[arin-ppml] ARIN-2015-3: Staff interpretation needed

Jason Schiller jschiller at google.com
Mon Apr 25 10:40:43 EDT 2016


After the topic of 2015-3 closed I was discussing the policy with some
folks and there seems to be some confusion.

If 2015-3 was current ARIN policy what would staff accept as an acceptable
justification.

It was my assumption that an ARIN ticket that said "We might have 9 million
new customers in the next two years.  We would like transfer approval for a
/8.  We are currently holding a /21 which we intend to keep."   And an
officer of the company attests to this.  Then ARIN would accept this
justification as sufficient.

Others postulated that the amount of documentation required would be
unchanged from what it previously was.  For a two year transfer approval
that is not based on a doubling of the previous 1 year run rate, a
requester would still have to submit a business case supporting the two
year growth need, and the officer would have to attest to that business
case.  The only difference here is that ARIN would not review the business
case except that the project count of things in two years is more that 50%
of what is requested plus what is held.  This means ARIN would not review
the supporting documentation of the business case, and leave that up to the
officer of the requesting company to do.  Is that correct?


Additionally, can staff provide some statistics on the following:

1. over the last year how many end user transfer (pre-)approvals were
justified based on past growth?

2. over the last year how many end user transfer (pre-)approvals were
justified based on
a future looking growth projection that was not based an past growth?

3. Of the requests in type 2 above, how many were:
- Approved with no additional questions asked about the growth projection
(not including the request for attestation)?
- How many with one additional question about the growth projection?
- How many with two or more additional questions about the growth
projection?
- How many were closed with no (pre-)approval during additional questions
about the growth projection?
- How many were left unresolved for 30 days or more (or abandoned) during
additional questions about the growth projection


I realize that some or all of the stats questions may take some time to
answer.  Please feel free to answer the first question about what
documentation is required to be in the ticket and attested to, and any
stats that are easily found, and follow up with the more time consuming
stats later.

Thanks,

__Jason



On Wed, Feb 17, 2016 at 1:19 PM, Jason Schiller <jschiller at google.com>
wrote:

