[arin-ppml] ARIN-PPML 2014-19

Rudolph Daniel rudi.daniel at gmail.com
Wed Dec 24 19:40:14 EST 2014


I support this policy.

Rudi Daniel
ICT consulting
On Dec 24, 2014 1:24 PM, <arin-ppml-request at arin.net> wrote:

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> Today's Topics:
>
>    1. Recommended Draft Policy ARIN-2014-19: New MDN Allocation
>       Based on Past Utilization (ARIN)
>    2. Re: Recommended Draft Policy ARIN-2014-1: Out of Region   Use
>       (William Herrin)
>    3. Re: Recommended Draft Policy ARIN-2014-17: Change Utilization
>       Requirements from last-allocation to total-aggregate (William Herrin)
>    4. Re: Recommended Draft Policy ARIN-2014-1: Out of Region   Use
>       (Martin Hannigan)
>    5. Re: 2014-14, was Internet Fairness (Randy Carpenter)
>    6. Re: 2014-14, was Internet Fairness (Seth Mattinen)
>    7. Re: Recommended Draft Policy ARIN-2014-1: Out of Region Use
>       (Andrew Dul)
>
>
> ----------------------------------------------------------------------
>
> Message: 1
> Date: Wed, 24 Dec 2014 11:21:48 -0500
> From: ARIN <info at arin.net>
> To: arin-ppml at arin.net
> Subject: [arin-ppml] Recommended Draft Policy ARIN-2014-19: New MDN
>         Allocation Based on Past Utilization
> Message-ID: <549AE81C.3000305 at arin.net>
> Content-Type: text/plain; charset=windows-1252; format=flowed
>
> Recommended Draft Policy ARIN-2014-19
> New MDN Allocation Based on Past Utilization
>
> On 18 December 2014 the ARIN Advisory Council (AC) recommended
> ARIN-2014-19 for adoption, making it a Recommended Draft Policy.
>
> ARIN-2014-19 is below and can be found at:
> https://www.arin.net/policy/proposals/2014_19.html
>
> You are encouraged to discuss Draft Policy 2014-19 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-2014-19
> New MDN Allocation Based on Past Utilization
>
> Date: 16 December 2014
>
> AC's assessment of conformance with the Principles of Internet Number
> Resource Policy:
>
> This draft policy enables fair and impartial number resource
> administration by removing an impediment to additional allocations seen
> by some organizations due to the recent policy changes under
> ARIN-2013-08. This draft policy applies equally to all organizations and
> allows for MDN organizations to use previous utilization of a site to
> justify a new allocation for an MDN network site. The policy is clear
> and implementable as written. This proposal is technically sound. There
> are no technical issues which are raised by allowing a new criteria set
> to justify a new MDN network allocation. This proposal is supported by
> the community. Specifically, the draft policy is supported by
> organizations which use the MDN policy for their network allocation.
>
> Problem Statement:
> The previous MDN policy was too limiting in that a new MDN could only
> qualify under immediate need. This was extended by ARIN-2013-8 where the
> minimum allocation will now be assigned unless immediate need for more
> can be demonstrated.
>
> Unfortunately, this policy did not go far enough. There may be some
> cases where there is a one year utilization history that is applicable
> to a new MDN. For example, imagine a network that is divided into four
> regions, each an MDN. Three of the four MDNs have been growing at a /20
> per year. The fourth MDN has been growing at a /19 per year, it is over
> 80% utilized, and the region is too large. The region will be divided in
> half, which half of the current customers and their addresses to be
> migrated into a new MDN (Region 5). It is also anticipated that half of
> Region 4's growth will be shifted to Region 5. With Region 4 and Region
> 5 each above 80%, both should qualify for subsequent allocations at half
> of what was Region 4's growth rate.
>
> Policy statement:
>
> replace section 4.5.4 created by 2013-8:
>
> Upon verification that the organization has shown evidence of deployment
> of the new discrete network site, the new network(s) shall be allocated
> the minimum allocation size under section 4.2.1.5 unless the
> organization can demonstrate additional need using the immediate need
> criteria (4.2.1.6).
