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

John Santos JOHN at egh.com
Mon Nov 10 18:17:14 EST 2014

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

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