[arin-ppml] LAST CALL for Recommended Draft Policy ARIN-2015-3: Remove 30 day utilization requirement in end-user IPv4 policy
David Farmer
farmer at umn.edu
Thu May 12 21:53:08 EDT 2016
Jason,
Even though the last call period formally ended May 9th, I try my best
to consider all feedback received for a policy even following the
formal last call deadline, and while I can't speak for directly for
other AC members, I believe most of them do the same. However, when
feedback comes in late sometimes it might not get full consideration,
especially if it comes in immediately prior to one of our conference
calls. To help avoid this I explicitly noted when AC would be
considering the feedback. I will additionally note at this point it
is extremely important to get any additional feedback in ASAP to allow
the AC due time for its consideration prior to its May 19th conference
call.
As for the issues and questions you have raise, I believe John and
Richard have been answering your questions. Further, I believe the
community consensus remains to move forward with removing the 25%
Immediate (30 day) use requirement for end users as this policy
suggests. I would specifically ask anyone who disagrees and thinks we
need to consider the issues more to speak up ASAP.
Thanks.
On Tue, May 10, 2016 at 11:32 AM, Jason Schiller <jschiller at google.com> wrote:
> 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
>> > 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
>> 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
>> You are receiving this message because you are subscribed to
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>> Please contact info at arin.net if you experience any issues.
>
>
>
>
> --
> _______________________________________________________
> Jason Schiller|NetOps|jschiller at google.com|571-266-0006
>
--
===============================================
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
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