP. ISPs may also qualify under the exceptional process of immediate need. Once an ISP gets its first ARIN allocation it can repeatedly double under slow start assuming the usage of IP space is growing and all of the available IPs are efficiently utilized in less that 1.5 months.

Subsequent allocations are based on the past one year utilization rate and demonstration of efficient utilization of all previously held space, as well as 80% utilization of the most recent block. ARIN will provide addresses up to a 3 month supply based on the previous one year run rate. Transfers up to a two year supply based on the previous one year run rate are also permitted.

End users can qualify for an initial assignment based on their anticipated one year projection so long as they can put 25% of the addresses in use immediately (30 days) and have over 50% utilization within one year.

Subsequent assignments must first demonstrate 80% utilization of all previous assignments, and then are again based on their anticipated one year projection so long as they can put 25% of the addresses in use immediately (30 days) and have over 50% utilization within one year.

Issue with current policy when IPv4 is depleted

IPv4 depletion may make if difficult for ISPs to be able to get an allocation from an upstream provider creating a barrier to entry.

Additionally, slow start for an ISP would require frequent and small IPv4 transfers. This is costly in that it leads to address fragmentation, and requires multiple transfer agreements to be negotiated and signed.

For end users, the easiest way to demonstrate immediate need is to already be using IP space from an up stream provider, and promise to renumber into the newly provided IP space (although this may actually take more than 30 days to execute). This approach may be limited if an end user has difficulty getting an assignment from an upstream ISP.

Additionally, the 25% immediate (30 day) need and 50% one year utilization rates are completely future looking projections. It may be difficult to verify these claims prior to transferring the address space, and a required return of the address at the 30 day or one year make may make the financial transaction complicated. The 30 day utilization provision is problematic for larger end sites who may have hosts that can use the addresses immediately, but require more that 30 days to fully deploy the addresses.

Policy statement:

remove the following section 8.3 text:

  • The recipient must demonstrate the need for up to a 24-month supply of IP address resources under current ARIN policies and sign an RSA.

Remove the following section 8.4 text:

  • Recipients within the ARIN region must demonstrate the need for up to a 24-month supply of IPv4 address space.

Add:

8.3.1 New ORGs

8.3.1.1 End-Sites

End-user organizations which do not currently hold IP addresses, and can demonstrate 50% immediate utilization by currently held equipment, will immediately qualify for a non-M&A transfer between the minimum assignment size and a /24, inclusive.

8.3.1.2 ISPs

ISP organizations which do not currently hold IP addresses, and can demonstrate 50% immediate utilization by currently held equipment, current customers, or customer orders will immediately qualify for a non-M&A transfer between the minimum allocation size and a /21, inclusive.

8.3.2 Existing ORGs

8.3.2.1 Minimum requirements

Prior to qualifying for non-M&A address transfers, an organization must demonstrate an average of 80% utilization across the aggregate of all addresses that are currently allocated, assigned, reallocated, or reassigned to, or otherwise in use by, the organization.

8.3.2.2 Transfer Approval

An organization which qualifies for transfers under one of the criteria in 8.3.2.3 shall be approved for the transfer in of an aggregate amount of address space as determined by the relevent section. An organization with such an approval may then complete one or more transfers, with a cumulative total not exceeding the approved amount, without submitting additional justification. An organization will be ineligible for additional non-M&A transfers until it can again demonstrate that it meets the minimum requirements in section 8.3.2.1.

8.3.2.3 Qualifying Criteria

8.3.2.3.1 Stable Growth

Organizations may be approved for the non-M&A transfer of additional address space equal to the amount of address space they were holding at the time of approval.

8.3.2.3.2 Rapid Growth

Organizations may be approved for the non-M&A transfer of additional address space equal to 24 times the organization's calculated monthly average use rate.

8.3.2.3.2.1 Calculation of Monthly Average Use Rate

An organization may choose a look-back window of any number of months between 3 and 12, inclusive, from the date of the current request. ARIN will calculate the total amount of new addresses acquired, during the look-back window, by the organization from non-M&A transfers, direct allocations or assignments from ARIN, or reallocations or reassignments from an ISP. That total will be divided by the number of months in the look-back window to calculate the organization's monthly average use rate.

8.3.2.3.2.2 Returned IP space

If addresses are returned or transferred out within the look-back window, then those addresses will be subtracted from the total amount of new addresses acquired for the purposes of the monthly average use rate calculation.

8.3.2.3.2.3 M&A activity

If M&A transfer activity occurs during the look-back window, the addresses acquired through M&A transfers will only be counted in the total amount of new addresses acquired if the pre-M&A organization had acquired the resources during the post-M&A organization's look-back window.

8.4.1 – (Same text as 8.3.1, but not repeated here for brevity)

Comments: a. Timetable for implementation: Immediate b. Anything else:

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