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

Tue Aug 20 18:08:15 EDT 2019

While you are obviously entiteled to your opinion stated I keep my view
that transfer market should never be the first option specially for new
entrants.
I however recognize and accept its exitence in a way to help organizations
to adapt to this transition period and also move unused resources to their
main propose. That's why it was a good thing for organizarion in most RIRs
where a Inter-RIR transfer policy was adopted at the correct time.

This however doesn't have anythig to do with the possibility of having any
custom made policies that will only benefit of private and for-proft
companies. It is certanly not the propose of any RIR to pass anything to
that propose but instead to the benefit of organizations and the entire
Internet ecosystem.

I understand it may be hard for some people to understand the diference of
a shared resouce where its main propose is to make a entire ecosystem to
work well and balanced and a really private and unrevokable property and
these are the "old principles" that should be highlighted and kept in my
view.

With regards the new entrants topic is simply a question of fairness. Every
organization who hold any IP space was tretaed the same way when they first
requested these resources and althoguh they cannot receive any more they
have alternatives and option to keep themselves in business. Why not treat
new entrants the same way they were treated in the past with the same
fairness and rules ?
Otherwise these organizations will only be creating artificial barriers for
new companies to exist in the Internet and to kill competition and
entrepreneurship which drives evolution.

Best regards
Fernando

On Tue, 20 Aug 2019, 18:23 Mueller, Milton L, <milton at gatech.edu> wrote:

> This is a really bizarre perspective:
>
> >transfer market … is not a natural thing and ideally should not exist.
>
> I’m sorry, but giving out scarce and valuable resources for free is a
> highly “unnatural” thing. It always has disastrous consequences when it is
> done. Think of all the American companies who were given /8s and sat on
> them for decades. Think of the appropriation of RIPE’s last /8 by shell
> companies. Anyone who fails to recognize the powerful role of economic
> incentives in this process should not be talking about “nature” or the
> “natural.”
>
> I have to agree with Burns, you are clinging to old processes and thoughts
> from the free pool era. People who try to re-litigate the existence of
> transfer markets are not making a constructive contribution to the policy
> discussion in 2019. Transfer markets are inevitable and necessary. Equally
> irrational is the claim that we should all just convert to IPv6 and the
> problem will go away. The fact is anyone who wants to be on the internet
> needs IPv4 numbers unless they are willing to not be connected to 70% of
> the internet. Can we agree to set that stuff aside and talk about reality?
>
> So let’s accept “nature” and work from there. IPv4 numbers are scarce, and
> valuable, and people will behave accordingly.
>
> As for new entrants, entering any business costs money – you have to hire
> people, rent offices, acquire infrastructure. What makes IP addresses
> different? Nothing, really. I do not understand this concern about new
> entrants as a special category for RIR allocations.
>
> --MM
>
>
>
>
>
> 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>
> <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
> *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>
> <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> <Alison.WOOD at oregon.gov>
> *Cc:* arin-ppml <arin-ppml at arin.net> <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> 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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> >> Please contact info at arin.net if you experience any issues.
> >
> >
> > _______________________________________________
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