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

[Matthew Kaufman]

On 5/2/2011 6:56 PM, Owen DeLong wrote:
> On May 2, 2011, at 5:05 PM, Matthew Kaufman wrote:
>
>> If you qualify for an 8.3 transfer there is NO reason that transfer should fall under the 3-month rules, which right now, in many cases, it does... without a change like the one I have proposed.
>>
> Please cite such a case because as it currently stands, I don't believe that to be
> accurate.
>

A. My hypothetical ISP provides service to a small town. I presently get 
two /24s of IPv4 space from my upstream provider and I'm using them at 
about 85%. ARIN has run completely out of addresses. A benefactor 
arrives and offers to transfer a /22 to me and pay for me to multihome.

I attempt to use 4.2.2.2 (Initial Allocation to ISPs, Multihomed) for my 
justification. I need to demonstrate that I am efficiently using the two 
/24s. Done. I comply with 4.2.2.2.1 (SWIP). I attempt to comply with 
4.2.2.2.2, but my growth shows that I won't really need more than a /23 
for about 7 months. Transfer would be denied because 4.2.2.2.2 has a 
three month rule (as I claimed above). Benefactor takes his space 
elsewhere, and I lose out.


B. My hypothetical ISP provides service to a single data center. I 
presently have a /20 that I was able to obtain from ARIN a few months 
ago, and I wasn't an ARIN subscriber member prior to this. I have the 
opportunity to acquire another ISP in town which has a /20 of its own, 
but which it isn't using very well because their growth plans failed 
after I opened up. I can demonstrate that my /20 and the second /20 from 
the acquisition would be filled within a year if I complete this 
transfer under section 8.2, but I'll only be able to fill out my 
existing /20 over the next three months. However, because I am under 
4.2.4.3 (Subscriber Members Less Than One Year) my 8.2 transfer is 
denied, again because 4.2.4.3 has a three month rule (as I claimed above).

on the flip side...

C. My hypothetical ISP provides service to a small city that is served 
by only one transit provider, so I cannot multihome. It has been using a 
/20 from the upstream ISP and is efficiently using 16 /24s worth of 
space with reassignment documentation (satisfying 4.2.2.1.1 and 
4.2.2.1.2). I provide detailed information showing that I can use a /20 
within the next three months (satisfying 4.2.2.1.3). Now that I have met 
all the tests, I complete a section 8.3 transfer for a /14 worth of 
space (because I have loads of money I won in the lottery). As far as I 
can tell, there's nothing in the NRPM that blocks that transfer... 
because I've met all the tests in 4.2.2.1.

Matthew Kaufman