> Just in case it wasn't clear, I oppose as written as it has no teeth and
> can easily be an end user end-run around justified need.
>
> I support the change with some teeth so it is not likely to be an end-run
> around justified need.
>
> __Jason
>
>
>
> On Tue, Feb 16, 2016 at 4:52 PM, Brian Jones <bjones at vt.edu> wrote:
>
>>
>>
>>
>>
>> On Tue, Feb 16, 2016 at 3:51 PM, Richard J. Letts <rjletts at uw.edu> wrote:
>>
>>> My preference is to apply the policy change as written (with the minor
>>> editorial change substituting "criterion" for "criteria".)
>>>
>>
>> ​+1​
>> --
>> Brian
>>
>>
>>>
>>> Thank you
>>> Richard Letts
>>>
>>> > -----Original Message-----
>>> > From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net]
>>> On
>>> > Behalf Of David Farmer
>>> > Sent: Monday, February 15, 2016 9:23 PM
>>> > To: ARIN PPML <arin-ppml at arin.net>
>>> > Subject: Re: [arin-ppml] ARIN-2015-3: Remove 30-Day Utilization
>>> > Requirement in End-User IPv4 Policy
>>> >
>>> > As shepherd, I need additional feedback on this, I need a better sense
>>> of
>>> > what the community wants here.
>>> >
>>> > Should we move forward more or less as-is, with a minor editorial
>>> change,
>>> > substituting "criterion" for "criteria"?
>>> >
>>> > Or, does the community want to work on a way to address the concerns
>>> > raised but Jason?
>>> >
>>> > Your input please.
>>> >
>>> > Thanks
>>> >
>>> > On 1/29/16 10:00 , Jason Schiller wrote:
>>> > > McTim,
>>> > >
>>> > > WRT some other tangible and verifiable claim to show there was a real
>>> > > commitment to use half the address space within one year...
>>> > >
>>> > > I think there are 3 choices:
>>> > >
>>> > > 1. Very vague
>>> > >
>>> > > Something like "there must be some  tangible and verifiable claim to
>>> > > show there was a real commitment to use half the address space within
>>> > > one year and not just a future projection or business case"
>>> > >
>>> > >
>>> > > 2. Open ended with some guidance for ARIN staff:
>>> > >
>>> > > Something like "there must be some  tangible and verifiable claim to
>>> > > show there was a real commitment to use half the address space within
>>> > > one year and not just a future projection or business case.  Some
>>> > > examples include:
>>> > > - list of equipment in hand to be numbered counting at least 25% of
>>> > > requested IP size
>>> > > - invoices showing equipment purchases demonstrating a commitment to
>>> > > buy equipment to be numbered counting at least 25% of requested IP
>>> > > size
>>> > > - invoices showing equipment purchases demonstrating a commitment to
>>> > > buy equipment to be numbered counting at least 50% of requested IP
>>> > > size within one year
>>> > > - lease agreements for real estate supporting equipment that is
>>> > > appropratly sized to support equipment to be numbered counting at
>>> > > least 50% of requested IP size
>>> > >
>>> > > 3. specific criterion
>>> > >
>>> > > ----
>>> > >
>>> > > I don't know what it the right answer here, and suspect it has more
>>> to
>>> > > do with what the community is comfortable with.
>>> > >
>>> > > On one end of the spectrum is choice 1.  This allows ARIN to do the
>>> > > right thing.  But this also is not clear about what the community
>>> > > expects, and  ARIN may act in a way that is counter to what is
>>> > > anticipated, and may seem like ARIN is being arbitrary or has too
>>> much
>>> > > leeway to screw with requestors.
>>> > >
>>> > > The opposite end of the spectrum is choice 3.  This sets a very clear
>>> > > list of what qualifies.  Hammering out that list may be very
>>> > > difficult, and it is unlikely to be complete.  This will leave little
>>> > > or no room for ARIN to do the right thing and approve a request that
>>> > > is justified, but not one of the criterion listed.
>>> > >
>>> > > Choice 2 is the middle ground.  Where we have a not necessarily
>>> > > complete list of criterion (so somewhat less difficulty in drawing up
>>> > > the list) that creates a very clear expectation of what ARIN should
>>> > > accept (and reduces the possibility that ARIN may act in a way that
>>> is
>>> > > counter to what is anticipated, and may seem like ARIN is being
>>> > > arbitrary or has too much leeway to screw with requestors) with
>>> > > respect to criterion clearly defined, while also allowing ARIN to do
>>> > > the right thing with similar types of proof that are not explicitly
>>> > > listed as criterion (this has somewhat higher risk that ARIN may act
>>> > > in a way that is counter to what is anticipated, and may seem like
>>> > > ARIN is being arbitrary or has too much leeway to screw with
>>> > > requestors, but less risk than option 1 as the criterion should serve
