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

Jason Schiller jschiller at google.com
Wed Jan 24 13:06:12 EST 2018

ARIN staff,

After the implementation of 2009-8
and post  IANA IPv4 depletion
(say 02/03/2011)

If an ISP wanted more than a 90 day supply would
that have been limited to only a 90 day supply?
Is that because of both: Subscriber Members Less Than One Year Subscriber Members After One Year ?

Does that also apply to an ISP asking for IP space Immediate Need?

Does that also apply to an ISP asking for IP space Slow start?

Does this also apply to ISP asking for IP space
under 4.2.2. Initial allocation to ISPs?

After the implementation of 2013-7
(say September 2014)

Did any of this change?

Did Request size simply
replace and and
do essentially the same limit?

After the implementation of 2016-4
(say March 2017)

Did any of this change?
Is that because of Request size
still limits the maximum an ISP can get?

Then after 2016-2
(say April 20, 2017)

Would all of the above change to a 2 year supply?


responses in line


On Wed, Jan 24, 2018 at 10:38 AM, Owen DeLong <owen at delong.com> wrote:

> While there’s some truth to that, it was also the reality under which we
> operated when that /21 was coming from the free pool rather than from the
> transfer market.
> Admittedly, the price penalty was a bit higher because that was under an
> older fee structure which had higher prices for ISPs, but, as the old
> Churchill joke ends… “Madam, the first question established what you are,
> now we are merely haggling over price.”
> So, given that, do you really believe we need to place additional limits
> on transfers that didn’t exist on the free pool?

I don't believe this limit is new or additional...
My understanding of the policy that existed between 09/18/2012 and
was that an ISP could only get a 3 month supply of addresses.

This was established under 2009-8 (01/13/2010 and triggered 02/03/2011)
and modified by 2016-2 (04/20/2017)


Post 04/20/2017, and ISP can only get a 2 year supply.

I believe you need to show that the initial /21 you are asking for is a
90 day supply or less during the 09/2010-04/2012 time period, which
subsequently reverted to a two year window.

Hopefully staff questions above will clarify this.

At the very least it was never my expectation that passing 2016-4
would exclude the initial /21 from needing to meet the requirement
of Three Months.

> Also, even with the /24 limit, under current policy, they can immediately
> turn around, claim they’ve used that /24 and with officer attestation get
> an additional /23, then turn around again and get an additional /22 which
> would leave them only 1 /24 short of a /21 (which they could turn around
> and immediately obtain unto an additional /21 under the same policy). So we
> essentially already allow this transaction, but the question is how many
> hoops do we want to add to the process.
Assuming there is no fraud in the transaction you describe, then
they would essentially be doing slow start.
Get a block press it into service, show it is being used, and double.

That is exactly how it is supposed to work.
That is exactly what we did under slow start with no history of use:
1. get a /24 (or more up to a /21 from an upstream) show it is being used,
2. trade it out for ARIN space that replaces, and doubles the size
3. re number into the new space
4. press the unused new space into service
5. double you previous allocation if you do it in less than half the 90 day
6. get the same size as your previous allocation if you do it in less that
90 days
7. fall back to a smaller next allocation if you do it in more than 90 days.

The transfer version is more liberal in that it allows a straight doubling
of all
your holdings as opposed to only your last allocation doubling, and there is
no time horizon, you can double even if it take you 3 years to press your
address space into service.

So, less silly than slow start with a 1 year window, and much less silly
slow start with a 3 month window.

> I’m usually the one on the other side of this argument, but under the
> current circumstances, even I think it’s kind of silly.
What am I missing?  What is so silly with this approach?

> Owen
> On Jan 24, 2018, at 7:17 AM, Jason Schiller <jschiller at google.com> wrote:
> I oppose.
> 2016-4 was an attempt to replace the slow-start boot strap of get a /24
> (or more)
> from your upstream, put it into use, then use that to qualify to get your
> own IP space from ARIN.
> The transfer slow-start boot strapping is to give the first /24 with no
> justification,
> put it to use, then double (just as you did under slow start).
> Essentially changing this to a /21 allows roughly 80% of ARIN members
> to be able to get all the IPv4 address space they could even need with
> no justification if they are willing to call themselves an ISP, and pay
> the
> appropriate fees.
> I oppose a non-needs based (or simply put a money based) justification
> system on the grounds that does not provide IP addresses to those who need
> them, but rather to those who are more willing to spend, favoring services
> that
> generate the most revenue per IP.
> I even more strongly oppose a non-needs based justification that only
> benifits
> some small portion of the community.  This proposal is essentially a
> non-needs
> based justification for anyone who needs a /21 or less and is willing to
> pay an
> extra $400 annually for up to a /22 or, and extra $900 annually for up to
> a /21.
> Under NRPM version 2016.2 - 13 July 2016
> https://www.arin.net/vault/policy/archive/nrpm_20160713.pdf
> For an ISP request for ARIN IP space, required them to
> show utilization of currently held IPv4 space.
> 1. They could use the utilization of their provider's /24 along with
> the promise of renumbering to justify getting their own /24
> An ISP could meet the demonstration of utilization and
> get additional space by showing the 3 month growth projection under
> (replacing their provider supplied addressing can be
> included in the ask if they promose to return under
> Or doubling under slow start
> 2016-4 came along to remove the need to get IPs from your upstream.
> https://www.arin.net/policy/proposals/2016_4.html
> Replace Section 4.2.2 with:
> 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 for specified transfers, or three months otherwise.
> 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."
> At that time the difference between ARIN IP space was a 90 day supply
> versus a two tear supply on the transfer market.
> It also seemingly removed the following sections:
> ISP Requirements
> Use of /24
> Efficient Utilization
> Three Months
> Renumber and Return
> It was my impression that ARIN would not issue a /21 if it was more than a
> 90 day
> supply.
> 2016-2 came along and changes the time frame to sync pre-approval for
> transfers
> and approval for the waiting list.
> It seeming updates the non-existant section from 3 months to 24.
> and to 24 months.
> This is what creates the problem where now an initial ISP can request a /21
> without requiring
> I do not believe the intent was to give ISPs a /21 even if it is larger
> than a, then
> 90 day, or now two year supply.  I suggest that if more than a /24 is
> desired, they can get up
> to a /21 if it is less than a 2 year supply, and subsequently need to show
> utilization.
> That means a /21 is not entirely justification free like the /24 is.
> __Jason
> On Mon, Jan 22, 2018 at 6:35 PM, Owen DeLong <owen at delong.com> wrote:
>> Fully support the direction you are now taking this.
>> Owen
>> On Jan 20, 2018, at 9:16 AM, David Farmer <farmer at umn.edu> wrote:
>> I think the burden is the potential to have to rejustify an ISP's initial
>> allocation when being fulfilled by transfer.  The
>> inconsistency seems inefficient and creates confusion; there appears to
>> be support for eliminating the inconsistency.  With slightly more support
>> for changing section 8 to be consistent with section 4, rather than the
>> other way around.
>> On Thu, Jan 18, 2018 at 6:07 PM, Scott Leibrand <scottleibrand at gmail.com>
>> wrote:
>>> Quoting myself:
>>> 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.
>>> Do you know of any organizations transferring blocks larger than a /24
>>> for whom officer-attested justification is burdensome (to them or to ARIN)?
>>> Scott
>> --
>> ===============================================
>> 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>
>> ===============================================
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> --
> _______________________________________________________
> Jason Schiller|NetOps|jschiller at google.com|571-266-0006 <(571)%20266-0006>

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