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

[Austin Murkland]

support as written, may not be perfect but is a step in the right direction.



On Mon, Mar 4, 2019 at 2:43 PM John Springer <3johnl at gmail.com> wrote:

> 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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