[arin-ppml] Draft Policy ARIN-2019-17: Returned Addresses to the 4.10 Reserved Pool

Thu Aug 15 23:07:06 EDT 2019

On Thu, Aug 15, 2019 at 5:10 PM Owen DeLong <owen at delong.com> wrote:

> Really, it seems to me that this proposal is another attempt at
> eliminating the waiting list for unmet requests.
>
> The first attempt (ARIN auctions the space) met with resistance from
> ARIN’s legal team (for good reason), so now this attempts to sequester the
> space where it will be hard to distribute rather than allowing the waiting
> list to have any potential to compete with the transfer market.
>
> The proposed targets (4.4 and 4.10 pools) are well stocked and unlikely to
> run out in any useful IPv4 lifetime.
>
> As such, restocking them from returned space strikes me as just a way to
> sequester this space where it cannot be used.
>
> IMHO, this is counter to ARIN’s mission and should not be allowed.
>
> I oppose the policy as written and as proposed to be amended.
>
>

For different reasons, but generally close enough, agree. +1

>
> On Aug 15, 2019, at 13:55 , WOOD Alison * DAS via ARIN-PPML <
> arin-ppml at arin.net> wrote:
>
> Thank you for the continued input on this draft policy proposal.
>
> I will be updating the text of the draft policy to include both 4.4 and
> 4.10 pools.  Point of information, the 4.4 pool currently has approximately
> 391 /24’s and 4.10 has approximately 15,753 /24’s available and are not
> estimated to run out in the next five years.
>
> Please keep your feedback coming, it is very helpful for the council.
>
> -Alison
>
> *From:* ARIN-PPML [mailto:arin-ppml-bounces at arin.net
> <arin-ppml-bounces at arin.net>] *On Behalf Of *Fernando Frediani
> *Sent:* Tuesday, July 30, 2019 6:44 AM
> *To:* arin-ppml <arin-ppml at arin.net>
> *Subject:* Re: [arin-ppml] Draft Policy ARIN-2019-17: Returned Addresses
> to the 4.10 Reserved Pool
>
>
> The point is that you treating IP marketing as something 'natural' or a
> 'default route' which it is not and can never be. Natural is to receive
> some addresses from the RIR in first place so they are treated as anyone
> else was in the past and have a chance to exist in the Internet with same
> conditions as all others. From that if they need extra space then fine to
> seek for alternative ways.
>
> I don't think a new entrants would automatically qualify for 4.10 in all
> cases therefore any space left should be targeted also to them as well to
> IPv6 transition and critical infrastructure. Otherwise the community will
> be creating an artificial barrier to them in order to favor the IP market
> while the RIR still has IPv4 space available for them.
>
> Fernando
> On 30/07/2019 10:30, Tom Fantacone wrote:
>
> I would think that the majority of new entrants would need at least some
> allocation to help with IPv6 transition and would qualify for addresses
> from the 4.10 pool.  Depending on what they receive from that pool and
> when, they may not qualify for additional waiting list addresses and would
> have to go to the transfer market for additional IPv4 space anyway.  Those
> that don't qualify under 4.10 can still get smaller IPv4 blocks on the
> transfer market readily, and the cost for blocks in the /24-/22 range is
> not prohibitive.  Certainly an organization seeking a small IPv4 block for
> multi-homing or other purposes is better off spending a few thousand
> dollars to purchase a range than waiting a year on the waiting list to put
> their plans in motion.
>
>
> Note that while RIPE does not have a reserve pool specifically for IPv6
> transition, the expectation of their final /8 policy was to allow new
> entrants access to IPv4 to assist in this transition.  In reality, it
> didn't work out that way and most of the /22 allocations to new LIRs from
> the final /8 were to existing organizations who spun up new, related
> entities in order to increase their IPv4 holdings:
>
>
> https://labs.ripe.net/Members/wilhelm/so-long-last-8-and-thanks-for-all-the-allocations
>
> I'm also sympathetic to new entrants, but don't see the current waiting
> list as a great help to them vs. the 4.10 pool or the transfer market, both
> of which allow you your allocation in a timely fashion.
>
> Best Regards,
>
> Tom Fantacone
>
> ---- On Mon, 29 Jul 2019 11:39:32 -0400 *Fernando Frediani
> <fhfrediani at gmail.com <fhfrediani at gmail.com>>* wrote ----
>
>
> I find it interesting the idea of privileging the pool dedicated to
> facilitate IPv6 Deployment and I also agree with the comments below in
> the sense that it's not very beneficial do most ARIN members due to max
> size, /22, cannot be holding more than a /20.
>
