[arin-ppml] Draft Policy ARIN-2014-17: Change Utilization Requirements from last-allocation to total-aggregate - revised

[Michael Peddemors]

On 14-11-20 10:50 AM, William Herrin wrote:
> On Thu, Nov 20, 2014 at 1:25 PM, Michael Peddemors
> <michael at linuxmagic.com <mailto:michael at linuxmagic.com>> wrote:
>  > Sounds good, but suggest it get extended slightly..
>  >
>  > 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, must provide ARIN with utilization
>  > details, and have correct information in WHOIS directory via
>  > SWIP or use of an RWhois server (Section 4.2.3.7 and Section
>  > 3.2) and has responded to a recent Annual Whois POC Verificaiton
> (Section 3.6)
>  >
>  > This will help aid ARIN in ensuring information is up to date, for
> their own purposes.
>
> Hi Michael,
>
> You're kind of straying from policy language to business process
> language. The idea is that policy should tell ARIN -what- data it should
> require while business process tells ARIN -how- to collect and maintain
> that data. (Yes, 3.6.1 is badly written in that respect.)
>
> So, you'd want words along the lines of, "must have published accurate
> and complete utilization information and points of contact."
>
> Also, throwing the language in this way could muddy things. Accurate
> publication is conceptually separate from amount of utilization. 4.2.4
> has multiple subheadings, each with a distinct requirement for ISPs
> requesting additional space. Consider whether this requirement would
> belong in a separate subheading and, if it does, whether adding that
> separate subheading would be better pursued in a separate policy
> proposal or if it really needs to be attached to this one.
>
> Regards,
> Bill Herrin
>

I get your point, but while "Accurate  publication is conceptually 
separate from amount of utilization" this is related to getting new IP 
Space, and I don't see anywhere explicit language to say you don't get 
more space, unless your current space is operated properly according to 
policy, especially as it pertains to accurate whois and contact 
information, for both the parent and the delegated space..

Speaking with ARIN a few times on this issue, one of the complaints 
staff have is to even get POC data right.. (hehe.. to send the bill 
even) and if we can add language that helps enable ARIN to operate 
better, and to support the language elsewhere in the policies, maybe 
that data will get more accurate.

It also helps support future enforcement measures, if ARIN ever gets 
that mandate.. right now, they take reports of non-functioning rwhois, 
or incorrect information, but all it is is a note on their records.

Explicitly adding the language will allow ARIN staff to point to a 
policy during application(s) and say "the policy says you have to fix 
this before you get new space"



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