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

[Jason Schiller]

Comments in line.

On Fri, Sep 12, 2014 at 4:08 PM, David Huberman <
David.Huberman at microsoft.com> wrote:

> First, a direct reply to Jason, who wrote:
> >So we wanted some requirement to prevent someone
> >from spinning up Orgs just to get space with no intention of using it.
>
> I don't like writing policy which tries to outsmart scammers.  Scammers
> represent a fraction of a percent of ARIN transactions. We should write
> policy that makes good technical sense for the 99%. Also, this is 8.3
> transfers - space bought on a market, and recognized in ARIN's Whois.   In
> my experience no matter how section 8 is written, bad actors will buy the
> space they want to do bad things with, use it, and dump it - with or
> without allowances to update ARIN's Whois.
>
> Second, a comment about 2014-20:  how do these common scenarios work in
> the proposed policy:
>
> Scenario 1:
> ABC Trucking Company (an end-user) has 29 /24s of space from ISP.  ABC is
> going to disco from that ISP, and is going to buy space on the market to
> renumber into and grow.  Based on their 2 year projections, they've decided
> to buy a /16 on the market.  Do they qualify to transfer the entire /16
> under 2014-20?
>
> There is not enough information here to answer, so I'm going to make some
more stuff up.
ABC Trucking Company got the following ISP blocks

/24  - 06/19/2014
/22  - 07/10/2011
/21  - 08/01/2012
/20  - 08/22/2014

Today, 9/15/2014 ABC Trucking Company demonstrates that they are using
7,423 or more IPs.
((29*(2^(32-24)))*0.8)

Under 8.3.2.3.1 ABC Trucking Company qualifies to make one or more
transfers up to 29 /24s.
They also qualify under 8.3.2.3.2.

Choosing a 90 day look back window, they can show they used 29 /24s and
qualify for 4*29= 116 /24s
They can immediately transfer in  a /18, /19, /20 and a /22.

They could choose to transfer in a /18 and a /19.
They could renumber their ISP space into the /19, and use the /18 and the
remainder of the three /24s out of the /19 for growth over the next 90 days

on 12/13/2014 they could again re-demonstrate they are over 80%.
They then qualify under 8.3.2.3.1 to double again
They also qualify under 8.3.2.3.2.

Choosing a 90 day look back window, they can show they used a /18 and three
/24s  and qualify for four times that amount, a /16, /20, and a /21

They could choose to transfer in a /16.

---------------------

Alternatively, ABC Trucking might have had slow growth in the past... in
that case it would look like:

ABC Trucking Company got the following ISP blocks
/24 - 03/01/2010
/24 - 03/01/2011
/24  - 06/01/2011
/23  - 09/01/2011
/21  - 09/01/2012
/20  - 09/01/2013

Today, 9/15/2014 ABC Trucking Company demonstrates that they are using
7,423 or more IPs.
((29*(2^(32-24)))*0.8)

Under 8.3.2.3.1 ABC Trucking Company qualifies to make one or more
transfers up to 29 /24s.
(say a /20, /21, /22 and a /24).

They can transfer these all in on 9/15/2014.
They take 30 days to renumber and return the ISP space.
They return all but three ISP /24s blocks.
This is because they have added three more /24s worth of growth to their
new space from transfers.
They are holding a /20, /21, /22 and a /24 and and three ISP /24s.

On 10/15/2014 they again re-demonstrate they are over 80%.
They then qualify under 8.3.2.3.1 to double again, and can make one or more
transfers up to a /19.
say they transfer a /23 and a /24.
They could then return the final ISP space, and re-demonstrate 80%
utilization.

On 11/01/2014 they again re-demonstrate they are over 80%.
They then qualify under 8.3.2.3.1 to double again, and can make one or more
transfers up to a /19.
say they transfer a /19 and grow into that /19 over the next 90 days.
They are now holding a /19, /20, /21, /22, /23 and two /24s.

