[arin-ppml] Draft Policy ARIN-2015-7: Simplified requirements for demonstrated need for IPv4 transfers

2015-06-23 Thread ARIN

Draft Policy ARIN-2015-7
Simplified requirements for demonstrated need for IPv4 transfers

On 18 June 2015 the ARIN Advisory Council (AC) accepted ARIN-prop-221 
Simplified requirements for demonstrated need for IPv4 transfers as a 
Draft Policy.


Draft Policy ARIN-2015-7 is below and can be found at:
https://www.arin.net/policy/proposals/2015_7.html

You are encouraged to discuss the merits and your concerns of Draft
Policy 2015-7 on the Public Policy Mailing List.

The AC will evaluate the discussion in order to assess the conformance
of this draft policy with ARIN's Principles of Internet Number Resource
Policy as stated in the PDP. Specifically, these principles are:

  * Enabling Fair and Impartial Number Resource Administration
  * Technically Sound
  * Supported by the Community

The ARIN Policy Development Process (PDP) can be found at:
https://www.arin.net/policy/pdp.html

Draft Policies and Proposals under discussion can be found at:
https://www.arin.net/policy/proposals/index.html

Regards,

Communications and Member Services
American Registry for Internet Numbers (ARIN)


## * ##


Draft Policy ARIN-2015-7
Simplified requirements for demonstrated need for IPv4 transfers

Date: 23 June 2015

Problem statement:

ARIN transfer policy currently inherits all its demonstrated need 
requirements for IPv4 transfers from NRPM sections 4. Because that 
section was written primarily to deal with free pool allocations, it is 
much more complicated than is really necessary for transfers. In 
practice, ARIN staff applies much more lenient needs assessment to 
section 8 IPv4 transfer requests than to free pool requests, as 24-month 
needs are much more difficult to assess to the same level of detail.


This proposal seeks to dramatically simplify the needs assessment 
process for 8.3 transfers, while still allowing organizations with 
corner-case requirements to apply under existing policy if necessary.


Policy statement:

8.1.x Simplified requirements for demonstrated need for IPv4 transfers

IPv4 transfer recipients must demonstrate (and an officer of the 
requesting organization must attest) that they will use at least 50% of 
their aggregate IPv4 addresses (including the requested resources) on an 
operational network within 24 months.


Organizations that do not meet the simplified criteria above may instead 
demonstrate the need for number resources using the criteria in section 
4 of the NRPM.


Comments:

a. Timetable for implementation: Immediate

b. Anything else
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Re: [arin-ppml] Draft Policy ARIN-2015-7: Simplified requirements for demonstrated need for IPv4 transfers

2015-06-23 Thread Michael Peddemors

Opposed.

On 15-06-23 05:39 PM, Owen DeLong wrote:

I am opposed to this proposal.

It is yet another attempt to chip away at needs basis by those seeking
to provide for unlimited and unrestricted transfers.

The community has repeatedly indicated that the preservation of needs
basis is important and virtually every proposal
seeking to eliminate it has been rebuffed by the community.

This proposal should, IMHO, be recognized for what it is… A clear effort
to reduce the needs-basis requirements for transfers.

Owen


On Jun 23, 2015, at 17:31 , Scott Leibrand scottleibr...@gmail.com
mailto:scottleibr...@gmail.com wrote:

On Tue, Jun 23, 2015 at 5:20 PM, Matthew Kaufman matt...@matthew.at
mailto:matt...@matthew.at wrote:

On 6/23/2015 1:06 PM, ARIN wrote:

Draft Policy ARIN-2015-7
Simplified requirements for demonstrated need for IPv4 transfers


I support this policy, but would be even happier if we simply had
a trigger that said when ARIN is out of IPv4 addresses, this
simplified policy replaces all other tests for IPv4 transfers and
the other sections are inactive until such time as ARIN has a new
large free pool of IPv4 addresses (never)


The main reason we didn't write a replacement for section 4 is this:

Organizations that do not meet the simplified criteria above may
instead demonstrate the need for number resources using the
criteria in section 4 of the NRPM.


