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

Alyssa Moore alyssa.moore at cybera.ca
Fri May 13 18:42:22 EDT 2016

Apologies in advance for jumping in at the last minute on a policy that's
in recommended form, but I have a few questions and observations.

1)  The problem statement says:
> First, it often takes longer than 30 days to stage equipment and
start actually using the addresses.

Earlier on, Jason says:
> "I know I worked very hard to get my recent end-user assignment over 25%
by the deadline."

It is my understanding, Jason, that you're a proponent of some form of
verification with teeth - presumably something more aggressive than the 1
year/50% that would still be included if 2015-3 passes muster, but you also
concede that you had a difficult time meeting the current 30 day

I could be completely off base because I haven't been following 2015-3
since its inception, but has there been any discussion of a test that sits
somewhere between 25%/30 days and 50%/1 year?

2) It seems 4.3.3 in its current incarnation *doesn't have teeth to begin
with *as it applies to transfers (which are really the only option in a
post-depletion world.) John Curran says:

Such a requirement could only be applicable transfers to end-users who were
demonstrating their 24-month need using NRPM 4.3.3, and *there is no clear
interpretation for application of **the  "25% immediate utilization rate”
language*. As such, it is not directly considered during the process (as
elaborated by Richard Jimmerson on the list); therefore none were “reviewed and
verified explicitly” for that purpose.

Note that the language remains applicable (and organizations that attempt
to transfer without having immediate utilization do run the risk of number
resource fraud), but is not integrated into the end-user transfer review
process as its extrapolation into that context is unclear.  *This is also
why the staff and legal review for draft policy 2015-3 notes - "This policy
would **more closely align with the way staff applies the existing policy
in relation to 8.3 transfers.”*

[emphasis my own]

My understanding from these comments is that ARIN has not been doing 30 day
check ups on transfers because *staff has not received direction on how to
apply the existing policy to transfers, *which would be the reason behind
the staff assessment, "This policy would more closely align with the way
staff applies existing policy." To that end, then, the policy in its
current incarnation is not completely obsolete as some folks have claimed
on the PPML. Staff simply don't have direction for application of the
utilization rates.

It seems there needs to be clearer consensus around what the action of ARIN
staff ought to be a) in pursuing verification in the first place re:
transfers and b) in cases where verification tests aren't met. Should ARIN
be automatically checking in at the 30 day or 1 year mark? If so, what does
ARIN do if the 25%/30 days or 50%/1year tests aren't met? Should ARIN
revoke the address space? Serve the offender notice? Are either of these
ethical in a post-depletion world where folks have paid for address space?

If the community is to give direction in these areas, should it be included
in 2015-3, or in a separate problem statement?

Feel free to set me straight on all of this 'cause I'm a giant nooooob.
- Alyssa

On Fri, May 13, 2016 at 4:19 PM John Curran <jcurran at arin.net> wrote:

> On May 13, 2016, at 3:38 PM, Jason Schiller <jschiller at google.com> wrote:
> I am highly confused now.
> We have the 25% utilization check which really is the only verifiable
> check to rate-limit aggressively optimistic requests.
> On one hand, ARIN does not check this figure.  As such the policy
> change is a no-op.
> On the other hand the 25% utilization goal remains part of the
> policy and having no intention of complying is fraud.
> ARIN could make random checks, or check all of them.
> ...
> Jason -
>    Are you referring to assignments or transfers?  The above discussion
>    appears to mix requests of both types.
>    ARIN does check that end-user _assignment_ requests meet the
>    25% immediate utilization requirement (as called for in the end-user
>    assignment policy.)
>    ARIN does not have clear guidance how the assignment criteria for
>    25% immediate use is to be applied to transfers.  ARIN can apply the
>    criteria with respect to transfer requests, but that would require some
>    additional policy clarity from the community to do so.
> So in that respect the policy change is not a no-op.
>    The policy change will not materially affected transfer requests, as
> noted
>    above.  The change would effect processing of any end-user assignments
>    requests.  (It is probably worth noting that end-users who presently
> qualify
>    for assignment of an IPv4 block are being added to a waiting list with
> a
>    rather low probability of timely fulfillment.)
> Thanks,
> /John
> John Curran
> President and CEO
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