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

Fernando Frediani fhfrediani at gmail.com
Fri Aug 16 11:16:30 EDT 2019


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> *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>
>     <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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