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

Jason Schiller jschiller at google.com
Fri Jan 19 12:11:32 EST 2018


Can you clarify the problem (I'm confused).

What I expect to happen and an ISP under 4.2.2 can get an initial
allocation of between a /24 and a /21 inclusive.
They will be slow started because they have no history.  They can get a 2
year supply, and will need to make it
80% utilized before they can come back for more..

Utilized means:

- If an IP block is allocated/assigned to a customer and one of the
following is true:
   - the customer can show justification for 25% utilization in 30 days 50%
in 1 year
   - the customer can show a discreet multi-homing requirement each /24
   - the residential market area IP block is at least 50% utilized
   - the residential market area is TPIA and
       - initial assignments to each piece of hardware is the smallest
possible
       - additional assignments to each piece of hardware only made after
80% utilization
       - additional assignments to each piece of hardware is not more than
a 2 year supply

Then that space is considered 100% utilized

IP space in use by the ISP is counted as utilized.
This includes network and broadcast addresses for subsets in use.


Under 8.5.4
They can transfer pre-approval for a /24 no questions asked if they have no
direct IPv4.

If they have a direct IPv4, or want pre-approval for more than a /24 then
they
need to show how they will use 50% of the requested space in 24 months.



What is weird is post last /8, ISP could only get a 90 day supply on slow
start and then
had to come back.  So request for ARIN space were 1/8 the size (90 days)
of what could
be request on the transfer market (2 years).  We adjusted this back to a
two year supply to
mirror the transfer window of time and simplify things (which I opposed at
the time,
but now that it is changed standby it).

___Jason






On Thu, Jan 18, 2018 at 7:33 PM, Owen DeLong <owen at delong.com> wrote:

