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

[John Springer]

I support Draft Policy ARIN-2019-2 as written.

The community has the right to receive incremental improvement without
achieving perfection.

John Springer


On Tue, Feb 26, 2019, 09:50 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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