I support this policy. Rudi Daniel ICT consulting On Dec 24, 2014 1:24 PM, <[email protected]> wrote:
> Send ARIN-PPML mailing list submissions to > [email protected] > > To subscribe or unsubscribe via the World Wide Web, visit > http://lists.arin.net/mailman/listinfo/arin-ppml > or, via email, send a message with subject or body 'help' to > [email protected] > > You can reach the person managing the list at > [email protected] > > When replying, please edit your Subject line so it is more specific > than "Re: Contents of ARIN-PPML digest..." > > > Today's Topics: > > 1. Recommended Draft Policy ARIN-2014-19: New MDN Allocation > Based on Past Utilization (ARIN) > 2. Re: Recommended Draft Policy ARIN-2014-1: Out of Region Use > (William Herrin) > 3. Re: Recommended Draft Policy ARIN-2014-17: Change Utilization > Requirements from last-allocation to total-aggregate (William Herrin) > 4. Re: Recommended Draft Policy ARIN-2014-1: Out of Region Use > (Martin Hannigan) > 5. Re: 2014-14, was Internet Fairness (Randy Carpenter) > 6. Re: 2014-14, was Internet Fairness (Seth Mattinen) > 7. Re: Recommended Draft Policy ARIN-2014-1: Out of Region Use > (Andrew Dul) > > > ---------------------------------------------------------------------- > > Message: 1 > Date: Wed, 24 Dec 2014 11:21:48 -0500 > From: ARIN <[email protected]> > To: [email protected] > Subject: [arin-ppml] Recommended Draft Policy ARIN-2014-19: New MDN > Allocation Based on Past Utilization > Message-ID: <[email protected]> > Content-Type: text/plain; charset=windows-1252; format=flowed > > Recommended Draft Policy ARIN-2014-19 > New MDN Allocation Based on Past Utilization > > On 18 December 2014 the ARIN Advisory Council (AC) recommended > ARIN-2014-19 for adoption, making it a Recommended Draft Policy. > > ARIN-2014-19 is below and can be found at: > https://www.arin.net/policy/proposals/2014_19.html > > You are encouraged to discuss Draft Policy 2014-19 on the PPML prior to > the upcoming ARIN Public Policy Consultation at NANOG 63 in San Antonio > in February 2015. Both the discussion on the list and at the meeting > will be used by the ARIN Advisory Council to determine the community > consensus for adopting this as policy. > > The ARIN Policy Development Process can be found at: > https://www.arin.net/policy/pdp.html > > Draft Policies and Proposals under discussion can be found at: > https://www.arin.net/policy/proposals/index.html > > Regards, > > Communications and Member Services > American Registry for Internet Numbers (ARIN) > > > ## * ## > > > Recommended Draft Policy ARIN-2014-19 > New MDN Allocation Based on Past Utilization > > Date: 16 December 2014 > > AC's assessment of conformance with the Principles of Internet Number > Resource Policy: > > This draft policy enables fair and impartial number resource > administration by removing an impediment to additional allocations seen > by some organizations due to the recent policy changes under > ARIN-2013-08. This draft policy applies equally to all organizations and > allows for MDN organizations to use previous utilization of a site to > justify a new allocation for an MDN network site. The policy is clear > and implementable as written. This proposal is technically sound. There > are no technical issues which are raised by allowing a new criteria set > to justify a new MDN network allocation. This proposal is supported by > the community. Specifically, the draft policy is supported by > organizations which use the MDN policy for their network allocation. > > Problem Statement: > The previous MDN policy was too limiting in that a new MDN could only > qualify under immediate need. This was extended by ARIN-2013-8 where the > minimum allocation will now be assigned unless immediate need for more > can be demonstrated. > > Unfortunately, this policy did not go far enough. There may be some > cases where there is a one year utilization history that is applicable > to a new MDN. For example, imagine a network that is divided into four > regions, each an MDN. Three of the four MDNs have been growing at a /20 > per year. The fourth MDN has been growing at a /19 per year, it is over > 80% utilized, and the region is too large. The region will be divided in > half, which half of the current customers and their addresses to be > migrated into a new MDN (Region 5). It is also anticipated that half of > Region 4's growth will be shifted to Region 5. With Region 4 and Region > 5 each above 80%, both should qualify for subsequent allocations at half > of what was Region 4's growth rate. > > Policy statement: > > replace section 4.5.4 created by 2013-8: > > Upon verification that the organization has shown evidence of deployment > of the new discrete network site, the new network(s) shall be allocated > the minimum allocation size under section 4.2.1.5 unless the > organization can demonstrate additional need using the immediate need > criteria (4.2.1.6). > > with: > > Upon verification that the organization has shown > > evidence of deployment of the new discrete network site, the new > network(s) shall be allocated one of the following: > > - the minimum allocation size under section 4.2.1.5 > > - more than the minimum