[arin-ppml] Draft Policy ARIN-2014-20: Transfer Policy Slow Start and Simplified Needs Verification

Fri Sep 12 14:23:28 EDT 2014

The first sentence - 8.3.1.1 for new EUs.

Why is there a usage requirement of 50% immediately?  My experience is networks are not built like that.

David R Huberman
Microsoft Corporation
Principal, Global IP Addressing
________________________________
From: arin-ppml-bounces at arin.net <arin-ppml-bounces at arin.net> on behalf of Jason Schiller <jschiller at google.com>
Sent: Friday, September 12, 2014 10:44:20 AM
To: Scott Leibrand
Cc: arin-ppml at arin.net
Subject: Re: [arin-ppml] Draft Policy ARIN-2014-20: Transfer Policy Slow Start and Simplified Needs Verification

Scott,

I believe the text is officially out of Mike Joseph's and my control... but to answer your question...

I am suggesting we take one of the three edits as a modification to the draft, so it would be the whole draft with some minor difference to what text in the current 8.3 and 8.4 gets removed, or restated.

For clarity I will provide what the policy statement of draft could look like with the option 2 modification:

Policy statement:

Remove the following section 8.3 text:

 "> The recipient must demonstrate the need for up to a 24-month supply
  of IP address resources under current ARIN policies and sign an
  RSA.
  > The resources transferred will be subject to current ARIN policies."

 with:

"> Recipients will be subject to current ARIN policies and sign an RSA for the resources being received."

Remove the following section 8.4 text:

“Recipients within the ARIN region must demonstrate the need for up to a 24-month supply of IPv4 address space.”

Add:

8.3.1 New ORGs

8.3.1.1 End-Sites
End-user organizations which do not currently hold IP addresses, and can demonstrate 50% immediate utilization by currently held equipment, will immediately qualify for a non-M&A transfer between the minimum assignment size and a /24, inclusive.

8.3.1.2 ISPs
ISP organizations which do not currently hold IP addresses, and can demonstrate 50% immediate utilization by currently held equipment, current customers, or customer orders will immediately qualify for a non-M&A transfer between the minimum allocation size and a /21, inclusive.

8.3.2 Existing ORGs

8.3.2.1 Minimum requirements
Prior to qualifying for non-M&A address transfers, an organization must demonstrate an average of 80% utilization, as measured under section 4, across the aggregate of all addresses that are currently allocated, assigned, reallocated, or reassigned to, or otherwise in use by, the organization.

8.3.2.2 Transfer Approval
An organization which qualifies for transfers under one of the criteria in 8.3.2.3 shall be approved for the transfer in of an aggregate amount of address space as determined by the relevent section. An organization with such an approval may then complete one or more transfers, with a cumulative total not exceeding the approved amount, without submitting additional justification. An organization will be ineligible for additional non-M&A transfers until it can again demonstrate that it meets the minimum requirements in section 8.3.2.1.

8.3.2.3 Qualifying Criteria

8.3.2.3.1 Stable Growth
Organizations may be approved for the non-M&A transfer of additional address space equal to the amount of address space they were holding at the time of approval.

8.3.2.3.2 Rapid Growth
Organizations may be approved for the non-M&A transfer of additional address space equal to 24 times the organization’s calculated monthly average use rate.

8.3.2.3.2.1 Calculation of Monthly Average Use Rate
An organization may choose a look-back window of any number of months between 3 and 12, inclusive, from the date of the current request. ARIN will calculate the total amount of new addresses acquired, during the look-back window, by the organization from non-M&A transfers, direct allocations or assignments from ARIN, or reallocations or reassignments from an ISP. That total will be divided by the number of months in the look-back window to calculate the organization’s monthly average use rate.

8.3.2.3.2.2 Returned IP space
If addresses are returned or transferred out within the look-back window, then those addresses will be subtracted from the total amount of new addresses acquired for the purposes of the monthly average use rate calculation.

8.3.2.3.2.3 M&A activity
If M&A transfer activity occurs during the look-back window, the addresses acquired through M&A transfers will only be counted in the total amount of new addresses acquired if the pre-M&A organization had acquired the resources during the post-M&A organization’s look-back window.

8.4.1 -- Same text as 8.3.1

Timetable for implementation: Immediate

Hope this helps.

___Jason

On Fri, Sep 12, 2014 at 1:08 PM, Scott Leibrand <scottleibrand at gmail.com<mailto:scottleibrand at gmail.com>> wrote:
I'm still a bit confused. Is the option 2 text below what you're proposing as the complete proposal, replacing the many paragraphs and sections of your original proposal? Or are you just replacing some of it?  Can you post the full resulting policy statement?

Thanks,
Scott

On Sep 12, 2014, at 9:13 AM, Jason Schiller <jschiller at google.com<mailto:jschiller at google.com>> wrote:

It has been a week, and there has been no discussion on this thread.

I take the silence to mean the suggested "option 2" rewrite is non-controversial and meets all of Bill's concerns.

I also take the silence to mean that all three options I have suggested all result in the same implementation,
and since no one believes any of the three options differ in implementation, there is no preference.

I humbly submit we should go with option 2, as it is closest to Bill's suggestion, and keeps 8.2 and 8.3 in line
(setting the ground work for a future unification of 8.2 and 8.3).

Will there be discussion now?  Or should we just silently move forward?

