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 <[email protected]> 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 <[email protected] 
> <mailto:[email protected]>> 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 <[email protected] 
>> <mailto:[email protected]>> 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 <[email protected] 
>> <mailto:[email protected]>> 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 <[email protected] 
>>> <mailto:[email protected]>> 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 <[email protected] 
>>> <mailto:[email protected]>> wrote:
>>> 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 <[email protected] 
>>> <mailto:[email protected]>> 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:[email protected] 
>>> <mailto:email%[email protected]>
>>> 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 <tel:(612)%20626-0815>
>>> Minneapolis, MN 55414-3029   Cell: 612-812-9952 <tel:(612)%20812-9952>
>>> ===============================================
>>> _______________________________________________
>>> PPML
>>> You are receiving this message because you are subscribed to
>>> the ARIN Public Policy Mailing List ([email protected] 
>>> <mailto:[email protected]>).
>>> Unsubscribe or manage your mailing list subscription at:
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>>> Please contact [email protected] <mailto:[email protected]> if you experience any 
>>> issues.
>> 
>> 
>> 
>> 
>> -- 
>> ===============================================
>> David Farmer               Email:[email protected] 
>> <mailto:email%[email protected]>
>> 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 <tel:(612)%20626-0815>
>> Minneapolis, MN 55414-3029   Cell: 612-812-9952 <tel:(612)%20812-9952>
>> ===============================================
> 
> 
> 
> 
> -- 
> ===============================================
> David Farmer               Email:[email protected] 
> <mailto:email%[email protected]>
> Networking & Telecommunication Services
> Office of Information Technology
> University of Minnesota   
> 2218 University Ave SE        Phone: 612-626-0815
> Minneapolis, MN 55414-3029   Cell: 612-812-9952
> ===============================================

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