if the organization can demonstrate additional > need using the immediate need criteria (4.2.1.6) > > - a 3-month supply of address space may be requested if the new MDN can > show a demonstrated one-year utilization history. > > Timetable for implementation: Immediate > > Comment: > > The third bullet was changed from: > > "- a three month supply if there is an applicable one year utilization > rate, specific to the use to be covered by the new MDN, on which to base > a three month supply on as per 4.2." > > to: > > "- a 3-month supply of address space may be requested if the new MDN can > show a demonstrated one-year utilization history." > > ##### > > ARIN STAFF ASSESSMENT > > Date of Assessment: 22 October 2014 > > 1. Summary (Staff Understanding) > > This policy proposes to change existing NRPM 4.5, ???Multiple Discrete > Networks??? bullet 7 to add an additional qualifying criteria. Currently > new sites applying under MDN will qualify for the minimum allocation > size specified in 4.2.1.5 or under immediate need. This proposal adds > the option for new MDNs with at least a year???s worth of historical > utilization data to request up to a 3 month supply of addresses. > > 2. Comments > > A. ARIN Staff Comments > > ?? If implemented, staff would require the organization to show a direct > correlation between the demonstrated 1-year utilization rate and the new > discrete network???s 3 month need. > > ?? The policy requires an ???applicable 1 year utilization rate??? in > order to qualify under this criteria. If implemented, staff would > require that there be at least a full year of utilization data in order > to qualify for a 3-month supply of address space. > > ?? The stated criterion is unclear. Staff would suggest restating as > follows: > > o A 3-month supply of address space may be requested if the new MDN can > show a demonstrated one-year utilization history. > > B. ARIN General Counsel - Legal Assessment > > This proposal does not create any material legal issue. > > 3. Resource Impact > > This policy would have minimal resource impact from an implementation > aspect. It is estimated that implementation would occur within 3 months > after ratification by the ARIN Board of Trustees. The following would be > needed in order to implement: > ?? Updated guidelines and internal procedures > ?? Staff training > > 4. Proposal/Draft Policy Text Assessed > Date: 3 September 2014 > Problem Statement: > The previous MDN policy was too limiting in that a new MDN could only > qualify under immediate need. This was extended by ARIN-2013-8 where the > minimum allocation will now be assigned unless immediate need for more > can be demonstrated. > Unfortunately, this policy did not go far enough. There may be some > cases where there is a one year utilization history that is applicable > to a new MDN. For example, imagine a network that is divided into four > regions, each an MDN. Three of the four MDNs have been growing at a /20 > per year. The fourth MDN has been growing at a /19 per year, it is over > 80% utilized, and the region is too large. The region will be divided in > half, which half of the current customers and their addresses to be > migrated into a new MDN (Region 5). It is also anticipated that half of > Region 4???s growth will be shifted to Region 5. With Region 4 and > Region 5 each above 80%, both should qualify for subsequent allocations > at half of what was Region 4???s growth rate. > Policy statement: > replace section 4.5.4 created by 2013-8: > ???Upon verification that the organization has shown evidence of > deployment of the new discrete network site, the new network(s) shall be > allocated the minimum allocation size under section 4.2.1.5 unless the > organization can demonstrate additional need using the immediate need > criteria (4.2.1.6).??? > with: > Upon verification that the organization has shown > evidence of deployment of the new discrete network site, the new > network(s) shall be allocated one of the following: > - the minimum allocation size under section 4.2.1.5 > - more than the minimum if the organization can demonstrate additional > need using the immediate need criteria (4.2.1.6) > - a three month supply if there is an applicable one year utilization > rate, specific to the use to be covered by the new MDN, on which to base > a three month supply on as per 4.2. > Timetable for implementation: Immediate > > > ------------------------------ > > Message: 2 > Date: Wed, 24 Dec 2014 11:50:42 -0500 > From: William Herrin <[email protected]> > Cc: "[email protected]" <[email protected]> > Subject: Re: [arin-ppml] Recommended Draft Policy ARIN-2014-1: Out of > Region Use > Message-ID: > < > cap-gugw1kyrtk8wx9or3-afdqun1_d5gqef1gs66oc5uu7y...