>>> > > as good guidance)
>>> > >
>>> > >
>>> > > So two open questions to the community?
>>> > >
>>> > > 1. Is the community most comfortable with:
>>> > >      A. totally vague and open-ended such as "there must be some
>>> > >   tangible and verifiable claim to show there was a real commitment
>>> to
>>> > > use half the address space within one year and not just a future
>>> > > projection or business case"
>>> > >
>>> > >     B. A vague statement with some guidance as to some acceptable
>>> > > forms of tangible verifiable proof of a real commitment to use half
>>> > > the IP address within one year.
>>> > >
>>> > >    C. A very clear list of what proof is considered acceptable
>>> > >
>>> > >
>>> > > 2. If the community prefers B. guidance or C. a very clear list then
>>> > > what sort of things would the community like to see on that list?
>>> > >
>>> > >
>>> > > On Fri, Jan 29, 2016 at 8:27 AM, McTim <dogwallah at gmail.com
>>> > > <mailto:dogwallah at gmail.com>> wrote:
>>> > >
>>> > >
>>> > >
>>> > >     On Thu, Jan 28, 2016 at 4:52 PM, Jason Schiller
>>> > >     <jschiller at google.com <mailto:jschiller at google.com>> wrote:
>>> > >
>>> > >         I support the removal of the 30 day utilization as it is
>>> > >         unreasonable for any larger end-site, who may have a real
>>> need
>>> > >         for say a /16, with 65,000 desktops arriving on a loading doc
>>> > >         next week, but an inability to unbox, configure and deploy
>>> > >         16,384 to the various office locations in 30 days.
>>> > >
>>> > >
>>> > >     agreed.
>>> > >
>>> > >         However, this is the only provision that has a real,
>>> tangible,
>>> > >         and verifiable claim.  Without this check justified need for
>>> end
>>> > >         users simply becomes a 1 year future looking projection, and
>>> > >         with sufficient arm waving an easy end run around justified
>>> need
>>> > >         for any end user with no IP space or if they are efficiently
>>> > >         using what they currently hold.
>>> > >
>>> > >
>>> > >     good point!
>>> > >
>>> > >         I could get on board if the maximum sized block permitted on
>>> a
>>> > >         purely future looking projection was a /24 and you had to
>>> use it
>>> > >         prior to getting more.
>>> > >
>>> > >
>>> > >     +1
>>> > >
>>> > >         I could certainly get on board if there were some other
>>> tangible
>>> > >         and verifiable claim to show there was a real commitment to
>>> use
>>> > >         half the address space within one year.
>>> > >
>>> > >
>>> > >     Would this language suffice, or would we need a metric of some
>>> sort?
>>> > >
>>> > >
>>> > >     Regards,
>>> > >
>>> > >     McTim
>>> > >
>>> > >         __Jason
>>> > >
>>> > >         On Thu, Jan 28, 2016 at 8:55 AM, Brian Jones <bjones at vt.edu
>>> > >         <mailto:bjones at vt.edu>> wrote:
>>> > >
>>> > >             Looks good to me Dave. I am okay with using criteria or
>>> > >             criterion, however using the strict definition it looks
>>> as
>>> > >             though criterion is the proper singular form.
>>> > >
>>> > >             --
>>> > >             Brian
>>> > >
>>> > >             On Wed, Jan 27, 2016 at 5:54 PM, David Farmer
>>> > >             <farmer at umn.edu <mailto:farmer at umn.edu>> wrote:
>>> > >
>>> > >                 The following is the proposed update for ARIN-2015-3:
>>> > >                 Remove 30-Day Utilization Requirement in End-User
>>> IPv4
>>> > >                 Policy based on strong support in Montreal.
>>> > >
>>> > >                 Beyond deleting the 25% bullet as the policy says,
>>> their
>>> > >                 are editorial changes as follows to the remaining
>>> > > text;
>>> > >
>>> > >                 - It looks weird to have single item bullet list, so
>>> > >                 merge the two remaining sentence fragments into a
>>> single
>>> > >                 sentence.
>>> > >                 - Change "are" to "is", since there is only one
>>> > >                 remaining criteria
>>> > >                 - Use of "criteria" as a singular is common usage,
>>> even
>>> > >                 though technically it's plural.
>>> > >                 - Resulting in "The basic criteria that must be met
>>> is a
>>> > >                 50% utilization rate within one year."
>>> > >
>>> > >                 The remaining and resulting text for 4.3.3 is now
>>> > >                 included in the policy text, for editorial clarity.
>>> The
>>> > >                 original staff and legal suggested removing the
>>> RFC2050
>>> > >                 reference and also pointed out that