>
> with:
>
> Upon verification that the organization has shown
>
> evidence of deployment of the new discrete network site, the new
> network(s) shall be allocated one of the following:
>
> - the minimum allocation size under section 4.2.1.5
>
> - more than the minimum if the organization can demonstrate additional
> need using the immediate need criteria (4.2.1.6)
>
> - a 3-month supply of address space may be requested if the new MDN can
> show a demonstrated one-year utilization history.
>
> Timetable for implementation: Immediate
>
> Comment:
>
> The third bullet was changed from:
>
> "- a three month supply if there is an applicable one year utilization
> rate, specific to the use to be covered by the new MDN, on which to base
> a three month supply on as per 4.2."
>
> to:
>
> "- a 3-month supply of address space may be requested if the new MDN can
> show a demonstrated one-year utilization history."
>
> #####
>
> ARIN STAFF ASSESSMENT
>
> Date of Assessment: 22 October 2014
>
> 1. Summary (Staff Understanding)
>
> This policy proposes to change existing NRPM 4.5, ???Multiple Discrete
> Networks??? bullet 7 to add an additional qualifying criteria. Currently
> new sites applying under MDN will qualify for the minimum allocation
> size specified in 4.2.1.5 or under immediate need. This proposal adds
> the option for new MDNs with at least a year???s worth of historical
> utilization data to request up to a 3 month supply of addresses.
>
> 2. Comments
>
> A. ARIN Staff Comments
>
> ?? If implemented, staff would require the organization to show a direct
> correlation between the demonstrated 1-year utilization rate and the new
> discrete network???s 3 month need.
>
> ?? The policy requires an ???applicable 1 year utilization rate??? in
> order to qualify under this criteria. If implemented, staff would
> require that there be at least a full year of utilization data in order
> to qualify for a 3-month supply of address space.
>
> ?? The stated criterion is unclear. Staff would suggest restating as
> follows:
>
> o A 3-month supply of address space may be requested if the new MDN can
> show a demonstrated one-year utilization history.
>
> B. ARIN General Counsel - Legal Assessment
>
> This proposal does not create any material legal issue.
>
> 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
> Date: 3 September 2014
> Problem Statement:
> The previous MDN policy was too limiting in that a new MDN could only
> qualify under immediate need. This was extended by ARIN-2013-8 where the
> minimum allocation will now be assigned unless immediate need for more
> can be demonstrated.
> Unfortunately, this policy did not go far enough. There may be some
> cases where there is a one year utilization history that is applicable
> to a new MDN. For example, imagine a network that is divided into four
> regions, each an MDN. Three of the four MDNs have been growing at a /20
> per year. The fourth MDN has been growing at a /19 per year, it is over
> 80% utilized, and the region is too large. The region will be divided in
> half, which half of the current customers and their addresses to be
> migrated into a new MDN (Region 5). It is also anticipated that half of
> Region 4???s growth will be shifted to Region 5. With Region 4 and
> Region 5 each above 80%, both should qualify for subsequent allocations
> at half of what was Region 4???s growth rate.
> Policy statement:
> replace section 4.5.4 created by 2013-8:
> ???Upon verification that the organization has shown evidence of
> deployment of the new discrete network site, the new network(s) shall be
> allocated the minimum allocation size under section 4.2.1.5 unless the
> organization can demonstrate additional need using the immediate need
> criteria (4.2.1.6).???
> with:
> Upon verification that the organization has shown
> evidence of deployment of the new discrete network site, the new
> network(s) shall be allocated one of the following:
> - the minimum allocation size under section 4.2.1.5
> - more than the minimum if the organization can demonstrate additional
> need using the immediate need criteria (4.2.1.6)
> - a three month supply if there is an applicable one year utilization
> rate, specific to the use to be covered by the new MDN, on which to base
> a three month supply on as per 4.2.
