[arin-ppml] 2014-19 and evidence of deployment

[Martin Hannigan]

+ppml

Hello. Happy to provide some answers, but I'll note that you're not on
the AC so I'm surprised that you're representing the AC.

Inline


On Mon, Nov 10, 2014 at 4:36 PM, Jason Schiller <jschiller at google.com> wrote:
> Marty,
>
> the ARIN AC is redrafting 2014-19 to respond to comments and staff concerns.
>
> I brought up your concerns about "evidence of deployment" being to vague and
> allowing ARIN to interpret it any way they see fit.  There was a suggestion
> of adding a non-exclusive list of the types of evidence that should be
> acceptable...
>

Like what?


> Unfortunately the AC felt there was no "substantive feedback" on specific
> changes.  In fact the AC feels the previous attempt was too concrete, and
> now we have a vague one which you are concerned is too vague.
>

Explaining that even if you do submit a "contract" to ARIN, they can't
tell if its for one site or another or if its even valid. Sounds
pretty substantive to me.

> I recall you say, put back the old language, but I looked back at the
> 12/2004 NRPM prior to the 2004-5 changes, I checked the 06/2014 NRPM prior
> to the 2013-8 changes.

And?


>None of them have advice to ARIN on how to judge
> when an ISP is truly creating a new MDN (and not just committing fraud).
>

How many fraud "prosecutions" has ARIN initiated in the last three years?

> Can us suggest some text along the line of...

'You'ze' can. But I think you mean me. :-)


>
> "7. Upon verification that the organization has shown evidence of deployment
> of the new discrete network site, [such as, but not limited to the
> following: a network design showing existing and new discreet networks and
> supporting documentation that the proposed design in in progress such as
> contracts for new space or power, new equipment orders, publicly available
> marketing material describing the offering in a new location, or some other
> significant capital investment in the project,] the new networks shall be
> allocated:
>

Let's go back to the original point I made in the last two PPC and
ARIN meetings. How can a company contract for real estate, energy or
network without knowing if they had IP addresses to operate their
business (in this current environment of v4 scarcity and policy
wonkery?)?

You're suggesting that we create even more conditions for un-qualified
staff to evaluate? What kind of energy contract is suitable in this
context? mW? mWh? kW? kWh? Min, Max, Capacity, triple peak average?
Renting slots on the medium voltage substation or acquiring energy
credits from the grid? All of them? None of them? You're proposing
non-starters.

The collective "we" already sign "officer attestations". If we
elaborate our need in a way that justifies the addresses, ARIN should
assign them. If they think there's fraud, ARIN should do what they
claim they will do and "prosecute". Use Section 12. Complain to the
SEC that regulated companies are lying to them. Do something that you
can actually have credibility in the sense that someone really
understands what they are talking about. So far, #fail.


Best,

-M<