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

Mike Burns mike at iptrading.com
Sat Sep 13 08:34:04 EDT 2014


Hi Jason,



  However, assuming that 2014-14 is discussed first and does not pass, would you still oppose 2014-20?

  Possibly. 


  Would you agree that 2014-20 a movement in the direction as it is in the middle ground between current needs based and transfers without need?

  It seems like you are removing the 24month distinction between transfers and free pool allocations and replacing it with a more complex, although possibly more expansive mechanism. I would have to consider more analysis of the various scenarios and balance my support against my opposition to NRPM bloat and transfer policy complexity.


  Would you agree that while 2014-20, in your opinion does not go far enough, it is still better than the status quo?

  Well the status quo has changed, with minimums reduced to /24, and I have not had time to analyze sufficiently. One of the real problems I had encountered with transfers was related to the /20 minimum and I have not had problems with transfers due to explosive growth. Unfortunately!



  2014-20 does in fact separate the needs test for transfers from the needs test for ARIN allocations and assignments.
  WRT transfers, at any time, an org that can demonstrate 80% utilization on average across all their IP space, is eligible to completed 1 or more transfer and up to double their holdings.  This is very different from demonstrating 80% utilization of your most recent block, and efficiently using all your older IP space, and only getting double what you used in the last 12 months.


  This however does not help orgs with no resources 2*0=0, nor does it help orgs that have a history of slow growth with recent rapid growth.


  To help orgs that have no resources, I wanted to make it fairly easy for them to get what ever the minimum assignment/allocation is (the only tie back to ARIN issued IP space) up to a /24 for end-sites and up to a /21 for ISPs.  I wanted at the same time to disqualify orgs that have no actual plan on having stuff to number.  Once they get their initial space that can use it to 80% and then double, us that to 80%, and double again, and so on.


  For orgs with only recent rapid growth, and for new orgs who don't want to keep doubling, they can choose a look back window between 3 and 12 months, and calculate a two year supply.


  So a new org may transfer in a /24, show 80% utilization after 45 days, transfer in an additional /24, show 80% utilization of both blocks after 90 days, and then qualify to transfer in up to the equivalent of  16 * /24s.


  __Jason


     
  It sounds better to me than the current system, but I definitely prefer 2014-14. My concern is that whenever verbiage is added to the NRPM it opens new doors to misinterpretation which have to be addressed through more verbiage. In addition, whenever new issues or problems are discovered when applying this new mechanism to different business-case scenarios, more verbiage would be necessary to restore "fairness". And considering the myriad ways that businesses can find themselves in need of IPv4 space I think we are taking the first steps down a dangerous path with your proposal. On the other hand 2014-14 addresses the needs of fast and slow growing companies, and the needs of small companies, with less of this danger and less risk of out-of-policy transfers which hold their own separate dangers. 

  Regards,
  Mike







    


    






  On Fri, Sep 12, 2014 at 1:19 PM, Mike Burns <mike at iptrading.com> wrote:

    Hi Jason,

    I apologize for not commenting on this earlier, I decided to sit back and see what other input was received.

    I think that you have correctly identified in your problem statement certain issues we face at the near-exhaust stage and beyond.
    ARIN allocation policy was always premised on the free pool, and we have decided to borrow the same policy and apply it to the wholly new environment of a trading market.
    You correctly identify issues like transactional costs which are imposed on recipients as a result of free-pool premised policies whose authors did not consider these implications.
    You note that ARIN policy does not efficiently accommodate various recipient growth profiles, especially as any wiggle-room is squeezed out of every allocation by a team of ARIN reviewers.

    We can expect more such problems as market forces tend to diverge from ARIN policy prescriptions, and it is my belief that the weight of these distortions puts a strain on Whois accuracy as more money flows into this market.  When business needs are faced-up against ARIN policy, at a certain point the business risk of inadequate allocation overrides the risk of an out-of-policy transfer. And these out-of-policy transfers can happen by multiple means, including phased-contracts, permanent leasing,  and zombie corporations which ARIN policy can't touch. ARIN policy is a market distortion which will likely grow larger over time.

    Rather than try to put our finger in the dyke through more and more NRPM verbiage, isn't it time we acknowledged that a separate allocation paradigm exists in the trading market which requires a separate (or absent) needs-test for transfers? 

    I believe that every circumstance elucidated in your proposal is answered by the much more streamlined 2014-14, which removes needs testing from transfers smaller than a /16, once per year. 

    I am against further un-necessary clutter in the NRPM, and if we seek to match every unknown and unknowable vagary of the impending transfer market with new policy, we open the door to a virtual tax code of text. Here is one of your new sections:

    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. 

    8.3.2.3.2.1?

    While I support the recognition of the problems Jason identified, I am opposed to 2014-20.  
    (Also I would counsel against regarding silence as approval.)

    Regards

    Mike Burns


    From: Jason Schiller 
    Sent: Friday, September 12, 2014 12:13 PM
    To: owens at nysernet.org ; Kevin Blumberg ; David Farmer 
    Cc: arin-ppml at arin.net 
    Subject: Re: [arin-ppml] Draft Policy ARIN-2014-20: Transfer Policy Slow Start and Simplified Needs Verification

    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> 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> 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|571-266-0006






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