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

[Owen DeLong]

On May 2, 2011, at 8:25 PM, Matthew Kaufman wrote:

> On 5/2/2011 8:16 PM, Owen DeLong wrote:
>> 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.
> 
> Because post-runout is a different world. Pre-runout I get 3 months of space, I use it, I go back to ARIN, I get 3 more months, I use it, I go back to ARIN and this time I get a whole year.
> 
And you can do that with the market as well.

> Post-runout I get whatever space I can successfully bid for, which takes an indeterminate amount of time, energy, and money and then three months later there may or may not be space available from anyone, and if there is it is quite possibly not at a price I can afford.
> 
Welcome to the post-run-out world. Why should we let you acquire more space now and deny that
space to someone else who has justified need now?

> You come up with a likely post-runout scenario where I can be *guaranteed* to get 3 more months of address space at no higher price than it takes to get the 3 months this time, and with minimal delay once I qualify for the next three months, and I'll support your point of view.
> 
If you expect to be guaranteed anything in terms of availability after runout, you are suffering
from hallucinations and I suggest you seek medical or psychological assistance.

However, I still don't see anything in your argument that justifies why you should be able
to deny space to someone else just because you might need it three months from now.

>>> 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.
> 
> See above about how post-runout is completely different.
> 
Except that it isn't. In fact, if anything, it is more critical to preserve these protections for the
rest of the community so that the people with more money don't amass larger address blocks
just for the sake of preventing their use by more immediate needs with less money.

>>> 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.
> 
> What section number are you referring to? There's nothing in 4.2.2.1 that requires that I justify more than a /20 to get that /14.
> 
Section 4.1.5 combined with section 4.2.1 mean that ARIN will review your justified need
in determining the size prefix you are able to acquire whether through initial allocation
from ARIN or by obtaining your first resources through a transfer request.

I admit that on review, the initial allocation policy for IPv4 appears to have a number of
flaws and probably should be improved. However, this should be true regardless of the
source of the addresses.

Owen