Re: [arin-ppml] re-org question

[William Herrin]

On Fri, Nov 4, 2016 at 11:54 PM, Ronald F. Guilmette
 wrote:
> In message 
> 
> William Herrin  wrote:
>>Sorry Owen, I won't engage you with the relocated goal post. If you
>>are correct, the 8.2 transfer language requires a registrant whose
>>addresses are assigned and in use but not efficiently used per ARIN
>>standards to engage some degree of renumbering as consequence of the
>>transfer.
>
> You say that like it's a bad thing.

Hi Ronald,

I say that like I think Owen's diversion to, 'Nowhere does it say you
are required to renumber," reeked of cognitive dissonance.

Whether I think it's a bad thing for ARIN to dictate that corporate
restructuring requires renumbering, as NRPM 8.2 seems to say, returns
us to the original conversion. My thoughts on that can be boiled down
to three words which start W.T.F.

Regards,
Bill Herrin


-- 
William Herrin  her...@dirtside.com  b...@herrin.us
Owner, Dirtside Systems . Web: 
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Re: [arin-ppml] re-org question

[Ronald F. Guilmette]

In message 
William Herrin  wrote:

>Sorry Owen, I won't engage you with the relocated goal post. If you
>are correct, the 8.2 transfer language requires a registrant whose
>addresses are assigned and in use but not efficiently used per ARIN
>standards to engage some degree of renumbering as consequence of the
>transfer.

You say that like it's a bad thing.

https://en.wikipedia.org/wiki/Manspreading

See also:  Social courtesy, Limited resources
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Re: [arin-ppml] re-org question

[William Herrin]

On Fri, Nov 4, 2016 at 10:55 PM, Owen DeLong  wrote:
> You can return as small as a /24.
>
> If you’re using half, then you can keep it.
>
> So, at most, you have to renumber 126 hosts out of each of half of your /25s.
>
> How is this not minimal again?

Sorry Owen, I won't engage you with the relocated goal post. If you
are correct, the 8.2 transfer language requires a registrant whose
addresses are assigned and in use but not efficiently used per ARIN
standards to engage some degree of renumbering as consequence of the
transfer.

-Bill



-- 
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Owner, Dirtside Systems . Web: 
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Re: [arin-ppml] re-org question

[William Herrin]

On Fri, Nov 4, 2016 at 10:42 PM, David R Huberman  wrote:
>> The language was introduced in draft policy 2010-6 whose rationale stated:
>> "This policy also should dramatically increase the completion rate for
>> transfer requests, as the evaluation of whether space is efficiently
>> utilized after the transfer can occur in parallel, completely
>> independently of the transfer request, and can continue even if the
>> transfer request is abandoned."
>>
>> Still think renumbering to achieve efficient utilization as a
>> consequence of the 8.2 transfer wasn't intended to be a requirement?
>
> I don't know for sure.  I was answering your question with objective fact,
> to help you help your client make an informed decision.

Hi David,

I'm sure it will come as a great relief to my client that ARIN
probably won't follow its policy as written because no one knows for
know for sure whether they really meant it that way.

Regards,
Bill Herrin


-- 
William Herrin  her...@dirtside.com  b...@herrin.us
Owner, Dirtside Systems . Web: 
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Re: [arin-ppml] re-org question

[Owen DeLong]

You can return as small as a /24.

If you’re using half, then you can keep it.

So, at most, you have to renumber 126 hosts out of each of half of your /25s.

How is this not minimal again?

Owen

> On Nov 4, 2016, at 19:52 , William Herrin  wrote:
> 
> On Fri, Nov 4, 2016 at 10:45 PM, Owen DeLong  wrote:
 Nowhere does it say you are required to renumber. You’re reading that into 
 things.
> 
>> In the vast majority of cases I’ve encountered, minimal renumbering can free 
>> up more than
>> enough space to return to satisfy policy.
> 
> Owen,
> 
> Minimal renumbering is still renumbering. Especially if there's some
> minority where the renumbering isn't minimal. The policy's renumbering
> requirement was there all along; I didn't insert it or "read it into
> things."
> 
> Regards,
> Bill Herrin
> 
> 
> -- 
> William Herrin  her...@dirtside.com  b...@herrin.us
> Owner, Dirtside Systems . Web: 

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Re: [arin-ppml] re-org question

[William Herrin]

On Fri, Nov 4, 2016 at 10:45 PM, Owen DeLong  wrote:
>>> Nowhere does it say you are required to renumber. You’re reading that into 
>>> things.

> In the vast majority of cases I’ve encountered, minimal renumbering can free 
> up more than
> enough space to return to satisfy policy.

Owen,

Minimal renumbering is still renumbering. Especially if there's some
minority where the renumbering isn't minimal. The policy's renumbering
requirement was there all along; I didn't insert it or "read it into
things."