There will likely be some sections of the community who feel that
their particular need for IPv4 is better met under section 4 than
under this simplified policy.  Rather than trying to identify every
such need and write in exceptions, I felt it would be better to first
allow everyone using the transfer market to opt out of section 4
entirely, and then once we have some experience with which requests
actually still end up using section 4, we will have some data on which
parts of it we need to keep and which can be eliminated in a
simplification cleanup proposal.

-Scott

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Re: [arin-ppml] Draft Policy ARIN-2015-7: Simplified requirements for demonstrated need for IPv4 transfers

2015-06-23 Thread William Herrin
On Tue, Jun 23, 2015 at 6:59 PM, Scott Leibrand scottleibr...@gmail.com wrote:
 On Tue, Jun 23, 2015 at 3:48 PM, William Herrin b...@herrin.us wrote:
  IPv4 transfer recipients must demonstrate (and an officer of the
  requesting
  organization must attest) that they will use at least 50% of their
  aggregate
  IPv4 addresses (including the requested resources) on an operational
  network
  within 24 months.

 I'm inclined to support changing the 8.3 recipient conditions
 consistent with this idea but it's not clear to me how this text would
 fit with what's already there.


 Currently, both 8.3 and 8.4 reference current ARIN policies for
 demonstrating need (The recipient must demonstrate the need for up to a
 24-month supply of IP address resources under current ARIN policies).  This
 new section 8.1.x would add a new type of policy that would allow
 organizations requesting simple 8.3 or 8.4 IPv4 transfers to bypass all the
 complexity and detailed utilization reporting requirements of NRPM section
 4.

Ah. In that case, I'm opposed to the policy as written.

As a practical matter, the text does not sensibly fit where indicated.
If placed there, it would make the surrounding policies harder, not
easier, to understand.

As a policy matter, I'm virulently opposed to using said criteria for
out-region 8.4 transfers.

Regards,
Bill Herrin


-- 
William Herrin  her...@dirtside.com  b...@herrin.us
Owner, Dirtside Systems . Web: http://www.dirtside.com/
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Re: [arin-ppml] Draft Policy ARIN-2015-7: Simplified requirements for demonstrated need for IPv4 transfers

2015-06-23 Thread Matthew Kaufman

On 6/23/2015 1:06 PM, ARIN wrote:

Draft Policy ARIN-2015-7
Simplified requirements for demonstrated need for IPv4 transfers


I support this policy, but would be even happier if we simply had a 
trigger that said when ARIN is out of IPv4 addresses, this simplified 
policy replaces all other tests for IPv4 transfers and the other 
sections are inactive until such time as ARIN has a new large free pool 
of IPv4 addresses (never)


Matthew Kaufman
matt...@matthew.at
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Re: [arin-ppml] Draft Policy ARIN-2015-7: Simplified requirements for demonstrated need for IPv4 transfers

2015-06-23 Thread William Herrin
On Tue, Jun 23, 2015 at 4:06 PM, ARIN i...@arin.net wrote:
 Draft Policy ARIN-2015-7
 Simplified requirements for demonstrated need for IPv4 transfers

 Draft Policy ARIN-2015-7
 Simplified requirements for demonstrated need for IPv4 transfers

 Date: 23 June 2015

 Problem statement:

 ARIN transfer policy currently inherits all its demonstrated need
 requirements for IPv4 transfers from NRPM sections 4. Because that section
 was written primarily to deal with free pool allocations, it is much more
 complicated than is really necessary for transfers. In practice, ARIN staff
 applies much more lenient needs assessment to section 8 IPv4 transfer
 requests than to free pool requests, as 24-month needs are much more
 difficult to assess to the same level of detail.

 This proposal seeks to dramatically simplify the needs assessment process
 for 8.3 transfers, while still allowing organizations with corner-case
 requirements to apply under existing policy if necessary.

