[arin-ppml] ARIN-2019-7: Elimination of the Waiting List (was:Re: Looking for final show of support on revised Advisory Council Recommendation Regarding NRPM 4.1.8. Unmet Requests

[hostmaster at uneedus.com]

Oppose

I have no problem with the idea of getting rid of the waiting list part of 
the proposal.

I do have a problem with an auction, as I think it will cause lots of 
issues when ARIN revokes resources, because it certainly will be alleged 
that "ARIN did it for the money", as has already been discussed, and will 
make any legal action a lot more costly. The Board choosing to use auction 
proceeds for legal costs would be like pouring gasoline on a fire, and I 
note that the Board could choose to spend auction proceeds in this 
fashion, since how to spend the proceeds is totally under their control.

Rather than an auction, I propose putting the returns in the 4.10 
Dedicated IPv4 Block to Facilitate IPv6 Deployment.  This pool is limited 
to a /24 maximum.  This use would also promote IPv6 use.

This would leave the marketplace as the only source of IPv4 addresses 
greater than a /24.  It would also effectively limit any "free" addresses 
to smaller players.

If we are giving out "Free" addresses at ARIN, why not impose a condition 
that the addresses so provided be used as part of IPv6 deployment?

Albert Erdmann
Network Administrator
Paradise On Line Inc.

On Thu, 20 Jun 2019, Alyssa Moore wrote:

> Hi folks,
>
> Trying to do a temperature check here. If you're following this thread,
> please indicate whether you support or oppose this draft policy.
>
> On Mon, Jun 17, 2019 at 11:42 AM David Farmer <farmer at umn.edu> wrote:
>
>>
>>
>> On Sun, Jun 16, 2019 at 2:50 PM Mueller, Milton L <milton at gatech.edu>
>> wrote:
>>
>>> OK, I’ve read it, and here is my reaction:
>>>
>>>
>>>
>>> This policy requires legal comment. ARIN’s Articles and Bylaws do not
>>> specifically prohibit ARIN from monetizing returned or revoked resources by
>>> selling those resources into the transfer market
>>>
>>>
>>>
>>> So point #1 is that this proposed policy does not violate any articles or
>>> bylaws.
>>>
>>>
>>>
>>> Today, ARIN does not financially benefit in any material way from such
>>> revocations. Adoption of this policy would for the first time allow the
>>> party in a contested revocation situation to argue that ARIN seeks to
>>> financially benefit. Avoiding that concern is also significant.
>>>
>>>
>>>
>>> I am totally unimpressed with this argument. If ARIN revokes addresses
>>> for nonpayment it is financially benefiting from the revocation is it not?
>>> It is basically taking them back because it is not getting paid.
>>>
>>>
>>>
>>> If ARIN “gets paid” by selling the numbers into the transfer market what
>>> is the difference exactly?
>>>
>>
>> Referring to the waiting list policy, the Draft Policy says, "this policy
>> provides valuable number resources essentially for free".
>>
>> Yes, ARIN currently financially benefits, but currently, that benefit is
>> at a level of cost recovery, "essentially for free" as stated above.
>> Whereas, if ARIN were to dispose of resources using the market, the level
>> of financial benefit is likely to be orders of magnitude larger.
>> Furthermore, if this wasn't the case, then the impact on the market and the
>> potential for fraud supposedly created by the waiting list, that the draft
>> policy proposes to mitigate, wouldn't exist in the first place.
>>
>> In short, "what is the difference", probably, several orders of magnitude
>> in the level of financial benefit involved. Where the financial motivations
>> from simple "cost recovery" can probably be summarily dismissed by the
>> court. Whereas the potential financial motivations, that one might even
>> call a windfall, from market-based transactions probably at least needs to
>> be examined and evaluated by the court, and probably wouldn't be summarily
>> dismissed. The outcome of the two situations might be the same in the end,
>> but the level of effort involved defending and the level of risk of an
>> adverse ruling, are not the same at all.
>>
>> More generally, ARIN participating in the market seems distasteful and
>> counter to its overall mission, but doesn't directly violate its Articles
>> and Bylaws.
>>
>> That said that doesn't mean ARIN can't implement the policy, but these
>> risks need to be evaluated when compared to other alternatives being
>> considered, along with the possible benefits this policy could have as well.
>>
>> --
>> ===============================================
>> 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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>