Inline:

> On Aug 26, 2021, at 10:46 AM, Mike Burns <[email protected]> wrote:
> 
> Hi,
> 
> I think the larger block should be allowed to be sold in pieces, 
> notwithstanding the disaggregation.

The intent of this policy is to allow organizations to avoid deaggregation, and 
contributing to global BGP table bloat, by transferring a smaller block in, 
then a larger block out in one piece. If the policy allows selling the larger 
block in pieces, that’s really no different than if they simply renumbered into 
a smaller portion of it and sold off the rest, making this policy language more 
or less pointless IMO.

> 
> I think the recipient should lose the ability to receive addresses 
> immediately upon receipt of the smaller block, until the larger block is 
> completely sold. Including waitlist addresses, not included other reserved 
> addresses.

After my last email, I did think of a corner case this might bite an 
otherwise-trying-to-do-the-right-thing operator: they transfer in, say, a /24, 
but grow faster than expected and need a second /24 (or larger block) before 
they can get rid of the block they’re seeking to transfer. As such, I rescind 
my earlier mention of this as a potential change I’d support.

> 
> If the smaller block is a /24, there should be no needs test.

Agreed, but I think this is already covered in other language? Does it need to 
be repeated here if so?

> I would lose the officer attestation.

My assumption is that this needs to be in place currently, as it is with other 
sections regarding needs-based requests; once the consultation is done, if the 
result of that process is to remove, I expect an omnibus proposal to be 
authored removing the language wherever it exists.

Thanks,

-C

> 
> Regards,
> Mike 
> 
> 
> 
> 
> -----Original Message-----
> From: ARIN-PPML <[email protected]> On Behalf Of Chris Woodfield
> Sent: Thursday, August 26, 2021 1:09 PM
> To: ARIN-PPML List <[email protected]>
> Subject: Re: [arin-ppml] Updated text: ARIN 2020-6 Swap Policy
> 
> This new language has my support, with a few comments:
> 
> - If I’m reading this properly, the prohibition on transferring the smaller 
> block kicks in if the larger block isn’t transferred within a year. Have we 
> considered the option of having that restriction kick in immediately until 
> the larger block is transferred? Or was that considered too onerous?
> 
> - I’ve noticed that officer attestation language is present in the new 
> 8.5.5.1.1 subsection; I’m assuming this will remain in place despite the 
> separate discussion on removing the need for officer attestations, and 
> removed via a future policy proposal if that action is taken. Please advise 
> if that assumption is incorrect.
> 
> Thanks,
> 
> -C
> 
>> On Aug 26, 2021, at 6:54 AM, Rob Seastrom <[email protected]> wrote:
>> 
>> 
>> Dear ARIN Community,
>> 
>> Please read the updated text for policy proposal ARIN 2020-6 Swap Policy 
>> (below) and offer your thoughts and comments.
>> 
>> All the best,
>> 
>> -r
>> 
>> -=-=-=-=-
>> 
>> ARIN 2020-6 Swap Policy
>> 
>> Current text:
>> 
>> 8.5.5. Block Size
>> Organizations may qualify for the transfer of a larger initial block, or an 
>> additional block, by providing documentation to ARIN which details the use 
>> of at least 50% of the requested IPv4 block size within 24 months. An 
>> officer of the organization shall attest to the documentation provided to 
>> ARIN.
>> 
>> 
>> Add:
>> 
>> 8.5.5.1- Transfer for the Purpose of Renumbering Organizations with 
>> larger direct allocations or assignments than they require may receive 
>> transfer of a smaller block for the purpose of renumbering onto the smaller 
>> block if they transfer the entire larger block to a qualified recipient 
>> under section 8 within one year of receipt of transfer of the smaller block. 
>> If the larger block is not transferred within one year of receipt of the 
>> smaller block, the smaller block will be ineligible for transfer under 
>> sections 8.3 and 8.4, and the organization will be ineligible to receive any 
>> further transfers under this policy.
>> 
>>      8.5.5.1.1 Smaller Block Size
>>      Organizations may qualify to receive transfer of a smaller block by 
>> providing documentation to ARIN which details the use of at least 50% 
>> of the smaller block size within 24 months. Current use of the larger 
>> block may be used to satisfy this criteria. An officer of the 
>> organization shall attest to the documentation provided to ARIN
>> 
>> Current text:
>> 8.5.6. Efficient Utilization of Previous Blocks Organizations with 
>> direct assignments or allocations from ARIN must have efficiently utilized 
>> at least 50% of their cumulative IPv4 address blocks in order to receive 
>> additional space. This includes all space reassigned to their customers.
>> 
>> Add:
>> 
>> 8.5.6.1 Transfer for the Purpose of Renumbering Organizations 
>> receiving transfer of a smaller block under section 8.5.5.1 may deduct the 
>> larger block they are transferring to a qualified recipient when calculating 
>> their efficient utilization of previous blocks under section 8.5.6.
>> 
>> Current Text:
>> Sections 8.3 and 8.4, under “Conditions on Source Of the Transfer”:  
>> “The source entity must not have received a transfer, allocation, or 
>> assignment of IPv4 number resources from ARIN for the 12 months prior to the 
>> approval of a transfer request. This restriction does not include 8.2 
>> transfers.
>> 
>> Add:
>> This requirement may be waived by ARIN for transfers made in connection with 
>> a renumbering exercise designed to more efficiently utilize number resources 
>> under section 8.5.5.1.
>> 
>> 
>> 
>> 
>> _______________________________________________
>> ARIN-PPML
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> 
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