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

[Owen DeLong]

You have always been able to get space from ARIN based on forward-looking business cases, but it has been limited.

This applies to both free pool and transfers equally, though free pool being limited to a 3-month window now for ISPs makes “forward” a little less useful.

I would venture that most end-user initial allocations are based on at least somewhat forward-looking projections.

Owen

On Sep 23, 2014, at 11:13 AM, Martin Hannigan <hannigan at gmail.com> wrote:

> ARIN is not qualified to limit Internet competition based on b-case review. 
> 
> I'd be interested to hear how they would accomplish this. 
> 
> Best, 
> 
> -M<
> 
> 
> 
> On Sep 23, 2014, at 20:01, Jason Schiller <jschiller at google.com> wrote:
> 
>> 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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