On 4/30/13, Owen DeLong <owen@delong.com> wrote:
With all due respect, this is a reference in section 8.3 to call out that the policies in section 4 regarding qualification of recipients are to be followed when determining eligibility for an 8.3 transfer.
I don't read a reference to section 4 there. don't think it's a reasonable belief, that a network operator supplicating for transfer of IPv4 resources, would come to this conclusion -- there is no reason to select a specific section to apply because no section is mentioned, reading the policy on their own, and what you are seeing there -- may be a result of bias from your prior exposure to another interpretation of the language. Its also possible, that all of us who were reviewing the proposed transfer policy language read some rationale statement at one time or another, and just (incorrectly) assumed that the final language accomplished our intended effect. I don't think this issue should effect any network operators at this time, but nonetheless i'm concerned about the RIR policy having confusing, surprising, or hidden ramifications built into it, which are problematic and not previously considered.
I would suggest that considering the expressed intent of the policy is more useful than attempting to nit-pick the most nonsensical possible
I looked at the intent of the policy specifically, and it seems pretty obvious that 4.2.2.1.1 and 4.2.2.1.3 very clearly do not intend that they apply to transfers, or other situations where a /20 is not involved. If 8.3 says the current policy applies, then, that by definition imports also the intent and scope restriction in the other sections of the policy, not just the procedures or rules. Specific evidence of intent from 4.2.2.1.1 quote: " if an organization holds a smaller allocation, such as 12 /24s, from its upstream provider, the organization would not meet the minimum utilization requirements of a /20." Furthermore, the 8.3 transfer rule specifically states that the minimum is /24. And the stated requirement is demonstrated need, not "whatever constraints apply to other kinds of allocations/assignment". When the interpretation is intent, with these two statements taken together, we have here, a contradiction between the acceptance of a /24 that can only be resolved by refraining from applying 4.2.2.1.1 and 4.2.2.1.3, or the antecedent is false (you're not requesting a /20, so it follows that you don't need to meet the minimum utilization requirements of a /20). There _is_ a reasonable demonstrated need criteria, in 4.2, that could apply to transfers; though, it's 4.2.3. Reassignment of address space... The characterization of the transfer recipient as a "customer" for reassignment purposes, seems less-problematic than the characterization of a /24 as a /20, for imposing 4.2.2.1.1 , and carries no requirement for a prior upstream assignment.
That is the express intent of that clause in the rationale and according to the authors during discussions of the policy text prior to its adoption.
My expectation about 8.3 is that justification is still to be required. But not the application of /20 justification criterion to a /23 or smaller. Also, i'm not sure what bearing the author's intent may have, as a policy document has to be able to stand on its own, and different members of the community, may aparently have had a different understanding of some of the ramifications of the language. If the language doesn't convey the intent in a clear, at least discernible way, that can be shown through sufficient evidence in the document, then the supposed intent may as well not exist: I mean, it's like saying the developed policy didn't matter "just the author's intent"?.
4.1 provides only general principles. In and of itself it is not a complete set of policies. In addition to the guidance provided by 4.1, one must qualify under 4.2 if one is an ISP/LIR or 4.3 if one is an end-user. There are exceptions provided in 4.4 et. seq. for certain special cases.
Yes; i'm not sure, what, if any relevance these distinctions really have or ought to have, with transfers, and a minimum size of /24, and /23s allowed as well, however. And I sure don't expect applicants for transfer applicants to sort all that out; the policy should be more explicit, and have conditions to clearly apply to the situation. -- -JH