[arin-ppml] ARIN-prop-204 Removing Needs Test from Small IPv4 Transfers (Sandra Brown)

[John Curran]

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 
pool.  

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 
purposes.)  

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 - 

  <http://lists.arin.net/pipermail/arin-ppml/2010-January/016211.html>

" 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.

Thanks,
/John

John Curran
President and CEO
ARIN