You have always been able to get space from ARIN based on forward-looking 
business cases, but it has been limited.

This applies to both free pool and transfers equally, though free pool being 
limited to a 3-month window now for ISPs makes “forward” a little less useful.

I would venture that most end-user initial allocations are based on at least 
somewhat forward-looking projections.

Owen

On Sep 23, 2014, at 11:13 AM, Martin Hannigan <[email protected]> wrote:

> 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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> _______________________________________________
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