[arin-ppml] ARIN-2015-3:(remove 30-day...) Staff interpretation needed

Thu May 5 14:26:03 EDT 2016

Comments in line.

On Thu, May 5, 2016 at 11:30 AM, David Farmer <farmer at umn.edu> wrote:

> On Mon, Apr 25, 2016 at 11:47 AM, Jason Schiller <jschiller at google.com>
> wrote:
> ...
>
> > David, I hear a lot of people such as yourself, supposing that removal of
> > the 30 day need check will not change anything else.  But I believe it
> makes
> > (pre-)approval  for transfer solely based on the 2 year need projection,
> > which I am concerned could be wildly optimistic.
>
> I'm not sure if this is directed at me or David Huberman, but I'll
> respond anyway.
>
> The staff assessment for ARIN-2015-3 says;
>    This policy would more closely align with the way staff applies the
> existing policy
>    in relation to 8.3 transfers. Because there is no longer an IPv4
> free pool and many
>    IPv4 requests are likely to be satisfied by 8.3 transfers, the
> adoption of this policy
>    should have no major impact on operations and could be implemented
> as written.
>
> I interpret this as saying the evaluation will be based on
> more-or-less the same criteria it is today just with no requirement to
> use 25% in 30 days, which you and everyone seems to support.
>

yes, true, but... what does it mean to have the same criteria just with
no requirement to use 25% in 30 days?

8.3 references "demonstrating need" "under current policies"

"The recipient must demonstrate the need for up to a 24-month supply of IP
address resources under current ARIN policies and sign an RSA."

WRT ISPs "under current policy means" under 4.2.2 and 4.2.2.

which in short says roughly:
For ISP initial:
The ISP must already have at least a /24 from their provider, and
show that the space they are using is efficiently used.

They can then one for one swap their re-allocation for a direct
allocation from ARIN (gotten from ARIN or the transfer market).

If they want more IP space then what they are currently using, they
need to show 3 month [or 24 month for transfers] growth projections
"showing specifically how the requested allocation will be utilized"

For additional ISP space:
They must show 80% utilization, with no blocks less than half full.
"Determination of the appropriate allocation to be issued is based on
efficient utilization of space within this time frame, consistent with the
principles in 4.2.1."

4.2.1 includes slow start.  So if the IP space you need in the next 3 months
[24 months for transfers] is more than what you used in the previous
3 months [24 months for transfers] you get slow started.  That means,
you get double what you had the last 3 months [24 months for transfers],
you use it up, you show utilization, and double again so long as the most
recent space was utilized in less than 3 months [24 months for transfers]

There is quite a lot of teeth in there to prevent abuse.

WRT end-users "under current policy means" under 4.3.3 and 4.3.6.1

For end-user initial:

"Requesters must provide appropriate details to verify their one-year
growth projection. The basic criteria that must be met are:

- 25% immediate utilization rate, and
- 50% utilization rate within one year."
For end-user additional:
They must demonstrate 80% utilization on average, and no block less than
half full, and then use the same initial criteria.

There is no slow-start.  The only thing that limits abuse is the threat
that ARIN
might check for compliance with the requirement to use 25% in 30 days
[60 days for transfers].

Without this check you are free to make any wildly optimistic plan that
supports a wildly optimistic growth projection and then in two years time
simply say "plans changed.  We are still going to that, but over 10 years
instead."

This easily becomes:
1. make a wildly optimistic plan,
2. officer attest to it,
3. end-run around need.

Which is nearly 2015-7 for end-users which is:
1. officer attest to the statement we think we might need X in the next 2
years
2. end-run around need.

I maintain that the 30 day check has been useful in mitigating abusively
large
requests, and without it there is no teeth in the policy to prevent abuse.

If I am wrong about this, please explain what mechanisms are in place to
mitigate
an end-user asking for approval for a 10 year supply of addresses on the
grounds
that if things go really really well, it will only be a 2 year supply?

If I am not wrong about this, then did people realize that this policy is
basically an
end-run around giving out addresses based on need when they voted to move
this
policy forward?

___Jason

> > I am not confusing it with 2015-7: Simplified requirements for
> demonstrated
> > need for IPv4 transfers.  I believe 2015-7 would result in two changes,
> 1.
> > lowering the bar for ISP to match what end users need in 2015-3, and 2.
> > removing any demonstration of current utilization (and by extension
> > demonstration that you can and are properly managing the space you have)
> for
> > both ISPs and end users.
> >
> > I can see where there could be some confusion as I have the same concern
> for
> > both proposals, that there needs to be some tangible verifiable claim.
>
> Thanks for clarifying.
>
> ...
> --
> ===============================================
> 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
> ===============================================
>

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