Regards,
Bill Herrin


-- 
William Herrin  her...@dirtside.com  b...@herrin.us
Owner, Dirtside Systems . Web: 
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Re: [arin-ppml] re-org question

[Owen DeLong]

> On Nov 4, 2016, at 19:33 , William Herrin  wrote:
> 
> On Fri, Nov 4, 2016 at 10:28 PM, Owen DeLong  wrote:
>>> On Nov 4, 2016, at 19:11 , William Herrin  wrote:
>>> On Fri, Nov 4, 2016 at 10:01 PM, Owen DeLong  wrote:
 Perhaps, in part, because some of us think that the RSA is what is broken 
 rather than the language in the policy.
>>> 
>>> Owen,
>>> Really? You think ARIN policy should be that folks are required to
>>> renumber just because of a business transaction involving the owner of
>>> the physical network using them?
>> 
>> Nowhere does it say you are required to renumber. You’re reading that into 
>> things.
>> 
>> It says that if the combined organization can not justify the combined 
>> resources, that ARIN will work with them on appropriate transfers, and/or 
>> returns.
> 
> Owen,
> 
> You're going to have to explain that particular magic to me because I
> haven't heard of any way to free up netblocks for return other than
> renumbering out of them.

If you’re using 50%, you pretty much meet current guidelines, so really very 
little problem.

If you’ve got a /16 and you’ve got /28s all over it, yeah, you’ll probably have 
to do some consolidation (renumbering) of some of the networks.

If you’ve got a /16 and you’re using most of the first /18, then no problem 
with returning the last /17 and (if needed) the second /18.


> Sure, an org might possibly have vast amounts of unrouted address
> space they're just not using with all the addresses they are using
> carefully crammed into an efficient /24 but what's your plan for
> everybody else?

There’s a lot of ground in between those two extremes. In the vast majority of 
cases I’ve encountered, minimal renumbering can free up more than
enough space to return to satisfy policy.

Owen

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Re: [arin-ppml] re-org question

[David R Huberman]

The language was introduced in draft policy 2010-6 whose rationale stated:

"This policy also should dramatically increase the completion rate for
transfer requests, as the evaluation of whether space is efficiently
utilized after the transfer can occur in parallel, completely
independently of the transfer request, and can continue even if the
transfer request is abandoned."

Still think renumbering to achieve efficient utilization as a
consequence of the 8.2 transfer wasn't intended to be a requirement?


I don't know for sure.  I was answering your question with objective fact, 
to help you help your client make an informed decision.

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Re: [arin-ppml] re-org question

[William Herrin]

On Fri, Nov 4, 2016 at 10:01 PM, David R Huberman  wrote:
>
>> It's a public policy document. In the absence of language to the
>> contrary, the MUST is implied. And if it's not a MUST then it's
>> operational guidance that doesn't belong in a POLICY document at all.
>
> Nevertheless, the MUST is not there and is not implied.

Hi David,

The language was introduced in draft policy 2010-6 whose rationale stated:

"This policy also should dramatically increase the completion rate for
transfer requests, as the evaluation of whether space is efficiently
utilized after the transfer can occur in parallel, completely
independently of the transfer request, and can continue even if the
transfer request is abandoned."

Still think renumbering to achieve efficient utilization as a
consequence of the 8.2 transfer wasn't intended to be a requirement?

Regards,
Bill Herrin

-- 
William Herrin  her...@dirtside.com  b...@herrin.us
Owner, Dirtside Systems . Web: 
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Re: [arin-ppml] re-org question

[William Herrin]

On Fri, Nov 4, 2016 at 10:01 PM, Owen DeLong  wrote:
> Perhaps, in part, because some of us think that the RSA is what is broken 
> rather than the language in the policy.

Owen,

Really? You think ARIN policy should be that folks are required to
renumber just because of a business transaction involving the owner of
the physical network using them?

'Cause if you don't think that then maybe let's get that stray
sentence the heck out of there.

Regards,
Bill Herrin




-- 
William Herrin  her...@dirtside.com  b...@herrin.us
Owner, Dirtside Systems . Web: 
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Re: [arin-ppml] re-org question

[Owen DeLong]

> On Nov 4, 2016, at 18:35 , David R Huberman  wrote:
> 
> 
>> "ARIN will proceed with processing transfer requests even if the
>> number resources of the combined organizations EXCEED WHAT CAN BE
>> JUSTIFIED UNDER CURRENT ARIN POLICY. IN THAT EVENT, ARIN will work
>> with the resource holder(s) to transfer the extra number resources to
>> other organization(s) or accept a voluntary return of the extra number
>> resources to ARIN."
>> 
>> I don't see an "or let you keep the extra number resources' in there.
> 
> Correct. You also don't see a MUST in the context of MUST transfer or MUST 
> return.  The RSA forbids it, and the community has never given ARIN such 
> power in policy.
> 
> The AC has tried to fix this text a few times, and perhaps we haven't done a 
> good enough job.

Perhaps, in part, because some of us think that the RSA is what is broken 
rather than the language in the policy.

The intent of the community, despite the board’s and staff’s future actions to 
the contrary was that an 8.2 transfer would force signing an RSA.

