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

> On Jan 19, 2018, at 12:35 AM, David Farmer <[email protected]> wrote:
> 
> Owen, I think you are justified in taking an "I told you so!"
> 
> But, here are the two options as I see them to harmonize things;
> 
> 1. Change 4.2.2 to /24
> 
> 2. Change 8.5.3 to /21
> 
> I think Owen is saying #2, and the best I could glean from the previous 
> comments most we leaning toward #1.  
> 
> So, which way do people think we should go, #1 or #2?
> 
> Thanks.
> 
>> On Thu, Jan 18, 2018 at 5:17 PM, Owen DeLong <[email protected]> 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 <[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]> 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]> 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]> 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]> 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]> 
>>>>>>>> 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]> 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]
>>>>>>> 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
>>>>>>> ===============================================
>>>>>>> _______________________________________________
>>>>>>> PPML
>>>>>>> You are receiving this message because you are subscribed to
>>>>>>> the ARIN Public Policy Mailing List ([email protected]).
>>>>>>> Unsubscribe or manage your mailing list subscription at:
>>>>>>> http://lists.arin.net/mailman/listinfo/arin-ppml
>>>>>>> Please contact [email protected] if you experience any issues.
>>>>>> 
>>>>> 
>>>>> 
>>>>> 
>>>>> -- 
>>>>> ===============================================
>>>>> David Farmer               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
>>>>> ===============================================
>>>> 
>>> 
>>> 
>>> 
>>> -- 
>>> ===============================================
>>> David Farmer               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
>>> ===============================================
>> 
> 
> 
> 
> -- 
> ===============================================
> David Farmer               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
> ===============================================
> _______________________________________________
> PPML
> You are receiving this message because you are subscribed to
> the ARIN Public Policy Mailing List ([email protected]).
> Unsubscribe or manage your mailing list subscription at:
> http://lists.arin.net/mailman/listinfo/arin-ppml
> Please contact [email protected] if you experience any issues.
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