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

Owen DeLong owen at delong.com
Fri May 13 01:06:48 EDT 2016


I see the policy itself largely as a no-op. I have no objection for it going to the board,
nor do I have any significant support for it to do so.

Owen

> On May 12, 2016, at 18:53 , David Farmer <farmer at umn.edu> wrote:
> 
> 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 <mailto: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
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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
>>> 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.
>> 
>> 
>> 
>> 
>> --
>> _______________________________________________________
>> Jason Schiller|NetOps|jschiller at google.com|571-266-0006
>> 
> 
> 
> 
> -- 
> ===============================================
> David Farmer               Email:farmer at umn.edu <mailto: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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