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

Andrew Dul andrew.dul at quark.net
Fri Jan 29 12:19:01 EST 2016


I would think that ARIN staff would already apply a "show me tangible 
evidence requirement" to a 50% within a year requirement.

My understanding is that that is current ARIN staff practice for new 
organizations requires them to show evidence they will actually use the 
IPv4 addresses on an operational network.  I don't think removing the 
immediate/30-day requirement would cause a shift in ARIN operational 
policy to remove the practice of showing documentation to substantiate 
the use of the addresses.

Perhaps ARIN staff could comment on the current operational practices 
for demonstrating usage for new end-users, if that includes a "tangible 
evidence requirement"?

And if the removal of the "immediate" usage of 25% would cause ARIN 
staff in their implementation to not conduct such a requirement on the 
50% within one year test.

Andrew

On 1/29/2016 8:00 AM, 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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>
>         -- 
>         _______________________________________________________
>         Jason Schiller|NetOps|jschiller at google.com
>         <mailto:jschiller at google.com>|571-266-0006 <tel:571-266-0006>
>
>
>         _______________________________________________
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>
>
>
>     -- 
>     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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