The first sentence - 8.3.1.1 for new EUs.

Why is there a usage requirement of 50% immediately?  My experience is networks 
are not built like that.

David R Huberman
Microsoft Corporation
Principal, Global IP Addressing
________________________________
From: arin-ppml-boun...@arin.net <arin-ppml-boun...@arin.net> on behalf of 
Jason Schiller <jschil...@google.com>
Sent: Friday, September 12, 2014 10:44:20 AM
To: Scott Leibrand
Cc: arin-ppml@arin.net
Subject: Re: [arin-ppml] Draft Policy ARIN-2014-20: Transfer Policy Slow Start 
and Simplified Needs Verification

Scott,

I believe the text is officially out of Mike Joseph's and my control... but to 
answer your question...

I am suggesting we take one of the three edits as a modification to the draft, 
so it would be the whole draft with some minor difference to what text in the 
current 8.3 and 8.4 gets removed, or restated.

For clarity I will provide what the policy statement of draft could look like 
with the option 2 modification:


Policy statement:

Remove the following section 8.3 text:

 "> The recipient must demonstrate the need for up to a 24-month supply
  of IP address resources under current ARIN policies and sign an
  RSA.
  > The resources transferred will be subject to current ARIN policies."

 with:

"> Recipients will be subject to current ARIN policies and sign an RSA for the 
resources being received."


Remove the following section 8.4 text:

“Recipients within the ARIN region must demonstrate the need for up to a 
24-month supply of IPv4 address space.”


Add:

8.3.1 New ORGs

8.3.1.1 End-Sites
End-user organizations which do not currently hold IP addresses, and can 
demonstrate 50% immediate utilization by currently held equipment, will 
immediately qualify for a non-M&A transfer between the minimum assignment size 
and a /24, inclusive.

8.3.1.2 ISPs
ISP organizations which do not currently hold IP addresses, and can demonstrate 
50% immediate utilization by currently held equipment, current customers, or 
customer orders will immediately qualify for a non-M&A transfer between the 
minimum allocation size and a /21, inclusive.

8.3.2 Existing ORGs

8.3.2.1 Minimum requirements
Prior to qualifying for non-M&A address transfers, an organization must 
demonstrate an average of 80% utilization, as measured under section 4, across 
the aggregate of all addresses that are currently allocated, assigned, 
reallocated, or reassigned to, or otherwise in use by, the organization.

8.3.2.2 Transfer Approval
An organization which qualifies for transfers under one of the criteria in 
8.3.2.3 shall be approved for the transfer in of an aggregate amount of address 
space as determined by the relevent section. An organization with such an 
approval may then complete one or more transfers, with a cumulative total not 
exceeding the approved amount, without submitting additional justification. An 
organization will be ineligible for additional non-M&A transfers until it can 
again demonstrate that it meets the minimum requirements in section 8.3.2.1.

8.3.2.3 Qualifying Criteria

8.3.2.3.1 Stable Growth
Organizations may be approved for the non-M&A transfer of additional address 
space equal to the amount of address space they were holding at the time of 
approval.

8.3.2.3.2 Rapid Growth
Organizations may be approved for the non-M&A transfer of additional address 
space equal to 24 times the organization’s calculated monthly average use rate.

8.3.2.3.2.1 Calculation of Monthly Average Use Rate
An organization may choose a look-back window of any number of months between 3 
and 12, inclusive, from the date of the current request. ARIN will calculate 
the total amount of new addresses acquired, during the look-back window, by the 
organization from non-M&A transfers, direct allocations or assignments from 
ARIN, or reallocations or reassignments from an ISP. That total will be divided 
by the number of months in the look-back window to calculate the organization’s 
monthly average use rate.

8.3.2.3.2.2 Returned IP space
If addresses are returned or transferred out within the look-back window, then 
those addresses will be subtracted from the total amount of new addresses 
acquired for the purposes of the monthly average use rate calculation.

8.3.2.3.2.3 M&A activity
If M&A transfer activity occurs during the look-back window, the addresses 
acquired through M&A transfers will only be counted in the total amount of new 
addresses acquired if the pre-M&A organization had acquired the resources 
during the post-M&A organization’s look-back window.

8.4.1 -- Same text as 8.3.1

Timetable for implementation: Immediate


Hope this helps.


___Jason


On Fri, Sep 12, 2014 at 1:08 PM, Scott Leibrand 
<scottleibr...@gmail.com<mailto:scottleibr...@gmail.com>> wrote:
I'm still a bit confused. Is the option 2 text below what you're proposing as 
the complete proposal, replacing the many paragraphs and sections of your 
original proposal? Or are you just replacing some of it?  Can you post the full 
resulting policy statement?

Thanks,
Scott

On Sep 12, 2014, at 9:13 AM, Jason Schiller 
<jschil...@google.com<mailto:jschil...@google.com>> wrote:

It has been a week, and there has been no discussion on this thread.

I take the silence to mean the suggested "option 2" rewrite is 
non-controversial and meets all of Bill's concerns.

I also take the silence to mean that all three options I have suggested all 
result in the same implementation,
and since no one believes any of the three options differ in implementation, 
there is no preference.

I humbly submit we should go with option 2, as it is closest to Bill's 
suggestion, and keeps 8.2 and 8.3 in line
(setting the ground work for a future unification of 8.2 and 8.3).