Thanks,

___Jason

On Thu, Sep 4, 2014 at 11:34 AM, Jason Schiller <jschiller at google.com<mailto:jschiller at google.com>> wrote:
Bill,

Thank you.

The intent was NOT to remove the requirement for in-region recipients of transfers to sign an RSA.

My apologies.

There is a lot or parallel structure in 8.3 and 8.4 and in my mind 8.4 is identical to 8.3 except 8.4 has a clause "Except when the recipient is out of region then that region's policy applies", and " Except when the source is out of region then that region's policy applies".  I really wanted to completely merge 8.3 and 8.4 to remove the parallel structure but as an editorial re-write only and not part of this discussion.

in 8.4 there are a separate bullets for 24-month supply and sign the RSA:
"> Recipients within the ARIN region will be subject to current ARIN policies and sign an RSA for the resources being received.
 > Recipients within the ARIN region must demonstrate the need for up to a 24-month supply of IPv4 address space."

I think in my mind I imagined a similar separate bullets in 8.3, one for 24-month supply and another for sign RSA, and I intended just to remove the 24 month part.

I think there are a few ways to fix this.

Option 1 - minimun rewrtite
- remove only the "24-month" portion of the 8.3 text. This is the minimum change, but brings section 8.3 and 8.4 further out of alignment

Option 2 - single bullet for "meet ARIN policy" and "sign RSA" (8.3 as the model text)
- replace the whole "24-month" text and "meet ARIN policy" text in 8.3 with a bullet that included "sign the RSA" and "meet ARIN policy" under one bullet and is parallel to text in 8.4 (minus within the ARIN region)

Option 3 - two separate bullets for "meet ARIN policy" and "sign RSA" (8.2 as the model text)
- replace the whole "24-month" text in 8.3 with a bullet that included "sign the RSA"
-separate the "sign the RSA" and "meet ARIN policy" in 8.4 into two bullets and is parallel to text in 8.3 (plus the within ARIN region)

(If the summary of the options are hard to follow I have a suggestion for the specific rewrites below)

I think your suggestion is roughly Option 2 below (the only difference is with your suggested rewrite, there are now two bullets in 8.3 stating the recipient is subject to current ARIN policies).  Assuming all the options have the same policy implications, I would prefer option 2 or 3, as these bring greater alignment of the sections.

Do these options all meet your concern?

Does the community and ARIN staff agree that the thee options have the same policy implications?

Kevin, David,

I think at this point you own the text?
I would be supportive of the friendly amendment to modify the draft policy as follows:

OPTION 1:
Replace the following Section 8.3 text:

 "> The recipient must demonstrate the need for up to a 24-month supply
  of IP address resources under current ARIN policies and sign an
  RSA."

 with:

"> Recipients will sign an RSA for the resources being received."

OPTION 2:

 Replace the following Section 8.3 text:

 "> The recipient must demonstrate the need for up to a 24-month supply
  of IP address resources under current ARIN policies and sign an
  RSA.
  > The resources transferred will be subject to current ARIN policies."

 with:

"> Recipients will be subject to current ARIN policies and sign an RSA for the resources being received."

OPTION 3:
Replace the following Section 8.3 text:

 "> The recipient must demonstrate the need for up to a 24-month supply
  of IP address resources under current ARIN policies and sign an
  RSA."

 with:

"> Recipients will sign an RSA for the resources being received."

and replace the following Section 8.4 text:

"> Recipients within the ARIN region will be subject to current ARIN policies and sign an RSA for the resources being received.
  > Recipients within the ARIN region must demonstrate the need for up to a 24-month supply of IPv4 address space."

With:

"> Recipients within the ARIN region will sign an RSA for the resources being received.
 > The resources transferred to recipients within the ARIN region will be subject to current ARIN policies."

If all the options are indeed the same I would prefer option 2 or 3.
If the options have different policy implications and we can converge on one standard for both 8.2 and 8.3, then I would prefer that.

___Jason

On Thu, Sep 4, 2014 at 8:50 AM, Bill Owens <owens at nysernet.org<mailto:owens at nysernet.org>> wrote:
On Wed, Sep 03, 2014 at 04:55:58PM -0400, ARIN wrote:
> On 28 August 2014 the ARIN Advisory Council (AC) accepted
> "ARIN-prop-212 Transfer policy slow start and simplified needs
> verification" as a Draft Policy.
>
. . .
>
> Draft Policy ARIN-2014-20
> Transfer Policy Slow Start and Simplified Needs Verification
>
> Date: 3 September 2014
>
. . .
>
> Policy statement:
>
> Remove the following section 8.3 text:
>
> “The recipient must demonstrate the need for up to a 24-month supply
> of IP address resources under current ARIN policies and sign an
> RSA.”

Shouldn't that be something like this, instead?

 Replace the following Section 8.3 text:

 "The recipient must demonstrate the need for up to a 24-month supply
  of IP address resources under current ARIN policies and sign an
  RSA.”

 with:

 "The recipient will be subject to current ARIN policies and sign an
  RSA for the resources being received."

As written it appears to remove the requirement for recipients of in-region transfers to sign an RSA.

Bill.
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_______________________________________________________
Jason Schiller|NetOps|jschiller at google.com<mailto:jschiller at google.com>|571-266-0006<tel:571-266-0006>

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