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

Jason Schiller jschiller at google.com
Wed Feb 17 13:19:52 EST 2016


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
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>> > >                 <mailto:ARIN-PPML at arin.net>).
>> > >                 Unsubscribe or manage your mailing list subscription
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>> > >                 Please contact info at arin.net <mailto:info at arin.net>
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>> > >                 you experience any issues.
>> > >
>> > >
>> > >
>> > >             _______________________________________________
>> > >             PPML
>> > >             You are receiving this message because you are subscribed
>> to
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>> > >             <mailto:ARIN-PPML at arin.net>).
>> > >             Unsubscribe or manage your mailing list subscription at:
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>> > >             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:
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>> > Please contact info at arin.net if you experience any issues.
>> _______________________________________________
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>
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-- 
_______________________________________________________
Jason Schiller|NetOps|jschiller at google.com|571-266-0006
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