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

David Farmer farmer at umn.edu
Wed Feb 27 12:47:34 EST 2019

I concur with what Tom says below. Further would like to add that when I
look at the statistics I see a policy that for the most part has been very
successful in accomplishing its primary goal, ensuring that IPv4
resources are not stuck in an ARIN pool.  More than 1.5M IPv4 addresses
have been allocated, in 700 allocations, to organizations meeting their
continuing need for IPv4 addresses, including a few larger allocations to
presumably larger organizations, and many smaller allocations to presumably
smaller organizations.

Unfortunately, it seems a small minority have decided to use this policy to
profiteer.  This was recognized as a possible outcome of the original
policy, but the community didn't want to limit the possibility of larger
allocations from this policy only on the potential for abuse. Now that we
have at least statistical evidence of abuse, it is therefore probably
prudent to not allow further large allocations through this policy. The
proposed /22 limit seems reasonable and should be effective in limiting the
financial incentives to profiteer.  That is not to say it will completely
eliminate the possibility of profiteering, however, good policy doesn't
have to be perfect in this regard.  I think we just need to eliminate the
possibility of a gigantic windfall from these larger blocks. The benefits
to the community of continuing to allocate smaller blocks seem to outweigh
the relatively small risk of profiteering on these smaller block.

I support the general idea of this policy, however, I think we need to
fully consider all the possibilities on how to adjust this policy. But,
lets not forget overall this has been a very effective policy.


On Wed, Feb 27, 2019 at 10:31 AM Tom Fantacone <tom at iptrading.com> wrote:

> Kevin,
> I agree that statistical data should be used in this case to validate that
> the problem exists.  Not only do non-disclosures prevent ARIN from
> presenting most evidence of specific cases, but ARIN acknowledges that
> there may be specific instances where transferring out a block received
> from the waiting list is not fraudulent at all, but due to unusual but
> legitimate business circumstances.  It would not be fair to publicly point
> out all actors in potential fraud when a few of them might not be
> culpable.  But the statistical evidence is strong enough to indicate that
> fraud exists.
> In that regard, in addition to the data John Curran provided showing the
> high percentage of larger blocks that have been re-transferred, it's worth
> reviewing the presentation by John Sweeting at the ARIN 42 meeting last
> October where he discussed the evidence and solicited possible solutions
> from the community.
> Transcript;
> https://www.arin.net/vault/participate/meetings/reports/ARIN_42/ppm1_transcript.html#anchor_5
> Youtube;
> https://www.youtube.com/watch?v=MJHgs4wWO58
> Presentation;
> https://www.arin.net/vault/participate/meetings/reports/ARIN_42/PDF/PPM/sweeting-policy.pdf
> Specifically, John discusses the re-transfer statistics, the fact that
> several waiting list orgs already have at least a /16 of space, and the
> cases of 8.2 mergers performed by orgs on the waiting list to consolidate
> their holdings, avoid the one year wait, and then perform an 8.3 transfer.
> Regards,
> Tom
> At 03:06 AM 2/27/2019, Kevin Blumberg wrote:
> Ronald,
> To be clear. For the purposes of the Policy Proposal I'm perfectly content
> with the aggregate data that has been provided.
> The problem statement from the author, in my view, matches up with the
> data provided by John Curran.
> Kevin
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David Farmer               Email:farmer at umn.edu
Networking & Telecommunication Services
Office of Information Technology
University of Minnesota
2218 University Ave SE        Phone: 612-626-0815
Minneapolis, MN 55414-3029   Cell: 612-812-9952
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