On 1/30/2015 they again re-demonstrate they are over 80%.
They then qualify under 8.3.2.3.1 to double again (another /19), BUT they
can also qualify under 8.3.2.3.2.
Choosing a look back window from 1/30/2015 to 11/01/2014, they can
demonstrate they used a /19 in 90 days.
This yields the ability to transfer in a /17.
Say they transfer in a /18
They are now holding a /18, /19, /20, /21, /22, /23 and two /24s.

If they make no further transfers then if they can demonstrate 80%
utilization on or before 4/30/2015 they qualify for a /16, and if they
transfer in a /16, they would be holding a /16, /18, /19, /20, /21, /22,
/23 and two /24s.

If they make no further transfers, under 8.3.2.3.1 ABC Trucking Company
qualifies to make one or more transfers up to 29 /24s.
(say a /20, /21, /22 and a /24).nsfers then if they can demonstrate after
4/30/2015 that they have 80% utilization they qualify for doubling (
another /17) and would be holding two /17, /18, /19, /20, /21, /22, /23 and
two /24s.  They would holding the equivalent of a /16.

They have the option at anytime to transfer in more blocks up to a /18.

===============

Scenario 2:
> XYZ Cloud Hosting Company (also an end-user, but could argue to be an ISP
> if it wanted) has a /20 from ARIN.  They want to buy a /15 that's available
> on the market for cheap, because they hope that's what they'll use in 2
> years, and the price of the /15 is right.  Do they qualify for an 8.3
> transfer under 2014-20 as an EU and/or as an ISP?
>

It doesn't make a difference.  The amount of space an organization gets is
based on how much they are currently using, or how much they used in their
look back window.

The only substantial difference between end-use and ISP is for new
organizations.
1. ISP can book IPs allocated/assigned for current customers or customer
orders
2. End-users get a starting block of up to a /24 and ISPs of up to /21

This means an rapidly growing End-user would need to complete three
transfers to catch up to a new ISP who could start with a /21 if they have
the appropriate documentation.

transfer 1: /24  total final holding /24
transfer 2: /24 - used a /24 in less than 90 days, qualify for a /21
transfer 3: /19 - used a /21 in less than 90 days, qualify for a /19

OR  transfer 3: /21 - used up the /21 in more than 90 days, can double up
to a /21 and a /24.


This means an large End-user would need to complete four transfer through
doubling to catch up to a new ISP who could start with a /21 if they have
the appropriate documentation.

through doubling that would be:
transfer 1: /24  total final holding /24
transfer 2: /24  total final holding two /24s
transfer 3: /23  total final holding one /23, and two /24s
transfer 4: /22  total final holding one /22, one /23, and two /24s

=======================


>
> Scenario 3:
> XXLarge ARIN company has 1 million IP addresses from ARIN.  They buy the
> exclusive first rights to a /8 worth of address space in the open market.
> Under 2014-20, how much space can they transfer into ARIN on day 1, and how
> much space has to sit in the old company's name?
>

As soon as XXLarge ARIN company can demonstrate that 80% of their 1 million
IPs are in use, they can transfer the entire /8 since it is less than
double of what they are currently holding.


>
> Thanks for indulging me.  I'm trying to understand how 2014-20 will act in
> what I think are real-world scenarios,
> /david
>


The short description of the policy for orgs holding addresses is
1. do nothing until you can show 80% utilization on average
2. When you cross 80% you qualify to double in size.
3. If your growth rate over the most recent 3-12 months is more than
doubling, you qualify for a 2 year run rate instead of doubling.
4. You can complete one or more transfers up to the amount you are
qualified for.
5. (You can always choose to transfer less than you qualify for)
6. At any time you can re-demonstrate 80% and re-qualify

David, is does this help you understand how the policy is intended to be
used?

Thanks,

__Jason




-- 
_______________________________________________________
Jason Schiller|NetOps|jschiller at google.com|571-266-0006
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