[arin-ppml] ARIN-prop-153 Correct erroneous syntax in NRPM 8.3

Brett Frankenberger rbf+arin-ppml at panix.com
Sun May 29 09:01:17 EDT 2011

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.

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.

     -- Brett

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