We could also simplify section 8 to state that the minimum transfer size is /24 
and that initial requests for transfer are governed by officer attestation 
limits unless a larger size is needed.

Owen

> On Jan 18, 2018, at 4:32 PM, David Farmer <[email protected]> wrote:
> 
> 
> Looking at this a little more closely;
> 
> Section 8.5.4 has a common size for both initial allocations and assignments 
> or in other words an initial transfer size of /24.
> 
> Whereas in section 4 the initial allocations and assignments sizes differ; 
> with section 4.2.2 having an initial ISP allocation size of /21 and section 
> 4.3.2 having an initial end-user assignment size of /24.
> 
> So, I believe the easiest way to harmonize section 4 and 8 is to harmonize 
> section 4.2.2 with section 4.3.2 at /24.
> 
> Otherwise, we need to make section 8 more complicated and distinguishing 
> between initial allocations and assignments sizes.
> 
> So which way should we go?
> 
> Thanks.
> 
> On Thu, Jan 18, 2018 at 5:17 PM, Owen DeLong <[email protected] 
> <mailto:[email protected]>> wrote:
> Well, section 4 doesn’t govern transfers since we decoupled it anyway, so I’m 
> not sure if we want to make staff behavior consistent or not. I would argue 
> that moving the transfer boundary to /21 would make more sense than moving 
> the section 4 boundary to /24, if we are going to synchronize them.
> 
> However, as you point out, transfers are governed by 8.5.5 and only free pool 
> is governed by section 4 unless section 4 is referenced by section 8.
> 
> As you may recall, I opposed this decoupling because of the confusion and 
> disparity in protocol I expected to result. Now we’re exactly where I 
> predicted we’d be.
> 
> Owen
> 
>> On Jan 18, 2018, at 3:03 PM, David Farmer <[email protected] 
>> <mailto:[email protected]>> wrote:
>> 
>> From the updated problem statement: If an organization applies under section 
>> 8 first they are initially qualified for a /24, larger allocations require 
>> additional documentation as noted in 8.5.5.
>> 
>> Again, whether a change in policy or staff practice, what do we want to 
>> happen?
>> 
>> On Thu, Jan 18, 2018 at 4:38 PM, Owen DeLong <[email protected] 
>> <mailto:[email protected]>> wrote:
>> The existing language “up to a /21” is consistent with staff allowing you to 
>> obtain a /24 via transfer.
>> 
>> Are you telling me that staff is refusing /21 transfers, but allowing /24 
>> transfers to new ISPs without further justification? If so, I would argue 
>> that current staff practice is in error vs. policy language.
>> 
>> Owen
>> 
>>> On Jan 18, 2018, at 2:37 PM, David Farmer <[email protected] 
>>> <mailto:[email protected]>> wrote:
>>> 
>>> Owen,
>>> 
>>> Yep, that was an editing error, it should have been; 
>>> 
>>> 4.2.2. Initial allocation to ISPs
>>> 
>>> All ISP organizations without direct assignments or allocations from ARIN 
>>> qualify for an initial allocation of a /24. Organizations may qualify for a 
>>> larger initial allocation by documenting how the requested allocation will 
>>> be utilized within 24 months.
>>> 
>>> On Thu, Jan 18, 2018 at 4:26 PM, Owen DeLong <[email protected] 
>>> <mailto:[email protected]>> wrote:
>>> I see no reason to move the boundary for an ISP initial allocation from /21 
>>> to /24.
>>> 
>>> Well that seems to be staff intrupretation if you are getting an initial 
>>> allocation via a transfer, how would you reslove this then?
>>> 
>>> Thanks.
>>>  
>>> I certainly see no reason for “up to a /24” as there’s nothing smaller 
>>> available and even if it were, it wouldn’t be useful in any foreseeable 
>>> environment.
>>> 
>>> Owen
>>> 
>>>> On Jan 18, 2018, at 2:21 PM, David Farmer <[email protected] 
>>>> <mailto:[email protected]>> wrote:
>>>> 
>>>> David, 
>>>> 
>>>> The resolution you suggest below seems like a different policy proposal to 
>>>> me, one with a significantly broader scope than this draft policy has.  
>>>> But I think it is a valid question for the community to consider, it's 
>>>> just not really the problem statement in question for this Draft Policy.
