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

Mon Sep 15 15:14:01 EDT 2014

sorry I messed up the dates...

In the first example for ABC Trucking those should have all been 2014 dates:

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

The idea being all their ISP space was within a 90 day look back window.

Sorry for the confusion.

__Jason

On Mon, Sep 15, 2014 at 3:10 PM, Jason Schiller <jschiller at google.com>
wrote:

> 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
>
>

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