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

Jason Schiller jschiller at google.com
Mon Nov 10 17:36:36 EST 2014


I am not on the AC.  As originator I was contacted on the rewrites, and I
thought it would be helpful to address your concerns, so I suggested that.

The shepherds did not have actionable recommendations, and asked me for
text, so I reached out to you.

Reading between the lines of your email, would I be correct in concluding
there should be no proof of deployment of a new MDN (as this does not give
ARIN any more proof to believe deployment of an MDN is likely, and getting
approval for the IPs happens before commitment to spend).

Simply an engineering plan to do such, and an officer attestation that the
engineering plan is indeed truthful, should suffice.

If that is the case would the resulting text meet your need?

7. Upon an organization providing plans for a new discreet network, which
an officer of the company attests is in progress, the new network shall be


On Mon, Nov 10, 2014 at 5:19 PM, Martin Hannigan <hannigan at gmail.com> wrote:

> +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<

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