On 25 Jan 2018, at 5:17 AM, Jason Schiller <[email protected]> wrote:
> 
> The argument (as I understand it) is comparing justification
> required for a transfer vs for ARIN free pool.
> 
> If ARIN does not permit a "no justification" approval 
> for a transfer of a /21 under ISP initial allocation 
> if they have no direct resources then,
> 
> There are extra requirements on transfers that 
> did not exist on getting that same approval for a /21
> from the free pool.
> 
> My understanding is that there is a restriction
> on the ISP initial allocation from the free pool.
> It was show that this is not more than a 90 day 
> supply.  We changed that to two years.
> 
> My understanding is that ISPs with no direct IPv4
> didn't get a free pass on the (then) 90 day restriction
> when asking for their initial /21.  

2009-8 (which added the 90 restriction on ISP initial allocations) indicated 
"This reduction does not apply to resources received via section 8.3.”, and 
therefore it is inappropriate to take it into consideration when comparing 
allocation policy against transfer policy as it was never indicated to apply 
with respect to transfers.

Thanks,
/John

John Curran
President and CEO
ARIN


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