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

[Scott Leibrand]

I support Draft Policy ARIN-2019-2. IMO limiting waiting list recipients to a /22 is a reasonable approach that somewhat reduces the gains for fraudulent activity, and ensures that ARIN can serve more legitimate requests for each block it reclaims/receives. Organizations needing more than a /22 should be getting it from the transfer market anyway, so I don’t see much downside to such a restriction on waiting list allocations. 

Scott

> On Feb 26, 2019, at 9:49 AM, ARIN <info at arin.net> wrote:
> 
> 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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