ARIN is not qualified to limit Internet competition based on b-case review. 

I'd be interested to hear how they would accomplish this. 

Best, 

-M<



> On Sep 23, 2014, at 20:01, Jason Schiller <[email protected]> wrote:
> 
> Hello PPML,
> 
> I wanted to start a new thread on the topic of ARIN's current procedure of 
> assessing 24 month need for transfers based on a future looking business plan 
> that is not supported by half as much utilization over the previous year.
> 
> Personally I was surprised when we were discussing 2014-20 that objections 
> arose from the removal of the current practice of permitting ARIN to base a 
> justification on a future looking business plan.
> 
> My understanding is that the original 2008-6 required the transfer to be "in 
> the exact amount which can be justified under ARIN resource-allocation 
> policies."  Meaning you can only transfer as much address space as you could 
> otherwise qualify for from ARIN.  
> 
> This was modified in 2011-11 when we moved the ARIN requests for ISPs to a 3 
> month time horizon, we pushed out the transfer time horizon to one year.  The 
> net result being to bring in the time horizon of ARIN allocations without 
> impacting the time horizon of transfers.  (this also suggests that the amount 
> of space an organization qualifies for under transfers was previously tied to 
> how much space they qualify for under section 4)  There was no modification 
> in how need is measured.
> 
> Then 2011-12 was a simple change to push out transfers from a 1 year time 
> horizon to a two year time horizon.  
> 
> Then 2011-1 split out inter-ARIN transfers from intra-ARIn transfers, but did 
> not change the workings of intra-ARIN transfers.
> 
> 2012-1 broke down the policies into bullets.  There was some early discussion 
> about removing utilization as a measure of policy compliance, but that was 
> too controversial and dropped.  
> 
> It was my understanding that when discussed and adopted 2008-6 that transfers 
> were only to be permitted "in the exact amount which can be justified under 
> ARIN resource-allocation policies."
> 
> 2012-3 was a simple change to "number resources".
> 
> So where did this idea that you could qualify differently for transfer space 
> than ARIN space other than simply being permitted a larger time horizon?
> 
> Are others in the community equally surprised by the ability to get space on 
> a future looking business case?  
> 
> Supporting data below.
> 
> __Jason
> 
> Tthe original 2008-6 required the transfer to be "in the exact amount which 
> can be justified under ARIN resource-allocation policies."  Meaning you can 
> only transfer as much address space as you could otherwise qualify for from 
> ARIN.  
> 
> I took this to mean that you could only qualify for a certain amount of space 
> on the transfer market if you would otherwise qualify to get that same space 
> from ARIN (if they had it to offer).
> 
> Bill Darte, as originator of 2008-6 is that what was intended?
> 
> "It's intent is to preserve the current tradition of needs-based allocation 
> and assignment because that's what we've heard clearly out of discussion up 
> to this point in time in this community. ... The policy says need in 
> accordance with current and applicable ARIN policy."
> 
> ---
> 
> This was further modified in 2011-11 where we reduce ARIN 
> allocations/assignments to 3 months, and moved the 1 year restriction from 
> the ARIN allocation/assignment section 4 to the transfer section.  This 
> yields the more familiar text:
> 
> "...they can justify under current ARIN policies showing how the addresses 
> will be utilized within 12 months."
> 
> At the time there was some controversy for how need should be determined for 
> transfers, but that portion of the policy was dropped.
> 
> "not clear how "justified need" has been or should be determined, however 
> this proposal no longer addresses this."
> 
> My read is 2011-11 leave the previous needs test in place.
> 
> ---
> 
> This was immediately further modified by 2011-12 which simply extended the 
> time from 12 to 24 months.
> 
> It was modified by 2011-1 which removed and added ARIN specific language to 
> separate intra-ARIN transfers, but did not change the intra-ARIN policy 
> otherwise.
> 
> ---
> 
> 2012-1 broke the requirements down into bullets and added additional 
> requirements that the organization providing the space for transfer is 
> ineligible for additional space from ARIN for 12 months, and could not have 
> received ARIN space 12 months prior to the transfer.  It also established a 
> minimum of a /24.
> 
> The text changed from:
> 
> "Such transferred number resources may only be received uder RSA by 
> organizations that are within the ARIN region and can demonstrate the need 
> for such resources in the amount which they can justify under current ARIN 
> policies showing how the addresses will be utilized within 24 months"
> 
> to:
> "Conditions on recipient of the transfer:
> * The recipient must demonstrate the need for up to a 24 month supply of
> IP address resources under current ARIN policies and sign an RSA.
> * The resources transferred will be subject to current ARIN policies."
> 
> While the word "justify" is gone I believe the intent is still intact.  There 
> is some discussion in the rational that
> "The one key point that has been removed from the original text is that a 
> needs based
> review remains in place."
> 
> This refers to the original prop that added a clause to remove needs based 
> reviews, which is not part of the adopted draft.
> this text that was dropped is:
> "and add to the NRPM Section 12:
> 10. ARIN will not use utilization as a measure of policy compliance
> for addresses transferred under 8.3."
> 
> this was then further modified by 2012-3 but that just changed IP addresses 
> to number resources...
> 
> 
> 
> 
> -- 
> _______________________________________________________
> Jason Schiller|NetOps|[email protected]|571-266-0006
> 
> _______________________________________________
> PPML
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