> We could also simplify section 8 to state that the minimum transfer size
> is /24 and that initial requests for transfer are governed by officer
> attestation limits unless a larger size is needed.
>
> Owen
>
> On Jan 18, 2018, at 4:32 PM, David Farmer <farmer at umn.edu> wrote:
>
>
> Looking at this a little more closely;
>
> Section 8.5.4 has a common size for both initial allocations and
> assignments or in other words an initial transfer size of /24.
>
> Whereas in section 4 the initial allocations and assignments sizes differ;
> with section 4.2.2 having an initial ISP allocation size of /21 and section
> 4.3.2 having an initial end-user assignment size of /24.
>
> So, I believe the easiest way to harmonize section 4 and 8 is to harmonize
> section 4.2.2 with section 4.3.2 at /24.
>
> Otherwise, we need to make section 8 more complicated and distinguishing
> between initial allocations and assignments sizes.
>
> So which way should we go?
>
> Thanks.
>
> On Thu, Jan 18, 2018 at 5:17 PM, Owen DeLong <owen at delong.com> wrote:
>
>> Well, section 4 doesn’t govern transfers since we decoupled it anyway, so
>> I’m not sure if we want to make staff behavior consistent or not. I would
>> argue that moving the transfer boundary to /21 would make more sense than
>> moving the section 4 boundary to /24, if we are going to synchronize them.
>>
>> However, as you point out, transfers are governed by 8.5.5 and only free
>> pool is governed by section 4 unless section 4 is referenced by section 8.
>>
>> As you may recall, I opposed this decoupling because of the confusion and
>> disparity in protocol I expected to result. Now we’re exactly where I
>> predicted we’d be.
>>
>> Owen
>>
>> On Jan 18, 2018, at 3:03 PM, David Farmer <farmer at umn.edu> wrote:
>>
>> From the updated problem statement: If an organization applies under
>> section 8 first they are initially qualified for a /24, larger allocations
>> require additional documentation as noted in 8.5.5.
>>
>> Again, whether a change in policy or staff practice, what do we want to
>> happen?
>>
>> On Thu, Jan 18, 2018 at 4:38 PM, Owen DeLong <owen at delong.com> wrote:
>>
>>> The existing language “up to a /21” is consistent with staff allowing
>>> you to obtain a /24 via transfer.
>>>
>>> Are you telling me that staff is refusing /21 transfers, but allowing
>>> /24 transfers to new ISPs without further justification? If so, I would
>>> argue that current staff practice is in error vs. policy language.
>>>
>>> Owen
>>>
>>> On Jan 18, 2018, at 2:37 PM, David Farmer <farmer at umn.edu> wrote:
>>>
>>> Owen,
>>>
>>> Yep, that was an editing error, it should have been;
>>>
>>> 4.2.2. Initial allocation to ISPs
>>>
>>> All ISP organizations without direct assignments or allocations from
>>> ARIN qualify for an initial allocation of a /24. Organizations may qualify
>>> for a larger initial allocation by documenting how the requested allocation
>>> will be utilized within 24 months.
>>>
>>> On Thu, Jan 18, 2018 at 4:26 PM, Owen DeLong <owen at delong.com> wrote:
>>>
>>>> I see no reason to move the boundary for an ISP initial allocation from
>>>> /21 to /24.
>>>>
>>>
>>> Well that seems to be staff intrupretation if you are getting an initial
>>> allocation via a transfer, how would you reslove this then?
>>>
>>> Thanks.
>>>
>>>
>>>> I certainly see no reason for “up to a /24” as there’s nothing smaller
>>>> available and even if it were, it wouldn’t be useful in any foreseeable
>>>> environment.
>>>>
>>>> Owen
>>>>
>>>> On Jan 18, 2018, at 2:21 PM, David Farmer <farmer at umn.edu> wrote:
>>>>
>>>> David,
>>>>
>>>> The resolution you suggest below seems like a different policy proposal
>>>> to me, one with a significantly broader scope than this draft policy has.
>>>> But I think it is a valid question for the community to consider, it's just
>>>> not really the problem statement in question for this Draft Policy.
>>>>
>>>> So, back within the scope of this Draft Policy as the shepherd, I plan
>>>> to push forward Andrew's updated Problem Statement with a Policy Statement
>>>> that harmonizes and simplifies the text in section 4.2.2 as an official
>>>> update to this Draft Policy to get the conversation moving again.
>>>>
>>>> The current text of 4.2.2 is;
>>>>
>>>> 4.2.2. Initial allocation to ISPs
>>>>
>>>> All ISP organizations without direct assignments or allocations from
>>>> ARIN qualify for an initial allocation of up to a /21, subject to ARIN's
>>>> minimum allocation size. Organizations may qualify for a larger initial
>>>> allocation by documenting how the requested allocation will be utilized
>>>> within 24 months. ISPs renumbering out of their previous address space will
>>>> be given a reasonable amount of time to do so, and any blocks they are
>>>> returning will not count against their utilization.
>>>>
>>>> The text "subject to ARIN's minimum allocation size" seems extraneous.
>>>> And, post runout renumbering and returning any address space
>>>> seems unlikely, so let's just eliminate that whole sentence.
>>>>
>>>> I propose we simplify that to the following;
>>>>
>>>> 4.2.2. Initial allocation to ISPs
>>>>
