Dani,

In fairness to Bill, I think he may also have chosen them because I suggested 
that those would be boundaries I would consider livable.

I believe they represent a good size to guarantee that small organizations are 
not shut out of the transfer market based on size, but still ensure that need 
assessment is preserved in order to prevent acquisition of addresses without 
intended use thereof.

While a /20 is a fair quantity of addresses (4096), it’s a pretty small number 
of customers for an ISP in most cases and I think anything smaller would be 
somewhat punitive.

It does also line up well with transfer history and other ARIN data about 
small-ish organizations and address issuance over the last several years.

Owen

> On Sep 30, 2015, at 03:52 , Dani Roisman <drois...@softlayer.com> wrote:
> 
> Hi Bill,
>  
> I’m interested to learn how you came up with the below proposed netblock 
> sizes “/20 if a ISP or /22 for an end user” ?  Is there data behind that?  If 
> not, does it make sense to ask ARIN to supply data regarding sizes of 
> transfers which have occurred in the past 12 - 18 months?
>  
> --
> Dani Roisman
>  
> ________________________________
> From: "Bill Buhler" <b...@tknow.com<mailto:b...@tknow.com 
> <mailto:b...@tknow.com%3cmailto:b...@tknow.com>>>
> To: "owen" <o...@delong.com<mailto:o...@delong.com 
> <mailto:o...@delong.com%3cmailto:o...@delong.com>>>
> Cc: arin-ppml@arin.net<mailto:arin-ppml@arin.net 
> <mailto:arin-ppml@arin.net%3cmailto:arin-ppml@arin.net>>
> Sent: Monday, September 28, 2015 12:59:30 PM
> Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
> evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks
>  
> OK, how about this:
>  
> Small end users and ISPs are allowed to obtain IPv4 address blocks without a 
> needs test as long as the following criteria are met:
>  
>  
> a.       The total size of their ARIN allocations at any time of the process 
> does not exceed a /20 if a ISP or /22 for an end user.
>  
> b.      They cannot purchase IP address from the transfer market more than 
> three total times to reach this size, including the initial operation.
>  
> c.       None of the addresses purchased can be transferred to any other 
> entity for twenty-four months following the date of the last transfer.
>  
> d.      If the company ceases operations within the twenty-four month window 
> the addresses are automatically transferred to the ARIN free pool. After that 
> period of time regular transfer rights exist.
>  
> e.      All subsequent allocations / transfers require regular needs testing 
> after the initial twenty-four month allocation window.
>  
> f.        Eligible entities for this policy consist of ISPs and End users who 
> have a unique physical address in the ARIN region at the suite level. Meaning 
> if two companies share the same suite they are not eligible to both have ARIN 
> allocations.
>  
> -------------------
>  
> I believe that meets all of your concerns. I would prefer companies get 
> everything they think they will need in one operation, but I don?t want to 
> have fear drive them into buying the max amount just in case.
>  
> Best regards,
>  
> Bill Buhler
>  
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