@mail.gmail.com> > Content-Type: text/plain; charset=UTF-8 > > On Wed, Dec 24, 2014 at 11:21 AM, ARIN <[email protected]> wrote: > > Policy statement: > > > > Create new Section X: > > > > ARIN registered resources may be used outside the ARIN service region. > Out > > of region use of IPv4, IPv6, or ASNs are valid justification for > additional > > number resources if the applicant is currently using at least the > equivalent > > of a /22 of IPv4, /44 of IPv6, or 1 ASN within the ARIN service region, > > respectively. > > > > The services and facilities used to justify the need for ARIN resources > that > > will be used out of region cannot also be used to justify resource > requests > > from another RIR. When a request for resources from ARIN is justified by > > need located within another RIR?s service region, the officer of the > > applicant must attest that the same services and facilities have not been > > used as the basis for a resource request in the other region(s). ARIN > > reserves the right to request a listing of all the applicant's number > > holdings in the region(s) of proposed use, but this should happen only > when > > there are significant reasons to suspect duplicate requests. > > I think this is bad policy which will encourage registry shopping by > large multinational companies who really don't need yet another > advantage over their smaller competitors. Worse than just making ARIN > a flag-of-convenience registry to the world, it includes just enough > in-region requirement to shut out small players. I reiterate my > OPPOSITION to this draft policy. > > Regards, > Bill Herrin > > > > > -- > William Herrin ................ [email protected] [email protected] > Owner, Dirtside Systems ......... Web: <http://www.dirtside.com/> > May I solve your unusual networking challenges? > > > ------------------------------ > > Message: 3 > Date: Wed, 24 Dec 2014 11:54:48 -0500 > From: William Herrin <[email protected]> > Cc: "[email protected]" <[email protected]> > Subject: Re: [arin-ppml] Recommended Draft Policy ARIN-2014-17: Change > Utilization Requirements from last-allocation to total-aggregate > Message-ID: > < > cap-guguqsodsqb6rqsvpnjdmkq_s0xu1f32nmcwtjcmznho...@mail.gmail.com> > Content-Type: text/plain; charset=UTF-8 > > On Wed, Dec 24, 2014 at 11:21 AM, ARIN <[email protected]> wrote: > > Policy statement: > > > > Replace Section 4.2.4.1 > > > > ISPs must have efficiently utilized all allocations, in aggregate, to at > > least 80% and at least 50% of every allocation in order to receive > > additional space. This includes all space reassigned to their customers. > > > > Replace Section 4.3.6.1 > > > > End-users must have efficiently utilized all assignments, in aggregate, > to > > at least 80% and at least 50% of every assignment in order to receive > > additional space, and must provide ARIN with utilization details. > > I SUPPORT this draft policy as written. I believe it resolves an > ambiguity in ARIN policy regarding utilization of assigned blocks > prior to the most recent in a reasonable and even-handed manner. > > Regards, > Bill Herrin > > > -- > William Herrin ................ [email protected] [email protected] > Owner, Dirtside Systems ......... Web: <http://www.dirtside.com/> > May I solve your unusual networking challenges? > > > ------------------------------ > > Message: 4 > Date: Wed, 24 Dec 2014 12:03:10 -0500 > From: Martin Hannigan <[email protected]> > To: William Herrin <[email protected]> > Cc: "[email protected]" <[email protected]> > Subject: Re: [arin-ppml] Recommended Draft Policy ARIN-2014-1: Out of > Region Use > Message-ID: <[email protected]> > Content-Type: text/plain; charset=utf-8 > > If Ebola were a draft policy it would be this one. Not in favor. > > > > > On Dec 24, 2014, at 11:50, William Herrin <[email protected]> wrote: > > > >> On Wed, Dec 24, 2014 at 11:21 AM, ARIN <[email protected]> wrote: > >> Policy statement: > >> > >> Create new Section X: > >> > >> ARIN registered resources may be used outside the ARIN service region. > Out > >> of region use of IPv4, IPv6, or ASNs are valid justification for > additional > >> number resources if the applicant is currently using at least the > equivalent > >> of a /22 of IPv4, /44 of IPv6, or 1 ASN within the ARIN service region, > >> respectively. > >> > >> The services and facilities used to justify the need for ARIN resources > that > >> will be used out of region cannot also be used to justify resource > requests > >> from another RIR. When a request for resources from ARIN is justified by > >> need located within another RIR?s service region, the officer of the > >> applicant must attest that the same services and facilities have not > been > >> used as the basis for a resource request in the other region(s). ARIN > >> reserves the right to request a listing of all the applicant's number > >> holdings in the region(s) of proposed use, but this should happen only > when > >> there are significant reasons to suspect duplicate requests. > > > > I think this is bad policy which will encourage registry shopping by > > large multinational companies who really don't need yet another > > advantage over their smaller competitors. Worse than just making ARIN > > a flag-of-convenience registry to the world, it includes just enough > > in-region requirement to shut out small players. I reiterate my > > OPPOSITION to this draft policy. > > > > Regards, > > Bill Herrin > > > > > > > > > > -- > > William Herrin ................ [email protected] [email protected] > > Owner, Dirtside Systems ......... Web: <http://www.dirtside.com/> > > May I solve your unusual networking challenges? > > _______________________________________________ > > 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. > > > ------------------------------ > > Message: 5 > Date: Wed, 24 Dec 2014 12:05:33 -0500 (EST) > From: Randy Carpenter <[email protected]> > To: John Santos <[email protected]> > Cc: [email protected] > Subject: Re: [arin-ppml] 2014-14, was Internet Fairness > Message-ID: > <[email protected]> > Content-Type: text/plain; charset=utf-8 > > > I also oppose. John Santos sums up the big points with which I agree: > > ----- On Dec 24, 2014, at 1:00 AM, John Santos [email protected] wrote: > > > Oppose 2014-14 > > > > 1) /16 is not "small" > > Agreed. Even by ARIN definition it is "medium" :-) > > > 2) The problem the proposal purports to solve hasn't actually been > > demonstrated. "ARIN staff [...] is spending scarce staff time on needs > > testing of small transfers." Obviously, doing the necessary checking > > requires staff time, but is it a significant amount? Is it taking much > > longer than it used to? Is it costing ARIN a lot of money in staff > > wages and overhead to do these assessments, or is it lost in the noise? > > I have not heard or seen any data to support the "ARIN staff is too > burdened" argument, other than there being a slightly longer processing > time for IPv4 requests, which I am completely fine with. IPv6 requests have > been pretty speedy for me. > > -Randy > > > ------------------------------ > > Message: 6 > Date: Wed, 24 Dec 2014 09:20:17 -0800 > From: Seth Mattinen <[email protected]> > To: [email protected] > Subject: Re: [arin-ppml] 2014-14, was Internet Fairness > Message-ID: <[email protected]> > Content-Type: text/plain; charset=windows-1252; format=flowed > > On 12/23/14 22:00, John Santos wrote: > > 1) /16 is not "small" > > > Then make it /18 to align with the fee schedule definition of "small". > > ~Seth > > > ------------------------------ > > Message: 7 > Date: Wed, 24 Dec 2014 09:23:58 -0800 > From: Andrew Dul <[email protected]> > To: [email protected] > Subject: Re: [arin-ppml] Recommended Draft Policy ARIN-2014-1: Out of > Region Use > Message-ID: <[email protected]> > Content-Type: text/plain; charset=utf-8 > > Marty, > > Can you be a little more specific. Are you opposed to the whole concept > or the draft as written? > > Do you support the ARIN's current operational practice of excluding > address space, which is in use outside the region, from being considered > utilized when applying for additional allocations? > > This was one of the things this policy was attempting to rectify. > > I know you support removing all needs requirements, but that isn't the > current policy in this region. > > Andrew > > On 12/24/2014 9:03 AM, Martin Hannigan wrote: > > If Ebola were a draft policy it would be this one. Not in favor. > > > > > > > >> On Dec 24, 2014, at 11:50, William Herrin <[email protected]> wrote: > >> > >>> On Wed, Dec 24, 2014 at 11:21 AM, ARIN <[email protected]> wrote: > >>> Policy statement: > >>> > >>> Create new Section X: > >>> > >>> ARIN registered resources may be used outside the ARIN service region. > Out > >>> of region use of IPv4, IPv6, or ASNs are valid justification for > additional > >>> number resources if the applicant is currently using at least the > equivalent > >>> of a /22 of IPv4, /44 of IPv6, or 1 ASN within the ARIN service region, > >>> respectively. > >>> > >>> The services and facilities used to justify the need for ARIN > resources that > >>> will be used out of region cannot also be used to justify resource > requests > >>> from another RIR. When a request for resources from ARIN is justified > by > >>> need located within another RIR?s service region, the officer of the > >>> applicant must attest that the same services and facilities have not > been > >>> used as the basis for a resource request in the other region(s). ARIN > >>> reserves the right to request a listing of all the applicant's number > >>> holdings in the region(s) of proposed use, but this should happen only > when > >>> there are significant reasons to suspect duplicate requests. > >> I think this is bad policy which will encourage registry shopping by > >> large multinational companies who really don't need yet another > >> advantage over their smaller competitors. Worse than just making ARIN > >> a flag-of-convenience registry to the world, it includes just enough > >> in-region requirement to shut out small players. I reiterate my > >> OPPOSITION to this draft policy. > >> > >> Regards, > >> Bill Herrin > >> > >> > >> > >> > >> -- > >> William Herrin ................ [email protected] [email protected] > >> Owner, Dirtside Systems ......... Web: <http://www.dirtside.com/> > >> May I solve your unusual networking challenges? > >> _______________________________________________ > >> 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. > > > > ------------------------------ > > _______________________________________________ > ARIN-PPML mailing list > [email protected] > http://lists.arin.net/mailman/listinfo/arin-ppml > > End of ARIN-PPML Digest, Vol 114, Issue 50 > ****************************************** >
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