>>>> All ISP organizations without direct assignments or allocations from
>>>> ARIN qualify for an initial allocation of up to a /24. Organizations may
>>>> qualify for a larger initial allocation by documenting how the requested
>>>> allocation will be utilized within 24 months.
>>>>
>>>> Below is the policy update that results;
>>>>
>>>> Thanks
>>>>
>>>> --------
>>>>
>>>> Draft Policy ARIN-2017-9: Clarification of Initial Block Size for IPv4
>>>> ISP Transfers
>>>>
>>>> Problem Statement:
>>>>
>>>> It was noted in 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 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
>>>> qualified ISPs an initial /21 for Section 8 transfers when they first apply
>>>> and are approved under section 4.  If an organization applies under section
>>>> 8 first they are initially qualified for a /24, larger allocations require
>>>> additional documentation as noted in 8.5.5.
>>>>
>>>> Policy Statement:
>>>>
>>>> Change section 4.2.2 as follows;
>>>>
>>>> 4.2.2. Initial allocation to ISPs
>>>>
>>>> All ISP organizations without direct assignments or allocations from
>>>> ARIN qualify for an initial allocation of up to a /24. Organizations may
>>>> qualify for a larger initial allocation by documenting how the requested
>>>> allocation will be utilized within 24 months.
>>>>
>>>> Comments:
>>>>
>>>> Timetable for implementation: Immediate
>>>>
>>>>
>>>> On Thu, Dec 7, 2017 at 11:37 PM, David Huberman <daveid at panix.com> wr
>>>> ote:
>>>>
>>>>> Thank you for the clarification.  I think the staff practice is a
>>>>> reasonable approach and I don’t think change is needed in policy for this.
>>>>>
>>>>> The updated Problem Statement reveals the real issue here - the one we
>>>>> need to figure out as a community.   What to do about all the requests each
>>>>> month for IPv4 addresses under section 4?
>>>>>
>>>>> Is it time to pass a policy to direct staff to no longer accept
>>>>> section 4 requests (except the ones they still fill like critical
>>>>> infrastructure)? I wonder what the downside of such a policy would be -
>>>>> anyone know?
>>>>>
>>>>>
>>>>>
>>>>> On Dec 7, 2017, at 11:47 PM, Andrew Dul <andrew.dul at quark.net> wrote:
>>>>>
>>>>> It was noted to me by ARIN staff, that this updated problem statement
>>>>> doesn't accurately reflect ARIN's current practice.  Below I suggest
>>>>> another updated problem statement.
>>>>>
>>>>> *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 qualified ISPs an initial /21 for Section 8 transfers when they first
>>>>> apply and are approved under section 4.  If an organization applies under
>>>>> section 8 first they are initially qualified for a /24, larger allocations
>>>>> require additional documentation as noted in 8.5.5.
>>>>>
>>>>>
>>>>
>>>>
>>>> --
>>>> ===============================================
>>>> David Farmer               Email:farmer at umn.edu
>>>> Networking & Telecommunication Services
>>>> Office of Information Technology
>>>> University of Minnesota
>>>> 2218 University Ave SE
>>>> <https://maps.google.com/?q=2218+University+Ave+SE&entry=gmail&source=g>
>>>>       Phone: 612-626-0815 <(612)%20626-0815>
>>>> Minneapolis, MN 55414-3029   Cell: 612-812-9952 <(612)%20812-9952>
>>>> ===============================================
>>>> _______________________________________________
>>>> PPML
>>>> You are receiving this message because you are subscribed to
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>>>> Please contact info at arin.net if you experience any issues.
>>>>
>>>>
>>>>
>>>
>>>
>>> --
>>> ===============================================
>>> David Farmer               Email:farmer at umn.edu
>>> Networking & Telecommunication Services
>>> Office of Information Technology
>>> University of Minnesota
>>> 2218 University Ave SE
>>> <https://maps.google.com/?q=2218+University+Ave+SE&entry=gmail&source=g>
>>>       Phone: 612-626-0815 <(612)%20626-0815>
>>> Minneapolis, MN 55414-3029   Cell: 612-812-9952 <(612)%20812-9952>
>>> ===============================================
>>>
>>>
>>>
>>
>>
>> --
>> ===============================================
>> David Farmer               Email:farmer at umn.edu
>> Networking & Telecommunication Services
>> Office of Information Technology
>> University of Minnesota
>> 2218 University Ave SE
>> <https://maps.google.com/?q=2218+University+Ave+SE&entry=gmail&source=g>
>>       Phone: 612-626-0815 <(612)%20626-0815>
>> Minneapolis, MN 55414-3029   Cell: 612-812-9952 <(612)%20812-9952>
>> ===============================================
>>
>>
>>
>
>
> --
> ===============================================
> David Farmer               Email:farmer at umn.edu
> Networking & Telecommunication Services
> Office of Information Technology
> University of Minnesota
> 2218 University Ave SE        Phone: 612-626-0815 <(612)%20626-0815>
> Minneapolis, MN 55414-3029   Cell: 612-812-9952 <(612)%20812-9952>
> ===============================================
>
>
>
> _______________________________________________
> PPML
> You are receiving this message because you are subscribed to
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>



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