[arin-ppml] ARIN-2015-3:(remove 30-day...) Staff interpretation needed
David Farmer
farmer at umn.edu
Mon Apr 25 10:53:33 EDT 2016
I'm worried that people are confusing policy proposals; ARIN
2015-3:Remove 30 day utilization requirement in end-user IPv4 policy,
simply removes the 25% immediate need (30-day) clause, it shouldn't
really change anything else.
On Mon, Apr 25, 2016 at 9:40 AM, Jason Schiller <jschiller at google.com> wrote:
> 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
>
>
> _______________________________________________
> 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
Networking & Telecommunication Services
Office of Information Technology
University of Minnesota
2218 University Ave SE Phone: 612-626-0815
Minneapolis, MN 55414-3029 Cell: 612-812-9952
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