> However one point I couldn't identify is where the new entrants stand in
> this new possible scenario ? Will they only be able to apply under the
> 4.10 reserved pool ? If so for a access/broadband ISPs may be easier to
> fit, but not necessarily for other scenarios and types of ISPs.
> Therefore if I didn't miss anything these returned addresses should also
> be able to go to new entrants, not only to 4.10 reserved pool conditions.
>
> Best regards
> Fernando Frediani
>
> On 25/07/2019 17:32, Tom Fantacone wrote:
> > I found the wording of the Problem Statement on this one a bit
> > confusing. However, after deciphering the effect of the actual policy
> > change I support it.
> >
> > Essentially, all returned IPv4 space will no longer go to the waiting
> > list but will supplement the 4.10 reserved pool used to enhance IPv6
> > deployment.  This essentially kills off the waiting list.
> >
> > The recent restrictions placed on the waiting list to reduce fraud
> > have hobbled it to the point where it's not very beneficial to most
> > ARIN members.  (Max size, /22, cannot be holding more than a /20).
> > It's essentially only useful to new entrants, but those that go on it
> > still have to wait many months to receive their small allocation.  If
> > they justify need now, but have to wait that long, how critical is
> > their need if they're willing to wait that long?  Small blocks are not
> > terribly expensive and can be quickly gotten on the transfer market.
> > I can understand waiting that long for a large block needed for a
> > longer term project due to prohibitive cost, but I don't see a great
> > benefit to the waiting list as it stands.
> >
> > Also, if there's any fraud left on the waiting list, this would kill it.
> >
> > I would hope, however, that if implemented, those currently on the
> > waiting list would be grandfathered in.  I do think some entities with
> > legitimate need got burned on the last change made to the waiting list.
> >
> > At 04:05 PM 7/23/2019, ARIN wrote:
> >> On 18 July 2019, the ARIN Advisory Council (AC) accepted
> >> "ARIN-prop-276: Returned Addresses to the 4.10 Reserved Pool" as a
> >> Draft Policy.
> >>
> >> Draft Policy ARIN-2019-17 is below and can be found at:
> >>
> >> https://www.arin.net/participate/policy/drafts/2019_17/
> >>
> >> You are encouraged to discuss all Draft Policies on PPML. The AC will
> >> evaluate the discussion in order to assess the conformance of this
> >> draft policy with ARIN's Principles of Internet number resource
> >> policy as stated in the Policy Development Process (PDP).
> >> Specifically, these principles are:
> >>
> >> * Enabling Fair and Impartial Number Resource Administration
> >> * Technically Sound
> >> * Supported by the Community
> >>
> >> The PDP can be found at:
> >> https://www.arin.net/participate/policy/pdp/
> >>
> >> Draft Policies and Proposals under discussion can be found at:
> >> https://www.arin.net/participate/policy/drafts/
> >>
> >> Regards,
> >>
> >> Sean Hopkins
> >> Policy Analyst
> >> American Registry for Internet Numbers (ARIN)
> >>
> >> Draft Policy ARIN-2019-17: Returned Addresses to the 4.10 Reserved Pool
> >>
> >> Problem Statement:
> >>
> >> An inconsistent and unpredictable stream of address space is an
> >> unsuitable method of populating the waiting list (4.1.8.1) and
> >> fulfilling subsequent requests.
> >>
> >> Policy statement:
> >>
> >> Change "4.10. Dedicated IPv4 Block to Facilitate IPv6 Deployment" to
> >> "4.10 Dedicated IPv4 Pool to Facilitate IPv6 Deployment"
> >>
> >> Change" When ARIN receives its last /8 IPv4 allocation from IANA, a
> >> contiguous /10 IPv4 block will be set aside and dedicated to
> >> facilitate IPv6 deployment. Allocations and assignments from this
> >> block " to "In addition to the contiguous /10 IPv4 block set aside
> >> and dedicated to facilitate IPv6 deployment, all returns and
> >> revocations of IPv4  blocks will be added to the pool of space
> >> dedicated to the facilitation of IPv6 deployment. Allocations and
> >> assignments from this pool "
> >>
> >> Change "This block will be subject to a minimum size allocation of
> >> /28 and a maximum size allocation of /24. ARIN should use sparse
> >> allocation when possible within that /10 block." to "This pool will
> >> be subject to a minimum size allocation of /28 and a maximum sized
> >> allocation of /24. ARIN should use sparse allocation when possible
> >> within the pool."
> >>
> >> Comments:
> >>
> >> Timetable for implementation: Immediate
> >> _______________________________________________
> >> ARIN-PPML
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> >
> >
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