[arin-ppml] Draft Policy ARIN-2017-9: Clarification of Initial Block Size for IPv4 ISP Transfers

Scott Leibrand scottleibrand at gmail.com
Mon Dec 4 23:49:52 EST 2017 

Section 8 as discussed on PPML and as written gives anyone the ability to transfer a /24 without justification and requires officer-attested justification for anything larger. 

If there are organizations transferring blocks larger than a /24 for whom officer-attested justification is burdensome (to them or to ARIN) I’d like to understand what is burdensome, so we can figure out how to reduce that burden. If not, then implementing section 8 as written seems appropriate until we identify a reason to change it. 

Scott

> On Dec 5, 2017, at 8:40 AM, Andrew Dul <andrew.dul at quark.net> wrote:
> 
> I would agree there is nothing special about /21, that is just where we ended up at exhaustion.  
> 
> It is possible this draft policy doesn't do what the community wants us to do.  I wrote this draft as a followup to the policy experience report to continue the conversation about the issue and to correct the inconsistency.  (Normally, I think of inconsistencies as a "bad" thing in policy)  
> 
> Perhaps what we really do want is a more strict interpretation of the new section 8 transfer policy?  If so we need a way to signal that to staff.  I'd think that could happen here on this list or at a meeting and thus no policy change is needed.  
> 
> Andrew
> 
>> On 12/4/2017 2:47 PM, David Huberman wrote:
>> Andrew,
>> 
>> It’s unclear to me that /21 is the correct boundary, especially (as Scott Leibrand asked for) absent statistics from the staff (if any such stats make sense).  With section 8 policy now wholly separated from section 4 policy, I sort of think that it’s the staff who should change their practices, and follow section 8 policy as written.  
>> 
>> Further to your problem statement, ISPs should NOT be         applying under section 4 anymore. We know, however, from staff reports at the recent ARIN meeting that they still are applying.  That’s a definite problem, but it feels to me to be a different problem than what you are tackling in this draft policy proposal. 
>> 
>> Happy to hear and be swayed by data or other arguments.
>> 
>> David 
>> 
>> Sent from my iPhone
>> 
>> On Dec 4, 2017, at 4:30 PM, Andrew Dul <andrew.dul at quark.net> wrote:
>> 
>>> Scott,  how would you feel about this proposed updated problem statement which focuses on the current issue rather than the past.
>>> 
>>> Andrew
>>> 
>>> Problem Statement: 
>>> 
>>> It was noted at the ARIN 40 Policy Experience Report, that there is an inconsistency in the initial block size for ISPs. Section 4.2.2 notes that the initial ISP block size should be /21 whereas the initial block size in 8.5.4 is noted as "minimum transfer size" which is effectively a /24. This causes ISP organizations to be approved for different initial block size depending on if they first apply apply for a transfer directly under section 8 or if they apply for a block under section 4.  This policy is intended to clarify this issue, by setting a consistent ISP initial IPv4 block size. It was noted that ARIN staff current operational practice is to allow all ISPs an initial /21 for Section 8 transfers. 
>>> 
>>> 
>>>> On 11/21/2017 9:19 PM, Scott Leibrand wrote:
>>>> I’d be ok with a /21, but there’s nothing magical about that size in a post-exhaustion world. I’d rather base a loosening on actual transfer statistics, and consider doing so for both allocations and assignments. 
>>>> 
>>>> Scott
>>>> 
>>>> On Nov 21, 2017, at 7:28 PM, Andrew Dul <andrew.dul at quark.net> wrote:
>>>> 
>>>>> It sounds like our recollections of what we intended for ISP initial allocations have diverged. I will admit when I drafted the problem statement I did not go back through email to see if there was anything about this issue.
