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

[Owen DeLong]

On May 2, 2011, at 7:23 PM, Matthew Kaufman wrote:

> 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.
> 
I'm not seeing the problem. You wouldn't have gotten the space from ARIN before runout, I don't see why you
should get it now from a transfer.

> 
> 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).
> 
Again, this was the way things worked before runout or even scarcity and its really a corner case.
I don't see why it should work differently just because of runout.

> 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.
> 
You would need justified need for the /14 within 12 months under the subsequent allocations
clause or you would only be able to transfer a fraction of it. This is as intended.

Owen