[arin-ppml] Draft Policy ARIN-2019-17: Returned Addresses to the 4.10 Reserved Pool
Fernando Frediani
fhfrediani at gmail.com
Fri Aug 16 12:00:33 EDT 2019
Hello
On 16/08/2019 12:41, Mike Burns wrote:
>
> Hi Fernando,
>
> <clip>
>
> But absent the free pool, that mechanism is not necessary and fair, it
> is the opposite of that. In fact, you seem to be injecting items that
> could be considered obviously unfair, such as favoring new entrants
> and smaller companies.
>
This is quiet obvious for me, this is the way it has been done so far in
other RIRs and I don't think they and the community who developed such
policies are wrong. It doesn't take much thought to consider that
existing companies who already hold IP space have ways to keep going,
re-use and optimize the use of IPv4 in order to make more for less and
as time goes it will be natural to use them more for transition
mechanisms and survive. New entrants would be hugely discriminated if
they become an AS and have to go straight to the market. Pushing them to
it would be a way for current holders to protect themselves from new
competition creating artificial barriers, using a wrong mechanism and
also to not treat them the same way they were treated when they first
asked they IP space in the past. Therefore is pretty fair and correct to
assign space only to new entrants and other situations allowed by
sections like 4.10.
>
> I disagree with your opinions about markets being unnatural and not
> ideal, I hold the opposite view. Markets are the ideal method of
> fairly distributing scarce and valuable assets, and that is why they
> naturally evolve in every society.
>
Of course you do. I apologize if this argument bothers you, but it is a
fact to me that trying to build such policies to push people that way
only favors transfer market, not organizations and not the internet
ecosystem, not for new companies to exist in the Internet.
Market is far from an ideal method for distributing scarce resources
simply because who has more money will take them all and not necessary
who need the most and new entrants are the case.
If we were talking about a private resource that companies purchased,
own and is not irrevocable fine it belong to them and they may sell for
whatever amount they like, but we are talking about IP space which is
very different.
>
> I also agree with the executive board decision to shut the waiting
> list while at the same time observe that this unpalatable action was
> only required due to the fraud magnet which is the waiting list.
>
> Opening an office in Africa is to access the free pool remaining in
> AFRINIC and is unrelated to inter-RIR transfers.
>
If they do and use the addresses in Africa region then no problem at all.
>
> I reject the ad-hominem implication that this proposal is designed to
> favor my business. Please consider my arguments and not your personal
> interpretations of my motives in any future replies. This is a
> frequent occurrence for me as a broker and it bothers me.
>
> Regards,
> Mike
>
> *From:*ARIN-PPML <arin-ppml-bounces at arin.net> *On Behalf Of *Fernando
> Frediani
> *Sent:* Friday, August 16, 2019 11:17 AM
> *To:* arin-ppml at arin.net
> *Subject:* Re: [arin-ppml] Draft Policy ARIN-2019-17: Returned
> Addresses to the 4.10 Reserved Pool
>
> Hello Mike
>
> I didn't say those things, you are putting words in my mouth.
>
> What I said is that in current time things like new entrants, critical
> infrastructure, and usage like the 4.10 pool should be prioritized for
> various reasons and organizations under these circumstances should not
> be directed to the market as their first option therefore RIRs should
> not shape their policies to push people to the transfer market which
> is not a natural thing and ideally should not exist. I however
> understand the need of it new a days and that this should be a option
> for organizations who already hold IP space.
>
> With regards the shutdown of the waiting list by the executive board I
> personally consider that a correct decision. They have detected a
> fraud and risk of that happening again and it is their role to do such
> things in order to protect the RIR and ourselves in order to make sure
> that a few organizations needs is not on the top of everybody needs.
> The favoring of small members is another correct thing as well.
>
> With regards opening a office in Africa to get "free" addresses
> fortunately the RIR doesn't allow inter-RIR transfers and according to
> what have been discussed in the list so far they are not willing to
> allow it anytime soon.
>
> There is no sense to put new entrants to get space from 4.4 or 4.10 as
> they are for a different and reasonable propose and pushing them to
> market is exactly shaping policies to favor private business like
> yours which is not the function of a RIR and this community who
> develop these policies.
> Things change over time and we have do adapt to new scenarios (the
> policies allowing transfers intra and inter RIR is a example), but we
> must never forget some principles that has always been base for
> correct IP space allocations.
>
> Regards
> Fernando
>
> On 16/08/2019 10:43, Mike Burns wrote:
>
> Hi Fernando,
>
> Thanks for your input.
>
> I think you are completely wrong in your interpretation of how
> IPv4 addressing should be managed.
>
> You cling to old processes and thoughts associated with the free
> pool era, which is gone.
>
> Without the presence of the free pool, the market is the
> “necessary and fair” way to manage resources.
