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

Sat May 14 20:49:49 EDT 2016

Well put, David. +1
-Scott

    _____________________________
From: David R Huberman <daveid at panix.com>
Sent: Saturday, May 14, 2016 5:08 PM
Subject: Re: [arin-ppml] LAST CALL for Recommended Draft Policy ARIN-2015-3: Remove 30 day utilization requirement in end-user IPv4 policy
To:  <arin-ppml at arin.net>

Jason,

1) The policy in last call removes a criterion that is not being applied
today.  Staff have criteria they use to judge 24-month need, and have been
applying it for years without coming back to us and telling us there's a
problem or deficiency.

2) Most requestors (99%? 98%?) tell the truth.  They're just trying to
operate a network, and aren't attempting to defraud ARIN In any way. ARIN
staff have been fighting scammers for a very long time, and are very good
at it. They have measurable positive results in fighting fraud.

For those two reasons, I believe this policy should be adopted by the
board, and an obsolete criterion should be removed from NRPM.

David

> 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 â€“ 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
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>>
>
>
>
> --
> _______________________________________________________
> Jason Schiller|NetOps|jschiller at google.com|571-266-0006
> _______________________________________________
> PPML
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