>>>>> 
>>>>> Assuming we harmonize the problem statement, would you prefer the /24 as initial no questions asked size or a /21?
>>>>> 
>>>>> What do others prefer?
>>>>> 
>>>>> .Andrew
>>>>> 
>>>>> On Nov 21, 2017, at 2:52 PM, Scott Leibrand <scottleibrand at gmail.com> wrote:
>>>>> 
>>>>>> I believe this problem statement is incorrect, and therefore oppose the policy proposal as-is.
>>>>>> 
>>>>>> 8.5.4 was intended (by me, as one of the authors, and in PPML discussions I just pulled up) to allow ISPs to transfer a /24 without justification.  It was *not* intended to "match the previous policy" in 4.2.2.
>>>>>> 
>>>>>> 8.5.5 reads "8.5.5. Block size
>>>>>> Organizations may qualify for the transfer of a larger initial block, or an additional block, by providing documentation to ARIN which details the use of at least 50% of the requested IPv4 block size within 24 months. An officer of the organization shall attest to                           the documentation provided to ARIN."
>>>>>> 
>>>>>> The intention was that any ISP needing a /21 would need to "provide documentation to ARIN which details the use of at least 50% of the requested IPv4 block size within 24 months", with officer attestation to same.
>>>>>> 
>>>>>> If that policy is deemed insufficient, and we believe it's better to allow transfers of up to /21 without providing documentation to ARIN and officer attestation of such, then this proposal would need to be re-written with a new problem statement justifying that.
>>>>>> 
>>>>>> -Scott
>>>>>> 
>>>>>>> On Tue, Nov 21, 2017 at 2:40 PM, ARIN <info at arin.net> wrote:
>>>>>>> On 16 November 2017, the ARIN Advisory Council (AC) advanced "ARIN-prop-244: Clarification of Initial Block Size for IPv4 ISP Transfers" to Draft Policy status.
>>>>>>> 
>>>>>>> Draft Policy ARIN-2017-9 is below and can be found at:
>>>>>>> https://www.arin.net/policy/proposals/2017_9.html
>>>>>>> 
>>>>>>> You are encouraged to discuss all Draft Policies on PPML. The AC will evaluate the discussion in order to assess the conformance of this draft policy with ARIN's Principles of Internet number resource policy as stated in the Policy Development Process (PDP). Specifically, these principles are:
>>>>>>> 
>>>>>>> * Enabling Fair and Impartial Number Resource Administration
>>>>>>> * Technically Sound
>>>>>>> * Supported by the Community
>>>>>>> 
>>>>>>> The PDP can be found at:
>>>>>>> https://www.arin.net/policy/pdp.html
>>>>>>> 
>>>>>>> Draft Policies and Proposals under discussion can be found at:
>>>>>>> https://www.arin.net/policy/proposals/index.html
>>>>>>> 
>>>>>>> Regards,
>>>>>>> 
>>>>>>> Sean Hopkins
>>>>>>> Policy Analyst
>>>>>>> American Registry for Internet Numbers (ARIN)
>>>>>>> 
>>>>>>> 
>>>>>>> 
>>>>>>> Draft Policy ARIN-2017-9: Clarification of Initial Block Size for IPv4 ISP Transfers
>>>>>>> 
>>>>>>> Problem Statement:
>>>>>>> 
>>>>>>> It was noted at the ARIN 40 Policy Experience Report, that there is an inconsistency in the initial block size for ISPs. Section 4.2.2 notes that the initial ISP block size should be /21 whereas the initial block size in 8.5.4 is noted as "minimum transfer size" which is effectively a /24. The intent of the new 8.5.4 was to match the previous policy. This policy is intended to clarify this issue. It was noted that ARIN staff current operational practice is to allow ISPs an initial /21 for Section 8 transfers.
>>>>>>> 
>>>>>>> Policy statement:
>>>>>>> 
>>>>>>> Add the following to 8.5.4
>>>>>>> 
>>>>>>> ISP organizations without direct assignments or allocations from ARIN qualify for an initial allocation of up to a /21.
>>>>>>> 
>>>>>>> Comments:
>>>>>>> 
>>>>>>> a. Timetable for implementation: Immediate
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>>>>>> 
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