[arin-ppml] Draft Policy ARIN-2019-2: Waiting List Block Size Restriction

[ARIN]

On 21 February 2019, the ARIN Advisory Council (AC) accepted 
"ARIN-prop-261: Waiting List Block Size Restriction" as a Draft Policy.

Draft Policy ARIN-2019-2 is below and can be found at:
https://www.arin.net/policy/proposals/2019_2.html

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/policy/pdp.html

Draft Policies and Proposals under discussion can be found at:
https://www.arin.net/policy/proposals/index.html

Regards,

Sean Hopkins
Policy Analyst
American Registry for Internet Numbers (ARIN)



Draft Policy ARIN-2019-2: Waiting List Block Size Restriction

Problem Statement:

A substantial amount of misuse of the waiting list is suspected by ARIN 
staff. A significant percentage of organizations that receive blocks 
from the waiting list subsequently issue these blocks to other 
organizations via 8.3 or 8.4 transfers shortly after the one year 
waiting period required before engaging in such outbound transfers. Most 
of these cases involve larger-sized blocks, and many involve 
organizations that already have large IPv4 holdings. Some organizations 
engage in this practice multiple times, rejoining the waiting list 
shortly after transferring out blocks previously received on the waiting 
list. There are even cases of multiple startup organizations requesting 
approval to be placed on the waiting list where these organizations' 
requests can all be tracked originating from the same IP address. While 
it is possible that some of these cases are legitimate, and while it is 
difficult for ARIN to prove fraud in most individual cases, the large 
number of cases like these indicates a high likelihood that there is 
significant misuse of the waiting list. Specifically, some organizations 
are likely being dishonest in projecting their need for IPv4 space with 
the intent of receiving blocks off the waiting list so that they can 
sell them one year after receiving them. In the case of multiple 
startups, some organizations that receive blocks on the waiting list 
subsequently perform a 8.2 merger/acquisition, allowing them to sell the 
blocks even before the one year waiting period.

The problem is serious enough that the ARIN Board of Trustees has 
suspended issuance of number resources while a solution to this problem 
is found, and it is unfair to organizations with legitimate need on the 
waiting list that they are being crowded out and delayed by those 
looking to game the system.

Policy Statement:

Actual Text:

4.1.8. Unmet requests

In the event that ARIN does not have a contiguous block of addresses of 
sufficient size to fulfill a qualified request, ARIN will provide the 
requesting organization with the option to specify the smallest block 
size they'd be willing to accept, equal to or larger than the applicable 
minimum size specified elsewhere in ARIN policy. If such a smaller block 
is available, ARIN will fulfill the request with the largest single 
block available that fulfills the request. If no such block is 
available, the organization will be provided the option to be placed on 
a waiting list of pre-qualified recipients, listing both the block size 
qualified for and the smallest block size acceptable.

New Text:

4.1.8. Unmet requests

In the event that ARIN does not have a contiguous block of addresses of 
sufficient size to fulfill a qualified request, ARIN will provide the 
requesting organization with the option to specify the smallest block 
size they'd be willing to accept, equal to or larger than the applicable 
minimum size specified elsewhere in ARIN policy. If such a smaller block 
is available, ARIN will fulfill the request with the largest single 
block available that fulfills the request. If no such block is 
available, the organization will be provided the option to be placed on 
a waiting list of pre-qualified recipients, listing both the block size 
qualified for or a /22, whichever is smaller, and the smallest block 
size acceptable, not to exceed a /22.

Comments:

Timeframe for Implementation: Immediate

Anything Else: By limiting the maximum block size for waiting list 
recipients to a /22, the financial incentive to misuse the waiting list 
to receive blocks with the intent to sell them will be drastically 
reduced. The majority of waiting list requests are for smaller block 
sizes, and these requests will be more readily met as the abusers will 
no longer be crowding out the legitimate organizations with need. The 
original intent of the waiting list to help smaller organizations and 
new entrants will be realized. RIPE, APNIC and LACNIC do not have 
waiting lists, but they each have an emergency pool geared toward new 
recipients with a /22 limit which has largely curtailed abuse. 
Organizations that genuinely qualify for larger blocks can still obtain 
these in the marketplace through 8.3 transfers.