 Policy statement:

 8.1.x Simplified requirements for demonstrated need for IPv4 transfers

Was this intended to be 8.3.x? It doesn't make sense to me in the
transfer principles section (8.1).


 IPv4 transfer recipients must demonstrate (and an officer of the requesting
 organization must attest) that they will use at least 50% of their aggregate
 IPv4 addresses (including the requested resources) on an operational network
 within 24 months.

I'm inclined to support changing the 8.3 recipient conditions
consistent with this idea but it's not clear to me how this text would
fit with what's already there.

Regards,
Bill Herrin

-- 
William Herrin  her...@dirtside.com  b...@herrin.us
Owner, Dirtside Systems . Web: http://www.dirtside.com/
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Re: [arin-ppml] Draft Policy ARIN-2015-7: Simplified requirements for demonstrated need for IPv4 transfers

2015-06-23 Thread Scott Leibrand
On Tue, Jun 23, 2015 at 4:22 PM, William Herrin b...@herrin.us wrote:

 On Tue, Jun 23, 2015 at 6:59 PM, Scott Leibrand scottleibr...@gmail.com
 wrote:
  On Tue, Jun 23, 2015 at 3:48 PM, William Herrin b...@herrin.us wrote:
   IPv4 transfer recipients must demonstrate (and an officer of the
   requesting
   organization must attest) that they will use at least 50% of their
   aggregate
   IPv4 addresses (including the requested resources) on an operational
   network
   within 24 months.
 
  I'm inclined to support changing the 8.3 recipient conditions
  consistent with this idea but it's not clear to me how this text would
  fit with what's already there.
 
 
  Currently, both 8.3 and 8.4 reference current ARIN policies for
  demonstrating need (The recipient must demonstrate the need for up to a
  24-month supply of IP address resources under current ARIN policies).
 This
  new section 8.1.x would add a new type of policy that would allow
  organizations requesting simple 8.3 or 8.4 IPv4 transfers to bypass all
 the
  complexity and detailed utilization reporting requirements of NRPM
 section
  4.

 Ah. In that case, I'm opposed to the policy as written.

 As a practical matter, the text does not sensibly fit where indicated.
 If placed there, it would make the surrounding policies harder, not
 easier, to understand.


Do you have any suggestions for improving clarity?


 As a policy matter, I'm virulently opposed to using said criteria for
 out-region 8.4 transfers.


This would not apply to 8.4 transfers *out of* the ARIN regions, just 8.4
transfers *into* the ARIN region.  ARIN does not (and would not) enforce
needs assessment on 8.4 transfers to organizations in other regions: that
is up to the recipient's RIR.

-Scott
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Re: [arin-ppml] Draft Policy ARIN-2015-7: Simplified requirements for demonstrated need for IPv4 transfers

2015-06-23 Thread Scott Leibrand
On Tue, Jun 23, 2015 at 5:20 PM, Matthew Kaufman matt...@matthew.at wrote:

 On 6/23/2015 1:06 PM, ARIN wrote:

 Draft Policy ARIN-2015-7
 Simplified requirements for demonstrated need for IPv4 transfers


 I support this policy, but would be even happier if we simply had a
 trigger that said when ARIN is out of IPv4 addresses, this simplified
 policy replaces all other tests for IPv4 transfers and the other sections
 are inactive until such time as ARIN has a new large free pool of IPv4
 addresses (never)


The main reason we didn't write a replacement for section 4 is this:

Organizations that do not meet the simplified criteria above may instead
 demonstrate the need for number resources using the criteria in section 4
 of the NRPM.


There will likely be some sections of the community who feel that their
particular need for IPv4 is better met under section 4 than under this
simplified policy.  Rather than trying to identify every such need and
write in exceptions, I felt it would be better to first allow everyone
using the transfer market to opt out of section 4 entirely, and then once
we have some experience with which requests actually still end up using
section 4, we will have some data on which parts of it we need to keep and
which can be eliminated in a simplification cleanup proposal.

-Scott
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