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

[David Farmer]

On 5/2/11 21:30 CDT, Matthew Kaufman wrote:
> On 5/2/2011 7:14 PM, David Farmer wrote:
>> On 5/2/11 13:00 CDT, ARIN wrote:
>>> 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).
>>
>> Do you indent to eliminate the ability for end users to be the
>> recipient of transfers? You seem to be doing that.
>>
>> Would you please state your intended result for this policy in plain
>> English, because I'm confused as to your intended outcome.
>>
>> Like; "All ISP should be able to get a 12month supply" for example, if
>> that is your intended outcome.
>
> "Any transfer recipient should be able to get a 12 month supply for an
> 8.2 or 8.3 transfer as long as they justify it as well as an ISP had to
> justify additional space back in the old days"

I'd like to get staff's interpretation of how the second paragraph of 
8.2 is applied in practice.  When policy 2009-8 (the change to 3 month 
at IANA run-out) was written there wasn't any needs justification 
related to 8.2 transfers.  But I agree with you that the same needs 
justifications should apply to both 8.2 and 8.3.

Maybe the best way to fix that issue is the change the last paragraph of 
4.2.4.4 Subscriber members after one year to read

This reduction does not apply to resources received via a transfer in 
Section 8. An organization receiving a transfer under section 8 may 
continue to request up to a 12-month supply of IP addresses."

Instead of the current;

This reduction does not apply to resources received via section 8.3. An 
organization receiving a transfer under section 8.3 may continue to 
request up to a 12-month supply of IP addresses.

You also want to change the rules for new ISP, I think I can support 
changing this, given that they are going to have to buy addresses on the 
market maybe we shouldn't tie one hand behind there back too.  Life is 
going to be hard enough for a new ISP even without slow start and all of 
the other restriction put on them now.  However, the reason for slow 
start (4.2.2.3) was that it is difficult to judge the validity of a 12 
month estimate for an organization that doesn't have any history to base 
it on.  Do you have any suggestion on how to deal with that issue?

Also, I think you want to drop 4.2.2.1.3 Essentially a three month 
justification for a /20, that sounds reasonable.  But, maybe we should 
also drop 4.2.2.1.4. Renumber and return expecting an ISP to renumber 
out of a current upstream block post-run-out seems equally harsh and 
unrealistic.

So I think I support your intent, but not necessarily your prescribed 
language.  We should seriously look at easing up the restrictions on new 
ISPs as we enter a world of new IPv4 realities. Given these new 
realities, the old restrictions seem kind of harsh.  And I think the 
needs justification should be the same for both 8.2 and 8.3  Maybe we do 
this as two different policies, because they really are separate issues, 
with separate rationales.

-- 
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David Farmer               Email:farmer at umn.edu
Networking & Telecommunication Services
Office of Information Technology
University of Minnesota	
2218 University Ave SE	    Phone: 612-626-0815
Minneapolis, MN 55414-3029   Cell: 612-812-9952
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