>>> > >                 4.2.3.6 also has a 25% immediate use clause and a
>>> > >                 RFC2050 reference.
>>> > >
>>> > >                 Feedback in Montreal was that deleting the 25%
>>> immediate
>>> > >                 use was a nice bite-sized change, and we shouldn't
>>> try
>>> > >                 to do more than that with this change, so those
>>> changes
>>> > >                 are not included at this time.
>>> > >
>>> > >                 Any additional feedback or comments are appreciated.
>>> > >
>>> > >                 Thanks
>>> > >
>>> > >                 ---------
>>> > >
>>> > >                 Draft Policy ARIN-2015-3: Remove 30 day utilization
>>> > >                 requirement in end-user IPv4 policy
>>> > >
>>> > >                 Date: 27 January 2015
>>> > >
>>> > >                 Problem Statement:
>>> > >
>>> > >                 End-user policy is intended to provide end-users
>>> with a
>>> > >                 one year supply of IP addresses. Qualification for a
>>> > >                 one-year supply requires the network operator to
>>> utilize
>>> > >                 at least 25% of the requested addresses within 30
>>> days.
>>> > >                 This text is unrealistic and should be removed.
>>> > >
>>> > >                 First, it often takes longer than 30 days to stage
>>> > >                 equipment and start actually using the addresses.
>>> > >
>>> > >                 Second, growth is often not that regimented; the
>>> > >                 forecast is to use X addresses over the course of a
>>> > >                 year, not to use 25% of X within 30 days.
>>> > >
>>> > >                 Third, this policy text applies to additional address
>>> > >                 space requests. It is incompatible with the
>>> requirements
>>> > >                 of other additional address space request
>>> justification
>>> > >                 which indicates that 80% utilization of existing
>>> space
>>> > >                 is sufficient to justify new space. If a block is at
>>> > >                 80%, then often (almost always?) the remaining 80%
>>> will
>>> > >                 be used over the next 30 days and longer. Therefore
>>> the
>>> > >                 operator cannot honestly state they will use 25% of
>>> the
>>> > >                 ADDITIONAL space within 30 days of receiving it;
>>> they're
>>> > >                 still trying to use their older block efficiently.
>>> > >
>>> > >                 Fourth, in the face of ARIN exhaustion, some ISPs are
>>> > >                 starting to not give out /24 (or larger) blocks. So
>>> the
>>> > >                 justification for the 25% rule that previously
>>> existed
>>> > >                 (and in fact, applied for many years) is no longer
>>> germane.
>>> > >
>>> > >                 Policy statement:
>>> > >
>>> > >                 Remove the 25% utilization criteria bullet point from
>>> > >                 NRPM 4.3.3.
>>> > >
>>> > >                 Resulting text:
>>> > >
>>> > >                 4.3.3. Utilization rate
>>> > >
>>> > >                 Utilization rate of address space is a key factor in
>>> > >                 justifying a new
>>> > >                 assignment of IP address space. Requesters must show
>>> > >                 exactly how
>>> > >                 previous address assignments have been utilized and
>>> must
>>> > >                 provide
>>> > >                 appropriate details to verify their one-year growth
>>> > >                 projection.
>>> > >
>>> > >                 The basic criteria that must be met is a 50%
>>> utilization
>>> > >                 rate within one year.
>>> > >
>>> > >                 A greater utilization rate may be required based on
>>> > >                 individual network
>>> > >                 requirements. Please refer to RFC 2050 for more
>>> > >                 information on
>>> > >                 utilization guidelines.
>>> > >
>>> > >                 Comments:
>>> > >                 a.Timetable for implementation: Immediate
>>> > >                 b.Anything else
>>> > >
>>> > >                 --
>>> > >                 ================================================
>>> > >                 David Farmer               Email: farmer at umn.edu
>>> > >                 <mailto:farmer at umn.edu>
>>> > >                 Office of Information Technology
>>> > >                 University of Minnesota
>>> > >                 2218 University Ave SE     Phone: 1-612-626-0815
>>> > >                 <tel:1-612-626-0815>
>>> > >                 Minneapolis, MN 55414-3029  Cell: 1-612-812-9952
>>> > >                 <tel:1-612-812-9952>
