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

Scott Leibrand scottleibrand at gmail.com
Thu May 1 14:45:54 EDT 2014

Ok.  Sounds like Mike has added a clearer restriction to his policy
proposal, so I'm satisfied with that.


On Thu, May 1, 2014 at 11:16 AM, John Curran <jcurran at arin.net> wrote:

> 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
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