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 <[email protected]> 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 <[email protected]> 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 ([email protected]). >> > Unsubscribe or manage your mailing list subscription at: >> > http://lists.arin.net/mailman/listinfo/arin-ppml >> > Please contact [email protected] if you experience any issues. >> >> >> >> -- >> =============================================== >> David Farmer Email:[email protected] >> 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 ([email protected]). >> Unsubscribe or manage your mailing list subscription at: >> http://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact [email protected] if you experience any issues. >> > > > > -- > _______________________________________________________ > Jason Schiller|NetOps|[email protected]|571-266-0006 > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List ([email protected]). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact [email protected] if you experience any issues. _______________________________________________ PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List ([email protected]). Unsubscribe or manage your mailing list subscription at: http://lists.arin.net/mailman/listinfo/arin-ppml Please contact [email protected] if you experience any issues.
