[arin-ppml] Final draft of 2010-13 for Atlanta (Rev 1.55)

[Owen DeLong]

> 
> 2. Comments
> 
> A.	ARIN Staff Comments
> 
>  • The policy text has become very complex and complicated and the
> general community will have a very hard time understanding the concepts
> and criteria proposed within the policy.
> 
It is an effort to bring a complex set of needs to a fair and workable solution.
As such, there were no simple solutions to be had. We have simplified it
tremendously from several earlier drafts.

>  • It seems to be out of order – it starts out with reservations
> before ever mentioning the initial qualifying criteria.  The author
> might want to consider re-ordering to start with the essential
> qualification criteria first.
> 
We felt that since understanding the reservation system was a
prerequisite to any application under the subsequent guidelines,
it should be explained first. I still think the policy is far easier to
understand if you start with understanding the reservation system
and then move to the criteria by which you can qualify for a
reservation.

>  • Section 4.10.2 suggests that all allocations made under this policy
> will initially be made from a 3-year reservation.  In light of the
> imminent depletion of IPv4 address space, it doesn't seem fair to allow
> some organizations to retain/reserve this valuable resource for up to 3
> years while others will be denied.
> 
We shortened this to two years. Additionally, reservations will be
reduced as necessary to avoid denying space to anyone to the
extent feasible. The reservation system is required in order to provide
a limited amount of certainty to organizations trying to plan their
transitions between now and runout.

>  • The policy text in (in 4.10.3) appears to contradict itself, as it
> first directs staff to remove one quarter's worth of reservation, and
> then, if the organization continues this practice for three consecutive
> quarters, remove the organization's reserves completely. Later, it
> explicitly directs staff to revoke addresses issued under this policy
> that are used by the organizations for purposes not permitted under this
> policy.
> 
These are two completely separate issues.

The first (quarterly reduction on first failure and cancellation of remaining
reserves on failure for three consecutive quarters) addresses the situation
where an organization is using the addresses in a manner consistent with
policy, but, either is not consuming their full reservation (over-reserved) or
is not meeting their IPv6 deployment targets. In these cases, we do not
seek to revoke the transition space from the organization, but, we do feel
it is only fair to return their reserved unallocated space to the pool for the
benefit of the community.

The second case addresses a situation where an organization uses
the addresses in a manner inconsistent with the policy under which
they were issued. This is essentially intended to prevent organizations
from taking addresses under this policy for uses other than transition
and provides the stiff penalty of not only canceling the remaining
reservation, but, also revoking any previously issued transition
space from the organization and returning it to the pool for the benefit
of the community.

>  • This proposal will essentially supplant the recently ratified
> policy "Waiting List for Unmet Resources". That list will consist of
> people waiting for resources to be returned or revoked so that ARIN can
> then reissue them to requestors in need of IPv4 address space.  This
> proposal says that any IPv4 address space that comes back to ARIN
> immediately goes into the IPv6 transition pool and can only be used for
> that purpose.
> 
Yes... We feel that this is a better use of returned address space after
depletion.

>  • Under 4.10.4.B5, how would staff be able to verify that x percent
> of an organization’s content is IPv6 reachable?
> 
In part, this will depend on some level of voluntary compliance. However,
I believe that the community would find ways to make ARIN aware of
egregious violations.

While we leave the exact method of measurement and implementation
as an operational issue for staff, since staff appears to be asking for
guidance, some possible techniques could include:

1.	Measure percentage by host distinguished names (DNs).
2.	Require the provider to submit a complete list of DNs.
3.	Count the number of DNs providing A vs. A/AAAA records.
4.	The simple ratio would represent the percentage.

Owen