[arin-ppml] LAST CALL for Recommended Draft Policy ARIN-2015-3: Remove 30 day utilization requirement in end-user IPv4 policy

Tue May 10 12:32:08 EDT 2016

I seem to have missed the this thread in last call, and hope you
will consider the discussion on the other thread: " Re: [arin-ppml]
ARIN-2015-3:(remove 30-day...) Staff interpretation needed"

 I maintain that the 30-day [60-day for transfers] check has
been useful in mitigating abusively large requests, and
without it there is no teeth in the policy to prevent abuse.

I asked if I was 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?

I heard no response to indicate there was any mechanism.

I asked staff about information about stats that might help
determine what level of push back ARIN provides against two
year projected need in general, and if that push back would be
sufficient to prevent outlandishly large claims.

We found that 50% - 75% of all requests are approved with
past utilization more heavily weighed.

It remains unclear what level of oversight ARIN has to
question future looking projections.  John Curran provided
some text about approvals of future looking projections.

   "When we [ARIN] ask organization for their forward
    projections, we [ARIN] also ask them to provide details
   to show how they've arrived at their projections. We [ARIN]
   take into account factors such as new networks, locations,
   products, services they plan on offering (and this includes
   consideration of anticipated address utilization within the
   first 30 days for end-users.)

>From the text John provided it seems one could get IP
addresses solely on future looking plans which are
unverifiable.  As such an end-user could easily get a 10
year supply of addresses simply by providing very
optimistic deployment plans for the next 24 months.

I asked if I was 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?

I heard no response to this.

Thanks,

__Jason

On Thu, May 5, 2016 at 11:45 AM, David Farmer <farmer at umn.edu> wrote:

> As shepherd for this policy I welcome any additional last call
> feedback for this policy.  It is especially important to speak up if
> you feel there are any issues remaining that need to be considered.
> But, even if you simply support the policy as written that is
> important and useful feedback as well.
>
> The last call period formally continues through, Monday, May 9th, and
> the AC will consider the feedback during its scheduled call on
> Thursday, May 19th.
>
> Thanks
>
> On Mon, Apr 25, 2016 at 1:38 PM, ARIN <info at arin.net> wrote:
> > The ARIN Advisory Council (AC) met on 20 April 2016 and decided to
> > send the following to last call:
> >
> >   Recommended Draft Policy ARIN-2015-3: Remove 30 day utilization
> > requirement in end-user IPv4 policy
> >
> > Feedback is encouraged during the last call period. All comments should
> > be provided to the Public Policy Mailing List. This last call will
> > expire on 9 May 2016. After last call the AC will conduct their
> > last call review.
> >
> > The draft policy text is below and available at:
> > https://www.arin.net/policy/proposals/
> >
> > The ARIN Policy Development Process is available at:
> > https://www.arin.net/policy/pdp.html
> >
> > Regards,
> >
> > Communications and Member Services
> > American Registry for Internet Numbers (ARIN)
> >
> >
> > ## * ##
> >
> >
> > Recommended Draft Policy ARIN-2015-3
> > Remove 30 day utilization requirement in end-user IPv4 policy
> >
> > AC's assessment of conformance with the Principles of Internet Number
> > Resource Policy:
> >
> > ARIN 2015-3 contributes to fair and impartial number resource
> administration
> > by removing from the NRPM text that is operationally unrealistic for the
> > reasons discussed in the problem statement. This proposal is technically
> > sound, in that the removal of the text will more closely align with the
> way
> > staff applies the existing policy in relation to 8.3 transfers. There was
> > strong community support for the policy on PPML and at ARIN 36, which was
> > confirmed at ARIN 37. There was a suggestion to replace this text with an
> > alternate requirement. However, the community consensus was to move
> forward
> > with the removal alone.
> >
> > The staff and legal review also suggested removing RFC2050 references and
> > pointed out that 4.2.3.6 has an additional 25% immediate use clause,
> > community feedback was to deal with those issues separately.
> >
> > 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 criterion 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
> >
> > #####
> >
> > ARIN STAFF ASSESSMENT
> >
> > Draft Policy ARIN-2015-3
> > Remove 30 day utilization requirement in end-user IPv4 policy
> > Date of Assessment: 16 February 2016
> >
> > ___
> > 1. Summary (Staff Understanding)
> >
> > This proposal would remove the 25% utilization (within 30 days of
> issuance)
> > criteria bullet point from NRPM 4.3.3.
> >
> > ___
> > 2. Comments
> >
> > A. ARIN Staff Comments
> > 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.
> >
> > Note that both NRPM 4.3.3 and NRPM 4.2.3.6 contain references to obsolete
> > RFC 2050. Additionally, 4.2.3.6 references the 25% immediate use (within
> 30
> > days of issuance) requirement.
> >
> > Staff suggests removing the first two sentences of 4.2.3.6 to remove the
> > references to RFC 2050 and the 25% requirement. Additionally, staff
> suggests
> > removing the reference to the obsolete RFC 2050 in section 4.3.3.
> >
> > B. ARIN General Counsel – Legal Assessment
> > No material legal risk in this policy.
> >
> > ___
> > 3. Resource Impact
> >
> > This policy would have minimal resource impact from an implementation
> > aspect. It is estimated that implementation would occur immediately after
> > ratification by the ARIN Board of Trustees. The following would be
> needed in
> > order to implement:
> > * Updated guidelines and internal procedures
> > * Staff training
> > _______________________________________________
> > PPML
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> > 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
> ===============================================
> _______________________________________________
> PPML
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-- 
_______________________________________________________
Jason Schiller|NetOps|jschiller at google.com|571-266-0006
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