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

[Kevin Blumberg]

The problem statement is pretty damning in the abuse described. The BoT minutes while mentioning misuse and abuse was void of the information described by the policy author. While I would like to take the problem statement at face value, it would be helpful, based on the current discussion, to understand the percentage of space that has been "flipped" via 8.x transfers 0-24 months after issuance. While I'm sure the community could trawl through transfers and figure this out, I would appreciate the basic information.

Regarding the policy, I don't believe it goes far enough in addressing the issue. I would like to see the similar text as used in 4.2.3.8

IP allocations issued through 4.2.3.8 are non-transferable via section 8.3 and section 8.4 for a period of 36 months. In the case of a section 8.2 transfer the IP assignment must be utilized for the same purpose or needs based justification at a rate consistent with intended use.

Thanks,

Kevin Blumberg
-----Original Message-----
From: ARIN-PPML <arin-ppml-bounces at arin.net> On Behalf Of ARIN
Sent: Tuesday, February 26, 2019 12:50 PM
To: arin-ppml at arin.net
Subject: [arin-ppml] Draft Policy ARIN-2019-2: Waiting List Block Size Restriction

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.
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