However, since we’re talking about making changes here anyway (2017-9 is 
proposing changes), I would still
argue that the more logical change to make if we care about harmonization is to 
change section 8 rather than section 4. If we don’t care about harmonization, 
then let’s not change either one.

Owen

> On Jan 18, 2018, at 4:07 PM, Scott Leibrand <[email protected]> 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
> 
> On Jan 19, 2018, at 12:35 AM, David Farmer <[email protected] 
> <mailto:[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] 
>> <mailto:[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] 
>>> <mailto:[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:
>>>>> http://lists.arin.net/mailman/listinfo/arin-ppml 
>>>>> <http://lists.arin.net/mailman/listinfo/arin-ppml>
>>>>> 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 
>>> <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 <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:
>> http://lists.arin.net/mailman/listinfo/arin-ppml 
>> <http://lists.arin.net/mailman/listinfo/arin-ppml>
>> Please contact [email protected] <mailto:[email protected]> if you experience any 
>> issues.

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