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

[Jason Schiller]

John,

Thank you for your comments on the merits of the proposal, but I think it
is premature, as we are not sure what the proposal should be.

I think we should figure out some straw man text that is agreeable to
Martin prior to beating up the proposal.


__Jason

On Mon, Nov 10, 2014 at 6:17 PM, John Santos <JOHN at egh.com> wrote:

> On Mon, 10 Nov 2014, Martin Hannigan wrote:
>
> > >
> > > "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?)?
>
> Any company with a business plan is taking risks and has to have a
> fall back plan (even if the plan is "pack it in") for any conceivable
> eventuality.  You want ARIN to guarantee that they can get IPv4 before
> they've found a site, bought any equipment, signed any contracts with
> suppliers or customers, or even made any public announcements of their
> plans to establish a new site?  What happens if ARIN says "fine, you
> can have your IP space", and then when it comes time to allocate it,
> the cupboard is bare?  Or what happens if ARIN supplies some exceedingly
> scare IP4 to them, and then they can't find real-estate, customers,
> or some other obstacle prevents them from actually turning on their
> new network?  Do they then get a windfall of salable IPv4?
>
> The org trying to set up a new MDN site should have a fallback plan if
> they can't get ARIN MDN space, of repurposing existing addresses,
> acquiring them from an upstream, buying them in the market, or using IPv6
> instead.  If their entire business plan depends on them getting ARIN
> MDN space (with no other option), then they are being irresponsible to
> their stakeholders.
>
> >
> > 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.
>
> I think you're deliberately being obtuse.  It isn't the amount or type of
> power that matters.  What matters is that one method of determining that a
> site exists is that it is (or soon will be) on the electric grid.  What's
> relevant are the location and dates (i.e. that the contract is current and
> ongoing) and that the customer be the applicant or someone the applicant
> is representing.
>
> Presenting an electric bill is a perfectly legitimate and common method of
> establishing residency, which is probably why it's included in the "such
> as, but not limited to" list.
>
>
> This is not the *ONLY* way to establish the existance of a site, it
> is merely one of the possible pieces of evidence.  Payroll, equipment
> orders, budgets, networking agreements with upstream providers, site
> plans, existing, on-going relationship with ARIN can all show that
> the new site/network is legit.  They wouldn't even need to reveal the
> site's physical location (for example if it were a battered women's
> shelter, though I can't imagine why one would need an MDN.)
>
> You don't need to be an electrical engineer (or do a structural
> analysis of the building or evaluate the personnel policies of
> the applicant) to judge the legitimacy of the request.
>
>
> > 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.
>
>
> If an org can't demonstrate any form of documentation that the site
> they are claiming actually exists, an "officer attestation" is
> worthless.  Suing or prosecuting for fraud after the fact is far
> more difficult and costly (for both parties) than simply requiring
> evidence up front.
>
>
> --
> John Santos
> Evans Griffiths & Hart, Inc.
> 781-861-0670 ext 539
>
>


-- 
_______________________________________________________
Jason Schiller|NetOps|jschiller at google.com|571-266-0006
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