Owen

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Re: [arin-ppml] re-org question

[David R Huberman]

It's a public policy document. In the absence of language to the
contrary, the MUST is implied. And if it's not a MUST then it's
operational guidance that doesn't belong in a POLICY document at all.


Probably, yes. Nevertheless, the MUST is not there and is not implied. And 
I fully agree on the sentence not belonging there, because a reasonable 
reading includes the implication.

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Re: [arin-ppml] re-org question

[William Herrin]

On Fri, Nov 4, 2016 at 9:35 PM, David R Huberman  wrote:
>> "ARIN will proceed with processing transfer requests even if the
>> number resources of the combined organizations EXCEED WHAT CAN BE
>> JUSTIFIED UNDER CURRENT ARIN POLICY. IN THAT EVENT, ARIN will work
>> with the resource holder(s) to transfer the extra number resources to
>> other organization(s) or accept a voluntary return of the extra number
>> resources to ARIN."
>>
>> I don't see an "or let you keep the extra number resources' in there.
>
> Correct. You also don't see a MUST in the context of MUST transfer or MUST
> return.  The RSA forbids it, and the community has never given ARIN such
> power in policy.

David,

It's a public policy document. In the absence of language to the
contrary, the MUST is implied. And if it's not a MUST then it's
operational guidance that doesn't belong in a POLICY document at all.


> The AC has tried to fix this text a few times, and perhaps we haven't done a
> good enough job.

You think?

Regards,
Bill




-- 
William Herrin  her...@dirtside.com  b...@herrin.us
Owner, Dirtside Systems . Web: 
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Re: [arin-ppml] re-org question

[David R Huberman]

"ARIN will proceed with processing transfer requests even if the
number resources of the combined organizations EXCEED WHAT CAN BE
JUSTIFIED UNDER CURRENT ARIN POLICY. IN THAT EVENT, ARIN will work
with the resource holder(s) to transfer the extra number resources to
other organization(s) or accept a voluntary return of the extra number
resources to ARIN."

I don't see an "or let you keep the extra number resources' in there.


Correct. You also don't see a MUST in the context of MUST transfer or MUST 
return.  The RSA forbids it, and the community has never given ARIN such 
power in policy.


The AC has tried to fix this text a few times, and perhaps we haven't done 
a good enough job.

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Re: [arin-ppml] re-org question

[William Herrin]

On Fri, Nov 4, 2016 at 9:17 PM, David R Huberman  wrote:
>
>> As I read the last paragraph in NRPM section 8.2, in order for the /16
>> to be recorded under the new subsidiary's name, the subsidiary would
>> have to sign an RSA, renumber the otherwise unchanging network
>> infrastructure to meet ARIN's current efficiency standards and return
>> or sell the excess IP addresses.
>>
>> Am I actually reading that right?
>
>
> No. You are drawing a conclusion not supported by either the text or by many
> years of practice.  The /16 can be transferred as-is. ARIN has been given no
> power in the NRPM to coerce a renumbering, return, exchange, or anything
> else.

Hi David,

For clarity's sake, here's the text, emphasis mine:

https://www.arin.net/policy/nrpm.html#eight2

"ARIN will proceed with processing transfer requests even if the
number resources of the combined organizations EXCEED WHAT CAN BE
JUSTIFIED UNDER CURRENT ARIN POLICY. IN THAT EVENT, ARIN will work
with the resource holder(s) to transfer the extra number resources to
other organization(s) or accept a voluntary return of the extra number
resources to ARIN."

I don't see an "or let you keep the extra number resources' in there.

Regards,
Bill Herrin



-- 
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Owner, Dirtside Systems . Web: 
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Re: [arin-ppml] re-org question

[David R Huberman]

As I read the last paragraph in NRPM section 8.2, in order for the /16
to be recorded under the new subsidiary's name, the subsidiary would
have to sign an RSA, renumber the otherwise unchanging network
infrastructure to meet ARIN's current efficiency standards and return
or sell the excess IP addresses.

Am I actually reading that right?


No. You are drawing a conclusion not supported by either the text or by 
many years of practice.  The /16 can be transferred as-is. ARIN has been 
given no power in the NRPM to coerce a renumbering, return, exchange, or 
anything else.

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[arin-ppml] re-org question

[William Herrin]

Hi Folks,

I have an NRPM 8.2 question for you. One of the orgs I work with is
contemplating a reorganization in which the IT support group and all
of its assets will be split off in to a wholly owned subsidiary. One
of these assets is a legacy /16.

As I read the last paragraph in NRPM section 8.2, in order for the /16
to be recorded under the new subsidiary's name, the subsidiary would
have to sign an RSA, renumber the otherwise unchanging network
infrastructure to meet ARIN's current efficiency standards and return
or sell the excess IP addresses.

Am I actually reading that right?


Semi-related question: Does ARIN publish anywhere which RIRs it deems
to "share reciprocal, compatible, needs-based policies" under section
8.4?

Thanks,
Bill Herrin


-- 
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Owner, Dirtside Systems . Web: 
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