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

hostmaster at uneedus.com hostmaster at uneedus.com
Wed Feb 27 19:52:36 EST 2019

If we are talking of requests to transfer that were not done, I can see 
the point that this might be confidential.

However the statement says that "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 

If that is the case, a list of those who received waiting list blocks, 
only to transfer them after the year has passed should be public. While it 
might be difficult to extract from Whois without ARIN's help, but it could 
be done.  Since the research has already been done, I say put it out 
there for all of us to see, evaluate and judge intent.

IPv4 blocks from ARIN are meant to be used by the receiving organization, 
and not held for future sale like a currency trader might do.  This is why 
I maintain the ONLY solution to this issue is to limit future transfers of 
addresses transfered under 8.3 or 8.4.

The party giving up ipv4 addresses in an 8.3 or 8.4 transfer is 
effectively declaring that the numbers are no longer needed.  This party 
is not part of the problem.  The problem lies with the receiver of the 
IPv4 addresses who hold the numbers for the minimum period and then sell 
them on.

We need to change the rules such that once a block has been transfered by 
8.3 or 8.4, that party is agreeing that those IPv4 addresses can not ever 
be transfered again under 8.3 or 8.4 policy, in effect waiving any future 
sale windfall in exchange for ARIN granting the requested 8.3 or 8.4 
transfer. Also needed is language that M&A and Bankruptcy transfers of the 
IPv4 addresses can only happen when they are transferred to a new owner 
ALONG WITH the underlying network equipment/business using those IPv4 
addresses. Maybe the policy should also prohibit number resources being 
held by by any entity that actually does not own/control the actual 
network hardware using the addresses.  Placing such a limit would nix 
those persons who are "flipping" IPv4 addresses without the underlying 
business, since they would be no longer able to do so.

I agree with limiting the waiting list to a /22.  However, even at that 
lower value there are still likely to be "flippers", so I do not think 
that change alone will solve the problem stated in the proposal.  This is 
why I would also like to see a future transfer limit adopted.  This limit 
would also apply to private 8.3 and 8.4 transfers outside of the waiting 
list process.

Thus, I agree with option 1.  However, I would also like a transfer limit 
adopted as proposed in option 2.  Rather than 3 years, I would like to see 
it permanent, and require the return the numbers to ARIN if they are no 
longer needed by the receiving organization.  Once policy is changed, they 
would have to agree to this in order to receive IPv4 addresses under 8.3 
and 8.4.

Albert Erdmann
Network Administrator
Paradise On Line Inc.

On Wed, 27 Feb 2019, Ronald F. Guilmette wrote:

> In message <F6B352BB-13A2-43BB-A440-3A3F1019089C at arin.net>,
> John Curran <jcurran at arin.net> wrote:
>> The registry is public.  The _requests_ to change the registry (which often
>> require detailed technical and business information to meet the policies
>> that this community sets) are not public.
> Thanks for the clarification John.  That's a very very pretty point, and
> one that causes me to wonder if I have misconstrued the allegations that
> have been put forward to justify the proposal.
> Has ARIN merely seen _requests_ to change the registry... requests which,
> in 100% of the cases, ARIN has not actually acted upon... and which appear
> ARIN staff to be suspicious and perhaps even fradulent in some way?
> I quote directly from the original proposal problem statement:
>     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...
> Maybe I need to take a refresher course on plain English, but it appears
> to me that this says that blocks *were* assigned, and that some such blocks
> *were* subsequently transfered.  So it would appear that we are not talking
> about mere confidential requests here, nor are we talking about any of the
> confidential information that might relate in any way to such requests,
> i.e. while the requests are pending and while they are being evaluated by
> ARIN staff.  Instead, it seems to me, we are talking about both assignments
> and transfers that were in fact made, and that thus should have been duly
> recorded in the public ledger that we call the ARIN WHOIS data base.
> Have I misunderstood?
> If not, and if there is already public information that is available to
> anyone who simply compares successive historical editions editions of
> the WHOIS data base to one another, looking only at the changes, and if
> that change information, over time, points to the identities of the
> specific entities that have obtained and the transfered the allocations in
> question, in the suspicious manner described, then you have no compelling
> reason, either legal, moral, or ethical to withold those identities from
> the community.  And you should not do so.  Both individuals and corporate
> entities need to be held accountable for their public actions.  It is
> precisely the widspread _lack_ of such accountability that leads, always
> and inevitably, to even more audacious frauds in the future.
> Sunlight is the best disinfectant.  And frankly, I don't know why such
> a simple and obvious concept should require such a hard sell on my part
> to get across.
> Maybe we can cut to the chase here and just take a simple poll.
> Everyone on this list who really wants John to protect the identities of
> the guilty in this case please raise your hands now.
> Regards,
> rfg
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