>>>> 
>>>> So, back within the scope of this Draft Policy as the shepherd, I plan to 
>>>> push forward Andrew's updated Problem Statement with a Policy Statement 
>>>> that harmonizes and simplifies the text in section 4.2.2 as an official 
>>>> update to this Draft Policy to get the conversation moving again.  
>>>> 
>>>> The current text of 4.2.2 is;
>>>> 
>>>> 4.2.2. Initial allocation to ISPs
>>>> 
>>>> All ISP organizations without direct assignments or allocations from ARIN 
>>>> qualify for an initial allocation of up to a /21, subject to ARIN's 
>>>> minimum allocation size. Organizations may qualify for a larger initial 
>>>> allocation by documenting how the requested allocation will be utilized 
>>>> within 24 months. ISPs renumbering out of their previous address space 
>>>> will be given a reasonable amount of time to do so, and any blocks they 
>>>> are returning will not count against their utilization.
>>>> 
>>>> The text "subject to ARIN's minimum allocation size" seems extraneous.  
>>>> And, post runout renumbering and returning any address space seems 
>>>> unlikely, so let's just eliminate that whole sentence. 
>>>> 
>>>> I propose we simplify that to the following;
>>>> 
>>>> 4.2.2. Initial allocation to ISPs
>>>> 
>>>> All ISP organizations without direct assignments or allocations from ARIN 
>>>> qualify for an initial allocation of up to a /24. Organizations may 
>>>> qualify for a larger initial allocation by documenting how the requested 
>>>> allocation will be utilized within 24 months.
>>>>  
>>>> Below is the policy update that results;
>>>> 
>>>> Thanks
>>>> 
>>>> --------
>>>> 
>>>> Draft Policy ARIN-2017-9: Clarification of Initial Block Size for IPv4 ISP 
>>>> Transfers
>>>> 
>>>> Problem Statement: 
>>>> 
>>>> It was noted in the ARIN 40 Policy Experience Report, that there is an 
>>>> inconsistency in the initial block size for ISPs. Section 4.2.2 notes that 
>>>> the initial ISP block size should be /21 whereas the initial block size in 
>>>> 8.5.4 is noted as "minimum transfer size" which is effectively a /24. This 
>>>> causes ISP organizations to be approved for different initial block size 
>>>> depending on if they first apply for a transfer directly under section 8 
>>>> or if they apply for a block under section 4.  This policy is intended to 
>>>> clarify this issue, by setting a consistent ISP initial IPv4 block size. 
>>>> It was noted that ARIN staff current operational practice is to allow 
>>>> qualified ISPs an initial /21 for Section 8 transfers when they first 
>>>> apply and are approved under section 4.  If an organization applies under 
>>>> section 8 first they are initially qualified for a /24, larger allocations 
>>>> require additional documentation as noted in 8.5.5.
>>>> 
>>>> Policy Statement:
>>>> 
>>>> Change section 4.2.2 as follows;
>>>> 
>>>> 4.2.2. Initial allocation to ISPs
>>>> 
>>>> All ISP organizations without direct assignments or allocations from ARIN 
>>>> qualify for an initial allocation of up to a /24. Organizations may 
>>>> qualify for a larger initial allocation by documenting how the requested 
>>>> allocation will be utilized within 24 months. 
>>>> 
>>>> Comments:
>>>> 
>>>> Timetable for implementation: Immediate
>>>>  
>>>> 
>>>> On Thu, Dec 7, 2017 at 11:37 PM, David Huberman <[email protected] 
>>>> <mailto:[email protected]>> wrote:
>>>> Thank you for the clarification.  I think the staff practice is a 
>>>> reasonable approach and I don’t think change is needed in policy for this.
>>>> 
>>>> The updated Problem Statement reveals the real issue here - the one we 
>>>> need to figure out as a community.   What to do about all the requests 
>>>> each month for IPv4 addresses under section 4? 
>>>> 
>>>> Is it time to pass a policy to direct staff to no longer accept section 4 
>>>> requests (except the ones they still fill like critical infrastructure)? I 
>>>> wonder what the downside of such a policy would be - anyone know?
