[arin-ppml] ARIN-prop-146 Clarify Justified Need for Transfers

[Owen DeLong]

I oppose the policy as written. There are reasons that we have a
body of IPv4 policies with a variety of definitions of justified need.
ARIN is well versed in identifying the particular categories under
which an application should be processed and there is no reason
to treat transfers differently from initial allocations and assignments.

This proposal would subject end-user transferees to the same policy
structures as ISPs which could be very detrimental to such end users.

Owen

On May 2, 2011, at 11:00 AM, ARIN wrote:

> ARIN-prop-146 Clarify Justified Need for Transfers
> 
> ARIN received the following policy proposal and is posting it to the
> Public Policy Mailing List (PPML) in accordance with the Policy
> Development Process.
> 
> The ARIN Advisory Council (AC) will review the proposal at their next
> regularly scheduled meeting (if the period before the next regularly
> scheduled meeting is less than 10 days, then the period may be extended
> to the subsequent regularly scheduled meeting). The AC will decide how
> to utilize the proposal and announce the decision to the PPML.
> 
> The AC invites everyone to comment on the proposal on the PPML,
> particularly their support or non-support and the reasoning
> behind their opinion. Such participation contributes to a thorough
> vetting and provides important guidance to the AC in their deliberations.
> 
> Draft Policies and Proposals under discussion can be found at:
> https://www.arin.net/policy/proposals/index.html
> 
> The ARIN Policy Development Process can be found at:
> https://www.arin.net/policy/pdp.html
> 
> Mailing list subscription information can be found
> at: https://www.arin.net/mailing_lists/
> 
> Regards,
> 
> Communications and Member Services
> American Registry for Internet Numbers (ARIN)
> 
> 
> ## * ##
> 
> 
> ARIN-prop-146 Clarify Justified Need for Transfers
> 
> Proposal Originator: Matthew Kaufman
> 
> Proposal Version: 1
> 
> Date: 2 May 2011
> 
> Proposal type: new
> 
> Policy term: permanent
> 
> Policy statement:
> 
> Add a subsection to Section 8 (Transfers) of the NRPM:
> 
> "Justified Need" for resources associated with a transfer shall be
> determined using the "4.2.4 ISP Additional Requests" criteria applied as
> though the recipient has been a subscriber member of ARIN for at least
> one year (whether or not that is the case).
> 
> Rationale:
> 
> An organization which is not able to obtain its initial IPv4 address
> assignment from ARIN post-runout would otherwise be limited to
> purchasing only a 3-month supply (because the language in 4.2.4.4
> regarding 8.3 transfers is not triggered).
> 
> An organization which has only recently received its first allocation
> under the "last /8" criteria is also otherwise limited to purchasing
> only a 3-month supply (because the language in 4.2.4.4 is again not
> applicable).
> 
> There is also ambiguity if 4.2.2.1.3 is applied in that a transfer to
> a new organization might only need to show need for a /20 (because that
> is what is specifically called out) even though they are receiving a
> much larger block.
> 
> There is also ambiguity with regard to transfers under 8.2 where the
> receiving organization is a new organization... not at all clear how
> "justified need" has been or should be determined.
> 
> Timetable for implementation: immediate
> 
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