[arin-ppml] ARIN-2015-3: Remove 30-Day Utilization Requirement in End-User IPv4 Policy

Richard J. Letts rjletts at uw.edu
Tue Feb 16 15:51:22 EST 2016


My preference is to apply the policy change as written (with the minor editorial change substituting "criterion" for "criteria".)

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>
> >                 ================================================
> >                 _______________________________________________
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> >
> >
> >             _______________________________________________
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> >
> >
> >
> >
> >         --
> >
> _______________________________________________________
> >         Jason Schiller|NetOps|jschiller at google.com
> >         <mailto:jschiller at google.com>|571-266-0006 <tel:571-266-0006>
> >
> >
> >         _______________________________________________
> >         PPML
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> >         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
> >
> >
> >
> > _______________________________________________
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> 
> 
> --
> ================================================
> 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
> ================================================
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