> Timetable for implementation: Immediate
>
>
> ------------------------------
>
> Message: 2
> Date: Wed, 24 Dec 2014 11:50:42 -0500
> From: William Herrin <bill at herrin.us>
> Cc: "arin-ppml at arin.net" <arin-ppml at arin.net>
> Subject: Re: [arin-ppml] Recommended Draft Policy ARIN-2014-1: Out of
>         Region  Use
> Message-ID:
>         <
> CAP-guGW1KYrTK8WX9or3-AFDqun1_D5GQeF1Gs66Oc5uu7yJog at mail.gmail.com>
> Content-Type: text/plain; charset=UTF-8
>
> On Wed, Dec 24, 2014 at 11:21 AM, ARIN <info at arin.net> wrote:
> > Policy statement:
> >
> > Create new Section X:
> >
> > ARIN registered resources may be used outside the ARIN service region.
> Out
> > of region use of IPv4, IPv6, or ASNs are valid justification for
> additional
> > number resources if the applicant is currently using at least the
> equivalent
> > of a /22 of IPv4, /44 of IPv6, or 1 ASN within the ARIN service region,
> > respectively.
> >
> > The services and facilities used to justify the need for ARIN resources
> that
> > will be used out of region cannot also be used to justify resource
> requests
> > from another RIR. When a request for resources from ARIN is justified by
> > need located within another RIR?s service region, the officer of the
> > applicant must attest that the same services and facilities have not been
> > used as the basis for a resource request in the other region(s). ARIN
> > reserves the right to request a listing of all the applicant's number
> > holdings in the region(s) of proposed use, but this should happen only
> when
> > there are significant reasons to suspect duplicate requests.
>
> I think this is bad policy which will encourage registry shopping by
> large multinational companies who really don't need yet another
> advantage over their smaller competitors. Worse than just making ARIN
> a flag-of-convenience registry to the world, it includes just enough
> in-region requirement to shut out small players. I reiterate my
> OPPOSITION to this draft policy.
>
> Regards,
> Bill Herrin
>
>
>
>
> --
> William Herrin ................ herrin at dirtside.com  bill at herrin.us
> Owner, Dirtside Systems ......... Web: <http://www.dirtside.com/>
> May I solve your unusual networking challenges?
>
>
> ------------------------------
>
> Message: 3
> Date: Wed, 24 Dec 2014 11:54:48 -0500
> From: William Herrin <bill at herrin.us>
> Cc: "arin-ppml at arin.net" <arin-ppml at arin.net>
> Subject: Re: [arin-ppml] Recommended Draft Policy ARIN-2014-17: Change
>         Utilization Requirements from last-allocation to total-aggregate
> Message-ID:
>         <
> CAP-guGUQSodsqB6RQSvPnjdMkq_S0xU1f32nMCWtjcmZnHOg9g at mail.gmail.com>
> Content-Type: text/plain; charset=UTF-8
>
> On Wed, Dec 24, 2014 at 11:21 AM, ARIN <info at arin.net> wrote:
> > 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.
>
> I SUPPORT this draft policy as written. I believe it resolves an
> ambiguity in ARIN policy regarding utilization of assigned blocks
> prior to the most recent in a reasonable and even-handed manner.
>
> Regards,
> Bill Herrin
>
>
> --
> William Herrin ................ herrin at dirtside.com  bill at herrin.us
> Owner, Dirtside Systems ......... Web: <http://www.dirtside.com/>
> May I solve your unusual networking challenges?
>
>
> ------------------------------
>
> Message: 4
> Date: Wed, 24 Dec 2014 12:03:10 -0500
> From: Martin  Hannigan <hannigan at gmail.com>
> To: William Herrin <bill at herrin.us>
> Cc: "arin-ppml at arin.net" <arin-ppml at arin.net>
> Subject: Re: [arin-ppml] Recommended Draft Policy ARIN-2014-1: Out of
>         Region  Use
> Message-ID: <75E5775E-F26A-4722-B137-AA8611211E00 at gmail.com>
> Content-Type: text/plain;       charset=utf-8
>
> If Ebola were a draft policy it would be this one. Not in favor.