>>> > >                 ================================================
>>> > >                 _______________________________________________
>>> > >                 PPML
>>> > >                 You are receiving this message because you are
>>> subscribed to
>>> > >                 the ARIN Public Policy Mailing List (
>>> ARIN-PPML at arin.net
>>> > >                 <mailto:ARIN-PPML at arin.net>).
>>> > >                 Unsubscribe or manage your mailing list subscription
>>> at:
>>> > >                 http://lists.arin.net/mailman/listinfo/arin-ppml
>>> > >                 Please contact info at arin.net <mailto:info at arin.net>
>>> if
>>> > >                 you experience any issues.
>>> > >
>>> > >
>>> > >
>>> > >             _______________________________________________
>>> > >             PPML
>>> > >             You are receiving this message because you are
>>> subscribed to
>>> > >             the ARIN Public Policy Mailing List (ARIN-PPML at arin.net
>>> > >             <mailto:ARIN-PPML at arin.net>).
>>> > >             Unsubscribe or manage your mailing list subscription at:
>>> > >             http://lists.arin.net/mailman/listinfo/arin-ppml
>>> > >             Please contact info at arin.net <mailto:info at arin.net> if
>>> you
>>> > >             experience any issues.
>>> > >
>>> > >
>>> > >
>>> > >
>>> > >         --
>>> > >
>>> > _______________________________________________________
>>> > >         Jason Schiller|NetOps|jschiller at google.com
>>> > >         <mailto:jschiller at google.com>|571-266-0006 <tel:571-266-0006
>>> >
>>> > >
>>> > >
>>> > >         _______________________________________________
>>> > >         PPML
>>> > >         You are receiving this message because you are subscribed to
>>> > >         the ARIN Public Policy Mailing List (ARIN-PPML at arin.net
>>> > >         <mailto:ARIN-PPML at arin.net>).
>>> > >         Unsubscribe or manage your mailing list subscription at:
>>> > >         http://lists.arin.net/mailman/listinfo/arin-ppml
>>> > >         Please contact info at arin.net <mailto:info at arin.net> if you
>>> > >         experience any issues.
>>> > >
>>> > >
>>> > >
>>> > >
>>> > >     --
>>> > >     Cheers,
>>> > >
>>> > >     McTim
>>> > >     "A name indicates what we seek. An address indicates where it
>>> is. A
>>> > >     route indicates how we get there."  Jon Postel
>>> > >
>>> > >
>>> > >
>>> > >
>>> > > --
>>> > > _______________________________________________________
>>> > > Jason Schiller|NetOps|jschiller at google.com
>>> > > <mailto:jschiller at google.com>|571-266-0006
>>> > >
>>> > >
>>> > >
>>> > > _______________________________________________
>>> > > PPML
>>> > > You are receiving this message because you are subscribed to the ARIN
>>> > > Public Policy Mailing List (ARIN-PPML at arin.net).
>>> > > Unsubscribe or manage your mailing list subscription at:
>>> > > http://lists.arin.net/mailman/listinfo/arin-ppml
>>> > > Please contact info at arin.net if you experience any issues.
>>> > >
>>> >
>>> >
>>> > --
>>> > ================================================
>>> > David Farmer               Email: farmer at umn.edu
>>> > Office of Information Technology
>>> > University of Minnesota
>>> > 2218 University Ave SE     Phone: 1-612-626-0815
>>> > Minneapolis, MN 55414-3029  Cell: 1-612-812-9952
>>> > ================================================
>>> > _______________________________________________
>>> > PPML
>>> > You are receiving this message because you are subscribed to the ARIN
>>> > Public Policy Mailing List (ARIN-PPML at arin.net).
>>> > Unsubscribe or manage your mailing list subscription at:
>>> > http://lists.arin.net/mailman/listinfo/arin-ppml
>>> > Please contact info at arin.net if you experience any issues.
>>> _______________________________________________
>>> PPML
>>> You are receiving this message because you are subscribed to
>>> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
>>> Unsubscribe or manage your mailing list subscription at:
>>> http://lists.arin.net/mailman/listinfo/arin-ppml
>>> Please contact info at arin.net if you experience any issues.
>>>
>>
>>
>> _______________________________________________
>> PPML
>> You are receiving this message because you are subscribed to
>> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
>> Unsubscribe or manage your mailing list subscription at:
>> http://lists.arin.net/mailman/listinfo/arin-ppml
>> Please contact info at arin.net if you experience any issues.
>>
>
>
>
> --
> _______________________________________________________
> Jason Schiller|NetOps|jschiller at google.com|571-266-0006
>
>


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