Will there be discussion now?  Or should we just silently move forward?


Thanks,

___Jason




On Thu, Sep 4, 2014 at 11:34 AM, Jason Schiller 
<jschil...@google.com<mailto:jschil...@google.com>> wrote:
Bill,

Thank you.

The intent was NOT to remove the requirement for in-region recipients of 
transfers to sign an RSA.

My apologies.

There is a lot or parallel structure in 8.3 and 8.4 and in my mind 8.4 is 
identical to 8.3 except 8.4 has a clause "Except when the recipient is out of 
region then that region's policy applies", and " Except when the source is out 
of region then that region's policy applies".  I really wanted to completely 
merge 8.3 and 8.4 to remove the parallel structure but as an editorial re-write 
only and not part of this discussion.

in 8.4 there are a separate bullets for 24-month supply and sign the RSA:
"> Recipients within the ARIN region will be subject to current ARIN policies 
and sign an RSA for the resources being received.
 > Recipients within the ARIN region must demonstrate the need for up to a 
 > 24-month supply of IPv4 address space."

I think in my mind I imagined a similar separate bullets in 8.3, one for 
24-month supply and another for sign RSA, and I intended just to remove the 24 
month part.

I think there are a few ways to fix this.

Option 1 - minimun rewrtite
- remove only the "24-month" portion of the 8.3 text. This is the minimum 
change, but brings section 8.3 and 8.4 further out of alignment

Option 2 - single bullet for "meet ARIN policy" and "sign RSA" (8.3 as the 
model text)
- replace the whole "24-month" text and "meet ARIN policy" text in 8.3 with a 
bullet that included "sign the RSA" and "meet ARIN policy" under one bullet and 
is parallel to text in 8.4 (minus within the ARIN region)

Option 3 - two separate bullets for "meet ARIN policy" and "sign RSA" (8.2 as 
the model text)
- replace the whole "24-month" text in 8.3 with a bullet that included "sign 
the RSA"
-separate the "sign the RSA" and "meet ARIN policy" in 8.4 into two bullets and 
is parallel to text in 8.3 (plus the within ARIN region)

(If the summary of the options are hard to follow I have a suggestion for the 
specific rewrites below)

I think your suggestion is roughly Option 2 below (the only difference is with 
your suggested rewrite, there are now two bullets in 8.3 stating the recipient 
is subject to current ARIN policies).  Assuming all the options have the same 
policy implications, I would prefer option 2 or 3, as these bring greater 
alignment of the sections.

Do these options all meet your concern?

Does the community and ARIN staff agree that the thee options have the same 
policy implications?


Kevin, David,

I think at this point you own the text?
I would be supportive of the friendly amendment to modify the draft policy as 
follows:


OPTION 1:
Replace the following Section 8.3 text:

 "> The recipient must demonstrate the need for up to a 24-month supply
  of IP address resources under current ARIN policies and sign an
  RSA."

 with:

"> Recipients will sign an RSA for the resources being received."


OPTION 2:

 Replace the following Section 8.3 text:

 "> The recipient must demonstrate the need for up to a 24-month supply
  of IP address resources under current ARIN policies and sign an
  RSA.
  > The resources transferred will be subject to current ARIN policies."

 with:

"> Recipients will be subject to current ARIN policies and sign an RSA for the 
resources being received."

OPTION 3:
Replace the following Section 8.3 text:

 "> The recipient must demonstrate the need for up to a 24-month supply
  of IP address resources under current ARIN policies and sign an
  RSA."

 with:

"> Recipients will sign an RSA for the resources being received."

and replace the following Section 8.4 text:

"> Recipients within the ARIN region will be subject to current ARIN policies 
and sign an RSA for the resources being received.
  > Recipients within the ARIN region must demonstrate the need for up to a 
24-month supply of IPv4 address space."

With:

"> Recipients within the ARIN region will sign an RSA for the resources being 
received.
 > The resources transferred to recipients within the ARIN region will be 
 > subject to current ARIN policies."

If all the options are indeed the same I would prefer option 2 or 3.
If the options have different policy implications and we can converge on one 
standard for both 8.2 and 8.3, then I would prefer that.


___Jason











On Thu, Sep 4, 2014 at 8:50 AM, Bill Owens 
<ow...@nysernet.org<mailto:ow...@nysernet.org>> wrote:
On Wed, Sep 03, 2014 at 04:55:58PM -0400, ARIN wrote:
> On 28 August 2014 the ARIN Advisory Council (AC) accepted
> "ARIN-prop-212 Transfer policy slow start and simplified needs
> verification" as a Draft Policy.
>
. . .
>
> Draft Policy ARIN-2014-20
> Transfer Policy Slow Start and Simplified Needs Verification
>
> Date: 3 September 2014
>
. . .
>
> Policy statement:
>
> Remove the following section 8.3 text:
>
> “The recipient must demonstrate the need for up to a 24-month supply
> of IP address resources under current ARIN policies and sign an
> RSA.”

Shouldn't that be something like this, instead?

 Replace the following Section 8.3 text:

 "The recipient must demonstrate the need for up to a 24-month supply
  of IP address resources under current ARIN policies and sign an
  RSA.”

 with:

 "The recipient will be subject to current ARIN policies and sign an
  RSA for the resources being received."

As written it appears to remove the requirement for recipients of in-region 
transfers to sign an RSA.

Bill.
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