[arin-ppml] ARIN-2014-20 and current future looking needs assessment

[Jason Schiller]

Hello PPML,

I wanted to start a new thread on the topic of ARIN's current procedure of
assessing 24 month need for transfers based on a future looking business
plan that is not supported by half as much utilization over the previous
year.

Personally I was surprised when we were discussing 2014-20 that objections
arose from the removal of the current practice of permitting ARIN to base a
justification on a future looking business plan.

My understanding is that the original 2008-6 required the transfer to be
"in the exact amount which can be justified under ARIN resource-allocation
policies."  Meaning you can only transfer as much address space as you
could otherwise qualify for from ARIN.

This was modified in 2011-11 when we moved the ARIN requests for ISPs to a
3 month time horizon, we pushed out the transfer time horizon to one year.
The net result being to bring in the time horizon of ARIN allocations
without impacting the time horizon of transfers.  (this also suggests that
the amount of space an organization qualifies for under transfers was
previously tied to how much space they qualify for under section 4)  There
was no modification in how need is measured.

Then 2011-12 was a simple change to push out transfers from a 1 year time
horizon to a two year time horizon.

Then 2011-1 split out inter-ARIN transfers from intra-ARIn transfers, but
did not change the workings of intra-ARIN transfers.

2012-1 broke down the policies into bullets.  There was some early
discussion about removing utilization as a measure of policy compliance,
but that was too controversial and dropped.

It was my understanding that when discussed and adopted 2008-6 that
transfers were only to be permitted "in the exact amount which can be
justified under ARIN resource-allocation policies."

2012-3 was a simple change to "number resources".

So where did this idea that you could qualify differently for transfer
space than ARIN space other than simply being permitted a larger time
horizon?

Are others in the community equally surprised by the ability to get space
on a future looking business case?

Supporting data below.

__Jason

Tthe original 2008-6 required the transfer to be "in the exact amount which
can be justified under ARIN resource-allocation policies."  Meaning you can
only transfer as much address space as you could otherwise qualify for from
ARIN.

I took this to mean that you could only qualify for a certain amount of
space on the transfer market if you would otherwise qualify to get that
same space from ARIN (if they had it to offer).

Bill Darte, as originator of 2008-6 is that what was intended?

"It's intent is to preserve the current tradition of needs-based allocation
and assignment because that's what we've heard clearly out of discussion up
to this point in time in this community. ... The policy says need in
accordance with current and applicable ARIN policy."

---

This was further modified in 2011-11 where we reduce ARIN
allocations/assignments to 3 months, and moved the 1 year restriction from
the ARIN allocation/assignment section 4 to the transfer section.  This
yields the more familiar text:

"...they can justify under current ARIN policies showing how the addresses
will be utilized within 12 months."

At the time there was some controversy for how need should be determined
for transfers, but that portion of the policy was dropped.

"not clear how "justified need" has been or should be determined, however
this proposal no longer addresses this."

My read is 2011-11 leave the previous needs test in place.

---

This was immediately further modified by 2011-12 which simply extended the
time from 12 to 24 months.

It was modified by 2011-1 which removed and added ARIN specific language to
separate intra-ARIN transfers, but did not change the intra-ARIN policy
otherwise.

---

2012-1 broke the requirements down into bullets and added additional
requirements that the organization providing the space for transfer is
ineligible for additional space from ARIN for 12 months, and could not have
received ARIN space 12 months prior to the transfer.  It also established a
minimum of a /24.

The text changed from:

"Such transferred number resources may only be received uder RSA by
organizations that are within the ARIN region and can demonstrate the need
for such resources in the amount which they can justify under current ARIN
policies showing how the addresses will be utilized within 24 months"

to:
"Conditions on recipient of the transfer:
* 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."

While the word "justify" is gone I believe the intent is still intact.
There is some discussion in the rational that
"The one key point that has been removed from the original text is that a
needs based
review remains in place."

This refers to the original prop that added a clause to remove needs based
reviews, which is not part of the adopted draft.
this text that was dropped is:
"and add to the NRPM Section 12:
10. ARIN will not use utilization as a measure of policy compliance
for addresses transferred under 8.3."

this was then further modified by 2012-3 but that just changed IP addresses
to number resources...




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