[arin-ppml] ARIN-prop-153 Correct erroneous syntax in NRPM 8.3
jcurran at arin.net
Sun May 29 09:21:41 EDT 2011
On May 29, 2011, at 9:01 AM, Brett Frankenberger wrote:
> On Sun, May 29, 2011 at 11:01:45AM +0000, John Curran wrote:
>> Owen -
>> The language in ARIN-prop-153 is clear enough, but it is not when read with
>> the general concepts in 4.1.8 and their potential application to specified
>> transfers under your proposal, in particular:
>> - Does the requesting organization have the option to specify the
>> transfer of a smaller block than their need, as long as it is
>> equal to or larger than the applicable minimum size specified
>> elsewhere in ARIN policy?
>> From your response, I believe your intent is "No".
>> This point will be readily argued by those requesting transfers (by pointing
>> to the text in 4.1.8) unless otherwise directly addressed in your proposal.
>> It could be as simple as adding a statement to 153 that "An organization may
>> not receive a smaller block than their documented need."
>> Note that we would still apply the remainder of the 4.1.8 regarding disallowing
>> repeated requests as a means of circumvention, i.e. an organization may only
>> receive one transfer every 3 months, but ARIN, at its sole discretion, may waive
>> this requirement if the requester can document a change in circumstances since
>> their last request that could not have been reasonably foreseen at the time of
>> the original request, and which now justifies additional space.
> The "once every three months" restriction would be useful in preventing
> repeated transfers.
> I don't see that the "an organization may not receive a smaller block
> than their documented need" is going to have much practical effect.
> ARIN has not had a practice of asking organizations to demonstrate that
> their actual need is not actually greater than what they've attempted
> to justify, and I doubt ARIN would start doing that. So the effect of
> the "may not receive a smaller block" clause is going to be that
> organizations are going to find the largest block they can on the
> transfer market, and then go to ARIN with justification for that size
> (or smaller, if they can't justify the whole block), and then transfer
> it. Someone who can justify a /15 will have no trouble justifying a
> /16, and ARIN isn't likely (at least not absent specific policy) to
> attempt to determine that the organization could really justify a /15.
I agree that is the most likely outcome of such a policy proposal
> So all that really changes if thay provision is added is organizations
> have to negotiate the transfer before going to ARIN with the
> justification. This obviously creates a risk that the justification
> will not be accepted, or that the seller will find another buyer before
> ARIN completes its review of the request (possible mitigated by the
> buyer paying a portion of the sales price to get the seller to hold
> it). And the buyer would have to accept the risk of successfully
> justifying a certain amount of space and then having the transfer fail
> for some reason, at which point he'd be stuck with that size and not be
> able to find a smaller block to transfer.
> Overall, that would seem to inject a lot of risk into the process, for
> very little gain in actual efficiency.
My goal in responding to Owen was to solely provide clear guidance as to
how to insure that implementation will match his policy goal; I'll leave
it to Owen to speak to the concerns and benefits of the policy proposal.
President and CEO
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