[arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

Wed Oct 7 01:26:59 EDT 2015

> On Oct 6, 2015, at 6:45 PM, Jason Schiller <jschiller at google.com> wrote:
> 
> Before we started mucking around with lowering the minimum size block, it was a /20 for ISPs (/22 for multi-homed ISPs). /20 became the defacto ISP slow start.  Post 2014-13, it was reduced for to a /24 as the minimum for ISPs, but the slow start initial block was between a /24 and a /20 at the ISP's request. 
> 
> For end users it was /20 or /24 for multi-homed.
> 
> https://www.arin.net/policy/proposals/2014_13.html <https://www.arin.net/policy/proposals/2014_13.html>
> 
> Slow start of between /24 and /20 is consistent with automatic transfer pre-approval for ISPs holding no IPv4 addresses, or for ISPs whose IPv4 holding are at or above 80% used, and have no previous history in the past year to support a larger transfer.
> 
> We have never had a slow start for end-users, but could imagine a block between /24 and /22 as the right size based on the fact that most assignments are within that size, and it lines up with other region's soft landing.
> 
> Anti 2 year flip / revert to ARIN free pool is a good provision.
> 
> I have a few more thoughts for this policy.
> 
> 1. At any time, an org can opt to revert back to justified need based on their past 3-12 months (the org chooses the window size) run rate they can get a two year supply.
> 

I think that is implicit in the policy as it would get incorporated into the NRPM. Do you believe it needs to be made more explicit?

It certainly is in line with my understanding of the author’s intent as well as my own.

> [this is useful for orgs growing at faster than the slow start size] 
> 
> 2. Orgs disolved due to corporate restructuring less than 24 months after creation can keep their IP space if they meet traditional needs justification.

Do you mean that the space could be transferred to the parent organization in this case?

I would oppose such a provision because I believe it is quite ripe for abuse.

If not, then how, exactly, would you see this working? An org which is dissolved no longer exists to keep their IP space, so who is actually keeping it in this case?

Owen

> 
> ___Jason
> 
> 
> On Wed, Sep 30, 2015 at 10:42 PM, Owen DeLong <owen at delong.com <mailto:owen at delong.com>> wrote:
> Dani,
> 
> In fairness to Bill, I think he may also have chosen them because I suggested that those would be boundaries I would consider livable.
> 
> I believe they represent a good size to guarantee that small organizations are not shut out of the transfer market based on size, but still ensure that need assessment is preserved in order to prevent acquisition of addresses without intended use thereof.
> 
> While a /20 is a fair quantity of addresses (4096), it’s a pretty small number of customers for an ISP in most cases and I think anything smaller would be somewhat punitive.
> 
> It does also line up well with transfer history and other ARIN data about small-ish organizations and address issuance over the last several years.
> 
> Owen
> 
>> On Sep 30, 2015, at 03:52 , Dani Roisman <droisman at softlayer.com <mailto:droisman at softlayer.com>> wrote:
>> 
>> Hi Bill,
>>  
>> I’m interested to learn how you came up with the below proposed netblock sizes “/20 if a ISP or /22 for an end user” ?  Is there data behind that?  If not, does it make sense to ask ARIN to supply data regarding sizes of transfers which have occurred in the past 12 - 18 months?
>>  
>> --
>> Dani Roisman
>>  
>> ________________________________
>> From: "Bill Buhler" <bill at tknow.com<mailto:bill at tknow.com <mailto:bill at tknow.com%3cmailto:bill at tknow.com>>>
>> To: "owen" <owen at delong.com<mailto:owen at delong.com <mailto:owen at delong.com%3cmailto:owen at delong.com>>>
>> Cc: arin-ppml at arin.net<mailto:arin-ppml at arin.net <mailto:arin-ppml at arin.net%3cmailto:arin-ppml at arin.net>>
>> Sent: Monday, September 28, 2015 12:59:30 PM
>> Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks
>>  
>> OK, how about this:
>>  
>> Small end users and ISPs are allowed to obtain IPv4 address blocks without a needs test as long as the following criteria are met:
>>  
>>  
>> a.       The total size of their ARIN allocations at any time of the process does not exceed a /20 if a ISP or /22 for an end user.
>>  
>> b.      They cannot purchase IP address from the transfer market more than three total times to reach this size, including the initial operation.
>>  
>> c.       None of the addresses purchased can be transferred to any other entity for twenty-four months following the date of the last transfer.
>>  
>> d.      If the company ceases operations within the twenty-four month window the addresses are automatically transferred to the ARIN free pool. After that period of time regular transfer rights exist.
>>  
>> e.      All subsequent allocations / transfers require regular needs testing after the initial twenty-four month allocation window.
>>  
>> f.        Eligible entities for this policy consist of ISPs and End users who have a unique physical address in the ARIN region at the suite level. Meaning if two companies share the same suite they are not eligible to both have ARIN allocations.
>>  
>> -------------------
>>  
>> I believe that meets all of your concerns. I would prefer companies get everything they think they will need in one operation, but I don?t want to have fear drive them into buying the max amount just in case.
>>  
>> Best regards,
>>  
>> Bill Buhler
>>  
>> _______________________________________________
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> -- 
> _______________________________________________________
> Jason Schiller|NetOps|jschiller at google.com <mailto:jschiller at google.com>|571-266-0006
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