>
>
>
> > On Dec 24, 2014, at 11:50, William Herrin <bill at herrin.us> wrote:
> >
> >> On Wed, Dec 24, 2014 at 11:21 AM, ARIN <info at arin.net> wrote:
> >> Policy statement:
> >>
> >> Create new Section X:
> >>
> >> ARIN registered resources may be used outside the ARIN service region.
> Out
> >> of region use of IPv4, IPv6, or ASNs are valid justification for
> additional
> >> number resources if the applicant is currently using at least the
> equivalent
> >> of a /22 of IPv4, /44 of IPv6, or 1 ASN within the ARIN service region,
> >> respectively.
> >>
> >> The services and facilities used to justify the need for ARIN resources
> that
> >> will be used out of region cannot also be used to justify resource
> requests
> >> from another RIR. When a request for resources from ARIN is justified by
> >> need located within another RIR?s service region, the officer of the
> >> applicant must attest that the same services and facilities have not
> been
> >> used as the basis for a resource request in the other region(s). ARIN
> >> reserves the right to request a listing of all the applicant's number
> >> holdings in the region(s) of proposed use, but this should happen only
> when
> >> there are significant reasons to suspect duplicate requests.
> >
> > I think this is bad policy which will encourage registry shopping by
> > large multinational companies who really don't need yet another
> > advantage over their smaller competitors. Worse than just making ARIN
> > a flag-of-convenience registry to the world, it includes just enough
> > in-region requirement to shut out small players. I reiterate my
> > OPPOSITION to this draft policy.
> >
> > Regards,
> > Bill Herrin
> >
> >
> >
> >
> > --
> > William Herrin ................ herrin at dirtside.com  bill at herrin.us
> > Owner, Dirtside Systems ......... Web: <http://www.dirtside.com/>
> > May I solve your unusual networking challenges?
> > _______________________________________________
> > PPML
> > You are receiving this message because you are subscribed to
> > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
> > Unsubscribe or manage your mailing list subscription at:
> > http://lists.arin.net/mailman/listinfo/arin-ppml
> > Please contact info at arin.net if you experience any issues.
>
>
> ------------------------------
>
> Message: 5
> Date: Wed, 24 Dec 2014 12:05:33 -0500 (EST)
> From: Randy Carpenter <rcarpen at network1.net>
> To: John Santos <JOHN at egh.com>
> Cc: arin-ppml at arin.net
> Subject: Re: [arin-ppml] 2014-14, was Internet Fairness
> Message-ID:
>         <1073838686.613482.1419440733010.JavaMail.zimbra at network1.net>
> Content-Type: text/plain; charset=utf-8
>
>
> I also oppose. John Santos sums up the big points with which I agree:
>
> ----- On Dec 24, 2014, at 1:00 AM, John Santos JOHN at egh.com wrote:
>
> > Oppose 2014-14
> >
> > 1) /16 is not "small"
>
> Agreed. Even by ARIN definition it is "medium" :-)
>
> > 2) The problem the proposal purports to solve hasn't actually been
> >   demonstrated.  "ARIN staff [...] is spending scarce staff time on needs
> >   testing of small transfers."  Obviously, doing the necessary checking
> >   requires staff time, but is it a significant amount?  Is it taking much
> >   longer than it used to?  Is it costing ARIN a lot of money in staff
> >   wages and overhead to do these assessments, or is it lost in the noise?
>
> I have not heard or seen any data to support the "ARIN staff is too
> burdened" argument, other than there being a slightly longer processing
> time for IPv4 requests, which I am completely fine with. IPv6 requests have
> been pretty speedy for me.
>
> -Randy
>
>
> ------------------------------
>
> Message: 6
> Date: Wed, 24 Dec 2014 09:20:17 -0800
> From: Seth Mattinen <sethm at rollernet.us>
> To: arin-ppml at arin.net
> Subject: Re: [arin-ppml] 2014-14, was Internet Fairness
> Message-ID: <549AF5D1.9080306 at rollernet.us>
> Content-Type: text/plain; charset=windows-1252; format=flowed
>
> On 12/23/14 22:00, John Santos wrote:
> > 1) /16 is not "small"
>
>
> Then make it /18 to align with the fee schedule definition of "small".
