[arin-ppml] ARIN-prop-204 Removing Needs Test from Small IPv4 Transfers (Sandra Brown)
jcurran at arin.net
Thu May 1 14:16:52 EDT 2014
On May 1, 2014, at 1:14 PM, Scott Leibrand <scottleibrand at gmail.com> wrote:
>> We actually consider that paragraph regarding "repeated requests" within the context
>> of the policy section in which it was adopted, so 'requests' refers to requests for ARIN-
>> issued resources (i.e. those that could lead to "Unmet Requests"), and hence do not
>> consider it to be applicable to transfers.
> How do you square that with the presence of the words "or transfer"? In full, "an organization may only receive one allocation, assignment, or transfer every 3 months".
This section ("Unmet Requests") is setting policy with regards to resource
requests once there are "unmet requests" due to lack of regional IPv4 free
If an organization has received an allocation or assignment or transfer
within the last 3 months, it may not make a request for additional space
to be issued from ARIN "in a manner that would circumvent 4.1.6" (which
is ARIN's issuance of address space on CIDR boundaries for aggregation
So, those who have received a recent transfer will be precluded from
requesting an assignment or allocation from ARIN; they should have
waited instead and ended up with the issuance of a single slightly
larger block if possible.
Transfers are never "unmet requests" and do not involve the issuance
of address space from ARIN. This entire paragraph is intended to
prohibit people from factoring their assignment/allocation requests
to game their use of the waiting list system; this prohibition on
repeated issuance of space and its intent was noted clearly in the
staff assessment -
" Staff understands that this proposal would create a waiting list for
requestors whose IPv4 address needs cannot be fulfilled by ARIN at the
time of the request approval. The proposal includes text to prevent
requestors from gaming the policy's intent by forbidding requestors from
making multiple requests of a small size and limiting the issuance of
space to no more than once every 3 months."
Note: "prevent requests from gaming the (waiting list) policy",
and "limiting _the issuance_ of space"
The paragraph is in IPv4 general principles, and is applicable to all
types of requests for ARIN to issue space (since all of these requests
could end up in the waiting list), but no plain reading of it would
support it as a general prohibition against multiple transfers, nor
would such a purpose support its addition to the policy manual embedded
in new section entitled "Unmet Requests" whose primarily purpose was
establishment of an IPv4 waiting list.
Again, if there is a desire to create a restriction on repeated transfers
within a 3 month period, clear policy language to the effect should be
adopted. Note that such a policy proposal is also likely to get adequate
community discussion of the proposed prohibition, something that creative
reinterpretation of the existing policy text does not provide.
President and CEO
More information about the ARIN-PPML