[arin-ppml] Draft Policy 2020-10: Requirement to Demonstrate Utilization of Reassignments and Reallocations for ISPs Seeking Initial Allocation from ARIN

Fri Jan 22 18:09:39 EST 2021

I have some major concerns with fraud. My day job sometimes involves/has
involved reviews when business customers would like space. On occasion,
ARIN has already denied them. After further review, our security teams find
out these people aren't who they say they are, don't own the physical
address they list, etc. Speaking for myself and not for my company, I am
very concerned that we are opening a huge door to fraud if there are zero
checks in place for requirements. I don't feel ARIN should be less
stringent than orgs that get space from them. If the main concern is
customers are claiming it's too difficult, I have a lot of questions there
as well. It should be easy to prove you are who you say you are and have a
valid reason to use the space.

Kat Hunter
Comcast
ARIN AC VC

On Fri, Jan 22, 2021, 2:33 PM Amy Potter <amybpotter at gmail.com> wrote:

> Happy friday to the ARIN community!
>
> I just wanted to poke the crowd to see if I can get some additional
> feedback on ARIN-2020-10. Specifically I would love to hear from anyone
> that feels it is a problem that ARIN reviews utilization of blocks
> reasssigned and reallocated to ISPs when those ISPs apply for their first
> direct allocation or direct assignment from ARIN (when an ISP lacking any
> reassignments or reallocations that applies for their first direct
> assignment or direct allocations would not need to establish efficient
> utilization of prior blocks).
>
> Alternatively, if anyone feels that removing the current requirements
> would lead to problems, please speak up!
>
> Thanks,
>
> Amy
>
> On Thu, Dec 17, 2020 at 11:30 AM Owen DeLong <owen at delong.com> wrote:
>
>> Personally, I oppose the proposal.
>>
>> I do not believe this levels the playing field, but rather tilts it to
>> the advantage of those holding space from their providers already.
>>
>> An organization holding no space has nothing to efficiently utilize and
>> is starting from zero, same as those other organizations presumably did
>> back when they were able to obtain space from their upstream. They could
>> have chosen to gett that initial space from ARIN, but opted for provider
>> assigned space instead for whatever reason. In any case, they have space
>> already and are either looking to expand or are looking to replace that
>> provider assigned space. In the former case, they are on the same playing
>> field as anyone looking to expand today. In the latter case, they have the
>> advantage of being able to continue using their provider assigned space
>> while waiting, so any disadvantage they may face is rather limited and is
>> the result of their own past decisions.
>>
>> Owen
>>
>>
>> On Dec 16, 2020, at 2:17 PM, Amy Potter <amybpotter at gmail.com> wrote:
>>
>> Hello ppml community!
>>
>> I just wanted to recirculate Draft Policy ARIN 2020-10 for feedback. This
>> draft policy would remove the requirement that ISPs that already hold
>> reallocations or reassignments from upstream providers satisfy ARIN's
>> efficient utilization requirements for those reallocations/reassignments
>> before they are able to qualify for their initial allocation of space
>> directly from ARIN, and get on the waitlist to receive that space.
>>
>> Under current policy a new ISP that does not have any reallocations or
>> reassignments qualifies for a /24 without having to establish efficient
>> utilization of any previous space. This allows new ISPs to get on the
>> waitlist sooner than ISPs holding reassignments/reallocations, despite the
>> fact that neither type of organization holds space directly from ARIN yet.
>>
>> 1.  Do you believe that NRPM's current distinction between ISPs holding
>> reassignments/reallocations and new ISPs without any
>> reallocations/reassignments still makes sense today?
>>
>> 2.  Is leveling the playing field by allowing all ISPs that do not
>> currently hold space directly from ARIN to qualify for a /24 without
>> demonstrating prior use--regardless of whether or not they hold
>> reallocations/reassignments--a fair solution that reflects the realities
>> faced by these organizations today?
>>
>> Thanks!
>>
>> Amy
>>
>> On Tue, Nov 24, 2020 at 12:47 PM ARIN <info at arin.net> wrote:
>>
>>> On 19 November 2020, the ARIN Advisory Council (AC) accepted
>>> "ARIN-prop-293: Requirement to Demonstrate Utilization of Reassignments and
>>> Reallocations for ISPs Seeking Initial Allocation from ARIN" as a Draft
>>> Policy.
>>>
>>> Draft Policy ARIN-2020-10 is below and can be found at:
>>>
>>> https://www.arin.net/participate/policy/drafts/2020_10/
>>>
>>> You are encouraged to discuss all Draft Policies on PPML. The AC will
>>> evaluate the discussion in order to assess the conformance of this draft
>>> policy with ARIN's Principles of Internet number resource policy as stated
>>> in the Policy Development Process (PDP). Specifically, these principles are:
>>>
>>> * Enabling Fair and Impartial Number Resource Administration
>>> * Technically Sound
>>> * Supported by the Community
>>>
>>> The PDP can be found at:
>>> https://www.arin.net/participate/policy/pdp/
>>>
>>> Draft Policies and Proposals under discussion can be found at:
>>> https://www.arin.net/participate/policy/drafts/
>>>
>>> Regards,
>>>
>>> Sean Hopkins
>>> Policy Analyst
>>> American Registry for Internet Numbers (ARIN)
>>>
>>>
>>>
>>> Draft Policy 2020-10: Requirement to Demonstrate Utilization of
>>> Reassignments and Reallocations for ISPs Seeking Initial Allocation from
>>> ARIN
>>>
>>>
>>>
>>> Problem Statement:
>>>
>>>
>>>
>>> 4.2.2 seems to provide an unfair advantage to ISPs without any IP
>>> address holdings - that is, they don’t have any direct assignments or
>>> allocations, nor any reassignments or reallocations from another
>>> organization.
>>>
>>>
>>>
>>> If an ISP does already have holdings in the form of reassignments or
>>> reallocations, and they request a /24, or even a /29 as an initial
>>> allocation - they are required to provide utilization data. This slows
>>> their advancement to the waiting list compared to a new ISP without any
>>> holdings at all. An organization without reassignments or reallocations
>>> doesn’t need to provide any justification other than submitting the request
>>> and providing an officer attestation. This expedites their addition to the
>>> waiting list.
>>>
>>>
>>>
>>> Policy Statement:
>>>
>>>
>>>
>>> Replace 4.2.2 with the following:
>>>
>>>
>>>
>>> 4.2.2. Initial Allocation to ISPs
>>>
>>>
>>>
>>> All ISP organizations automatically qualify for a /24.These
>>> organizations may qualify for more than a /24 by documenting how the
>>> requested allocation will be utilized within the request size specified in
>>> 4.2.4.3.
>>>
>>>
>>>
>>> ISP organizations without direct assignments or allocations from ARIN
>>> qualify for an initial allocation of up to a /22, subject to ARIN’s minimum
>>> allocation size.
>>>
>>>
>>>
>>> Timetable for implementation: Immediate.
>>>
>>>
>>>
>>> Comments:
>>>
>>>
>>>
>>> This proposal was written as the result of a Policy Experience Report.
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>> _______________________________________________
>>> ARIN-PPML
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>>>
>> _______________________________________________
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