>
> ~Seth
>
>
> ------------------------------
>
> Message: 7
> Date: Wed, 24 Dec 2014 09:23:58 -0800
> From: Andrew Dul <andrew.dul at quark.net>
> To: arin-ppml at arin.net
> Subject: Re: [arin-ppml] Recommended Draft Policy ARIN-2014-1: Out of
>         Region Use
> Message-ID: <549AF6AE.7000807 at quark.net>
> Content-Type: text/plain; charset=utf-8
>
> Marty,
>
> Can you be a little more specific.  Are you opposed to the whole concept
> or the draft as written?
>
> Do you support the ARIN's current operational practice of excluding
> address space, which is in use outside the region, from being considered
> utilized when applying for additional allocations?
>
> This was one of the things this policy was attempting to rectify.
>
> I know you support removing all needs requirements, but that isn't the
> current policy in this region.
>
> Andrew
>
> On 12/24/2014 9:03 AM, Martin Hannigan wrote:
> > If Ebola were a draft policy it would be this one. Not in favor.
> >
> >
> >
> >> On Dec 24, 2014, at 11:50, William Herrin <bill at herrin.us> wrote:
> >>
> >>> On Wed, Dec 24, 2014 at 11:21 AM, ARIN <info at arin.net> wrote:
> >>> Policy statement:
> >>>
> >>> Create new Section X:
> >>>
> >>> ARIN registered resources may be used outside the ARIN service region.
> Out
> >>> of region use of IPv4, IPv6, or ASNs are valid justification for
> additional
> >>> number resources if the applicant is currently using at least the
> equivalent
> >>> of a /22 of IPv4, /44 of IPv6, or 1 ASN within the ARIN service region,
> >>> respectively.
> >>>
> >>> The services and facilities used to justify the need for ARIN
> resources that
> >>> will be used out of region cannot also be used to justify resource
> requests
> >>> from another RIR. When a request for resources from ARIN is justified
> by
> >>> need located within another RIR?s service region, the officer of the
> >>> applicant must attest that the same services and facilities have not
> been
> >>> used as the basis for a resource request in the other region(s). ARIN
> >>> reserves the right to request a listing of all the applicant's number
> >>> holdings in the region(s) of proposed use, but this should happen only
> when
> >>> there are significant reasons to suspect duplicate requests.
> >> I think this is bad policy which will encourage registry shopping by
> >> large multinational companies who really don't need yet another
> >> advantage over their smaller competitors. Worse than just making ARIN
> >> a flag-of-convenience registry to the world, it includes just enough
> >> in-region requirement to shut out small players. I reiterate my
> >> OPPOSITION to this draft policy.
> >>
> >> Regards,
> >> Bill Herrin
> >>
> >>
> >>
> >>
> >> --
> >> William Herrin ................ herrin at dirtside.com  bill at herrin.us
> >> Owner, Dirtside Systems ......... Web: <http://www.dirtside.com/>
> >> May I solve your unusual networking challenges?
> >> _______________________________________________
> >> PPML
> >> You are receiving this message because you are subscribed to
> >> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
> >> Unsubscribe or manage your mailing list subscription at:
> >> http://lists.arin.net/mailman/listinfo/arin-ppml
> >> Please contact info at arin.net if you experience any issues.
> > _______________________________________________
> > PPML
> > You are receiving this message because you are subscribed to
> > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
> > Unsubscribe or manage your mailing list subscription at:
> > http://lists.arin.net/mailman/listinfo/arin-ppml
> > Please contact info at arin.net if you experience any issues.
>
>
>
> ------------------------------
>
> _______________________________________________
> ARIN-PPML mailing list
> ARIN-PPML at arin.net
> http://lists.arin.net/mailman/listinfo/arin-ppml
>
> End of ARIN-PPML Digest, Vol 114, Issue 50
> ******************************************
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