>
> With both the presence of the free pool and the market, there are
> problems that manifested themselves in overt fraud.
>
> This situation caused unprecedented events like the unilateral
> shutting down of the waiting list by the executive board, the
> virtual writing of policy by the Advisory council, the changing of
> waiting list rules mid-game, the rationale of justifying the need
> for a block and then maintaining that same need for an
> indeterminate time before allocation, the creation of another
> class of addresses in ARIN space (not easily distinguished), the
> favoring of small members over large members, the FUD injected
> into project developments, the incentives to lease space to
> maintain waiting-list need, etc.
>
> We only have to look across the pond to see that any pool of
> “free” addresses will be plundered by those willing to skirt the
> rules for new entrants in RIPE or open an empty office in Africa
> in order to access “free” addresses. You don’t have to limit your
> thoughts to addresses, just think about any situation where a
> valuable resource is available for “free” and you will find fraud.
>
> My hope was the recent fraud recovery would provide an opportunity
> to provide a block to everybody on the waiting list and then be
> able to shut it down without anybody left on it who was waiting
> for a long time. I think it’s the right time to shutter the
> waiting list. Should any more tinkering with the rules become
> necessary, it will likely impact many more people adversely in the
> future if the waiting list is more populated, as I believe it
> will, with members placing their lottery bets. How many new
> ORG-IDs will be granted to members holding more than a /20, for
> the purpose of avoiding that new rule limiting the waiting list to
> those with less than a /20? Whatever rule is imposed, a way around
> it will be sought.
>
> I think it should be shut down, and new entrants buy from the
> market, or adhere to the rules for 4.10 and 4.4.
>
> Regards,
>
> Mike
>
> *From:*ARIN-PPML <arin-ppml-bounces at arin.net>
> <mailto:arin-ppml-bounces at arin.net> *On Behalf Of *Fernando Frediani
> *Sent:* Thursday, August 15, 2019 6:04 PM
> *To:* arin-ppml at arin.net <mailto:arin-ppml at arin.net>
> *Subject:* Re: [arin-ppml] Draft Policy ARIN-2019-17: Returned
> Addresses to the 4.10 Reserved Pool
>
> The waiting list is a necessary and fair way to manage what is
> left for the RIR to distribute to organizations according to its
> mission and based on similar rules that were ever used. If there
> is fraud so let's fix rules for the addresses from these pools as
> it has been discussed recently about the minimal wait period for
> transfers.
> What is out of the RIR's mission is shape its policies to favor
> the transfer market which should never be seen as something normal
> or natural or first option.
> Fernando
>
> On 15/08/2019 18:47, Mike Burns wrote:
>
> Hi Owen,
>
> It’s hard to predict when the useful IPv4 lifetime will end,
> so it’s hard to say whether runout of these reserved pools is
> unlikely, especially if conditions change.
>
> If you feel 4.4 and 4.10 are severely overstocked, maybe a
> proposal to release those “sequestered” addresses should be
> forthcoming, as maintaining those pools at those levels is
> counter to our mission?
>
> Do you have any comments on the problem statement, and the
> idea that the haphazard and unpredictable influx of addresses
> into the waiting list is problematic? For example, doesn’t the
> current constitution of the waiting list encourage virtually
> all ARIN members to enter the lottery for a /22? The size is
> small, the justification options pretty generous, the downside
> minimal.
>
> In my mind the waiting list is a fraud magnet and has outlived
> its usefulness, and yes, this is an attempt to eliminate it
> without going down the auction route. The addresses haven’t
> been destroyed, just taken off the market, adding the tiniest
> bit to the existing pools, whose size was approved by the
> community.
>
> I support the policy as written and amended.
>
> Regards,
>
> Mike
>
> *From:* ARIN-PPML <arin-ppml-bounces at arin.net>
> <mailto:arin-ppml-bounces at arin.net> *On Behalf Of *Owen DeLong
> *Sent:* Thursday, August 15, 2019 5:10 PM
> *To:* WOOD Alison * DAS <Alison.WOOD at oregon.gov>
> <mailto:Alison.WOOD at oregon.gov>
> *Cc:* arin-ppml <arin-ppml at arin.net> <mailto:arin-ppml at arin.net>
> *Subject:* Re: [arin-ppml] Draft Policy ARIN-2019-17: Returned
> Addresses to the 4.10 Reserved Pool
>
> 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.
>
> Owen
>
>
>
>
>
> On Aug 15, 2019, at 13:55 , WOOD Alison * DAS via
> ARIN-PPML <arin-ppml at arin.net <mailto: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]*On
> Behalf Of*Fernando Frediani
> *Sent:*Tuesday, July 30, 2019 6:44 AM
> *To:*arin-ppml <arin-ppml at arin.net
> <mailto: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
> <mailto: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
> >> _______________________________________________
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> >
> >
> > _______________________________________________
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