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

[Bill Buhler]

Dani,

Do you have a particular reason to want to dive into the stats? I looked at them but see no way to easily separate the requests between those that would qualify for this (those that have a no or a very small IP allocation), and those of larger entities. I did run out the transfers and found the following:

Size

Transfers

% Overall

% <=

/10

1

0.72%

100%

/11

3

2.17%

99.28%

/12

5

3.62%

97.10%

/13

2

1.45%

93.48%

/14

7

5.07%

92.03%

/15

7

5.07%

86.96%

/16

15

10.87%

81.88%

/17

6

4.35%

71.01%

/18

8

5.80%

66.67%

/19

11

7.97%

60.87%

/20

16

11.59%

52.90%

/21

9

6.52%

41.30%

/22

14

10.14%

34.78%

/23

12

8.70%

24.64%

/24

21

15.22%

15.94%

/25

1

0.72%

0.72%


Average block size: 19.20
Median block size: 20
Standard Deviation: 3.792

So we can see that /24 is the most popular allocation size, and ~ 50% of all transfer activity is for a /20 or smaller block. What I can't see without a lot of WHOIS work, is what the size of the entities are that transferred the smaller blocks. I suspect even if they had been subject to this policy change a large majority would still fall under the needs test provisions.

Best regards,

Bill Buhler

From: Dani Roisman [mailto:droisman at softlayer.com]
Sent: Wednesday, September 30, 2015 10:40 AM
To: Bill Buhler; arin-ppml at arin.net
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

That's just billing buckets then, not really based on actual transfer activity.  Maybe it will help to look at more relevant data?

ARIN staff watching - could you point me to any published statistics for transfers over the past 18 months, or if not could you generate them and share?  I'm thinking this is a good start:


1)      Number of transfers requests for each block size for 8.3 and 8.4 transfers which completed.  e.g. "/20 = qty 15, /19 = qty 5, /18 = qty 10"

2)      Number of transfers requests for each block size for 8.3 and 8.4 transfers which were closed without completion, specifically where need was not met

I'm only asking for 8.3 and 8.4 because 8.2 doesn't have the same type of needs demonstration burden (only as usage demonstration).

Thanks.

----
Dani Roisman

From: Bill Buhler [mailto:bill at tknow.com]
Sent: Wednesday, September 30, 2015 09:35
To: Dani Roisman <droisman at softlayer.com<mailto:droisman at softlayer.com>>; arin-ppml at arin.net<mailto:arin-ppml at arin.net>
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

Based on the ARIN fee table of ISP classification:

/20 is the max allocation size of a X-Small ISP

/22 is the max allocation size of a XX-Small End User.

So there is a slight bias towards small ISPs, but they are in less of a position to leverage NAT.

Thanks,

Bill Buhler

From: Dani Roisman [mailto:droisman at softlayer.com]
Sent: Wednesday, September 30, 2015 4:52 AM
To: arin-ppml at arin.net<mailto:arin-ppml at arin.net>; Bill Buhler
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


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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