>>>> 
>>>> 
>>>> 
>>>> On Dec 7, 2017, at 11:47 PM, Andrew Dul <[email protected] 
>>>> <mailto:[email protected]>> wrote:
>>>> 
>>>>> It was noted to me by ARIN staff, that this updated problem statement 
>>>>> doesn't accurately reflect ARIN's current practice.  Below I suggest 
>>>>> another updated problem statement.
>>>>> 
>>>>> Problem Statement: 
>>>>> 
>>>>> It was noted at the ARIN 40 Policy Experience Report, that there is an 
>>>>> inconsistency in the initial block size for ISPs. Section 4.2.2 notes 
>>>>> that the initial ISP block size should be /21 whereas the initial block 
>>>>> size in 8.5.4 is noted as "minimum transfer size" which is effectively a 
>>>>> /24. This causes ISP organizations to be approved for different initial 
>>>>> block size depending on if they first apply apply for a transfer directly 
>>>>> under section 8 or if they apply for a block under section 4.  This 
>>>>> policy is intended to clarify this issue, by setting a consistent ISP 
>>>>> initial IPv4 block size. It was noted that ARIN staff current operational 
>>>>> practice is to allow qualified ISPs an initial /21 for Section 8 
>>>>> transfers when they first apply and are approved under section 4.  If an 
>>>>> organization applies under section 8 first they are initially qualified 
>>>>> for a /24, larger allocations require additional documentation as noted 
>>>>> in 8.5.5.
>>>>> 
>>>> 
>>>> 
>>>> 
>>>> -- 
>>>> ===============================================
>>>> David Farmer               Email:[email protected] 
>>>> <mailto:email%[email protected]>
>>>> Networking & Telecommunication Services
>>>> Office of Information Technology
>>>> University of Minnesota   
>>>> 2218 University Ave SE 
>>>> <https://maps.google.com/?q=2218+University+Ave+SE&entry=gmail&source=g>   
>>>>      Phone: 612-626-0815 <tel:(612)%20626-0815>
>>>> Minneapolis, MN 55414-3029   Cell: 612-812-9952 <tel:(612)%20812-9952>
>>>> ===============================================
>>>> _______________________________________________
>>>> PPML
>>>> You are receiving this message because you are subscribed to
>>>> the ARIN Public Policy Mailing List ([email protected] 
>>>> <mailto:[email protected]>).
>>>> Unsubscribe or manage your mailing list subscription at:
>>>> http://lists.arin.net/mailman/listinfo/arin-ppml 
>>>> <http://lists.arin.net/mailman/listinfo/arin-ppml>
>>>> Please contact [email protected] <mailto:[email protected]> if you experience any 
>>>> issues.
>>> 
>>> 
>>> 
>>> 
>>> -- 
>>> ===============================================
>>> David Farmer               Email:[email protected] 
>>> <mailto:email%[email protected]>
>>> Networking & Telecommunication Services
>>> Office of Information Technology
>>> University of Minnesota   
>>> 2218 University Ave SE 
>>> <https://maps.google.com/?q=2218+University+Ave+SE&entry=gmail&source=g>    
>>>     Phone: 612-626-0815 <tel:(612)%20626-0815>
>>> Minneapolis, MN 55414-3029   Cell: 612-812-9952 <tel:(612)%20812-9952>
>>> ===============================================
>> 
>> 
>> 
>> 
>> -- 
>> ===============================================
>> David Farmer               Email:[email protected] 
>> <mailto:email%[email protected]>
>> Networking & Telecommunication Services
>> Office of Information Technology
>> University of Minnesota   
>> 2218 University Ave SE 
>> <https://maps.google.com/?q=2218+University+Ave+SE&entry=gmail&source=g>     
>>    Phone: 612-626-0815 <tel:(612)%20626-0815>
>> Minneapolis, MN 55414-3029   Cell: 612-812-9952 <tel:(612)%20812-9952>
>> ===============================================
> 
> 
> 
> 
> -- 
> ===============================================
> David Farmer               Email:[email protected] 
> <mailto:email%[email protected]>
> Networking & Telecommunication Services
> Office of Information Technology
> University of Minnesota   
> 2218 University Ave SE        Phone: 612-626-0815
> Minneapolis, MN 55414-3029   Cell: 612-812-9952
> =============================================== 

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