[arin-ppml] Fwd: Advisory Council Recommendation Regarding NRPM 4.1.8. Unmet Requests

Mon May 13 11:13:41 EDT 2019

I agree with these comments. I’m fine requiring all resources obtained via
the wait list to be returned to the wait list rather than be transferred.

+1

Sent from my iPhone

On 13 May 2019, at 11:11, Steven Ryerse via ARIN-PPML <arin-ppml at arin.net>
wrote:

Real life may be that larger sizes never come available, but if the size
does come available and an org is next on the list and it can be justified
within ARIN’s normal policies, then it should be assigned regardless of
size.  +1 to this comment.

*Steven Ryerse*

*President*

*100 Ashford Center North, Suite 110, Atlanta, GA  30338*

*770.656.1460 - Cell*

*770.399.9099 - Office*

*770.392.0076 - Fax*

<image002.jpg>℠ Eclipse Networks, Inc.

        Conquering Complex Networks℠

*From:* ARIN-PPML <arin-ppml-bounces at arin.net> *On Behalf Of *Tom Pruitt
*Sent:* Monday, May 13, 2019 10:39 AM
*To:* David Farmer <farmer at umn.edu>
*Cc:* arin-ppml at arin.net
*Subject:* Re: [arin-ppml] Fwd: Advisory Council Recommendation Regarding
NRPM 4.1.8. Unmet Requests

My biggest objection is limiting of an organization to a specific size.
  Although I realize ARIN can change policies, I believe if an organization
has in good faith followed the existing rules and been put on the waiting
list that they should not come away with nothing especially those that were
on the list before the current suspension began.   If those organizations
were watching the list, and moving up, it is likely that they have made
business decisions based on that data with the assumption that they would
get an allocation at some point.   I believe the proposed allocation limit
is being discussed as a method to discourage bad actors from receiving
address space and then just holding them in order to sell them at a profit
once they are allowed, but as you stated “the waiting list is primarily a
mechanism to ensure resources are not stuck at ARIN”, that has nothing to
do with the size of an organization requesting resources.     I can support
an allocation limit per allocation, and even extending the time an
organization must wait before  getting back on the wait list.  That being
said, if an organization is willing to wait on the list until the resources
are available then they should get the allocation.

Thanks,

Tom Pruitt

Network Engineer

Stratus Networks

<image003.png>

*From:* David Farmer <farmer at umn.edu>
*Sent:* Friday, May 10, 2019 3:44 PM
*To:* Tom Pruitt <tpruitt at stratusnet.com>
*Cc:* arin-ppml at arin.net
*Subject:* Re: [arin-ppml] Fwd: Advisory Council Recommendation Regarding
NRPM 4.1.8. Unmet Requests

If /20 is too small is their another size you would propose? a /19 or a /18
maybe? Do you have an argument for why that is the right number?

When the AC looked at this there was strong support for limiting the size
of the organization that could qualify to ensure these resources went to
smaller organizations. But there were varying opinions on what that size
should be, /20 was just the option with the most support amongst the AC.

This formulation also provides a limit on how many times an organization
can go back to the waiting list, allowing smaller organizations more times
to return to the waiting list, while limiting lager organization to fewer
times to return to the waiting list.  And organizations that already have
more than a /20 must go to the market.

A /20 limit, gives a new organization (with no resources) the opportunity
receive up to 5 allocations from the waiting list if they got a /22 each
time.

A /19 limit would allow a new ISP up to 9 allocations if they got a /22
each time.

A /18 limit would allow a new ISP up to 17 allocations if they got a /22
each time.

Please realize the waiting list is primarily a mechanism to ensure
resources are not stuck at ARIN, it should not be seen as a reliable means
of obtaining resources.

Thanks

On Fri, May 10, 2019 at 2:45 PM Tom Pruitt <tpruitt at stratusnet.com> wrote:

I do not support the new text, specifically the  limit of a /20 per
organization.

The limiting of an organization to an aggregate of a /20 is a huge
hinderance of the ability of a smaller ISP to compete.  A smaller ISP that
can win business on service and cost could lose that same business due to
simply recouping the IPv4 costs.   Large ISPs will often give the IPs away
to win the business, and it costs them nothing as they received their IPV4
space for free.   Additionally, many smaller ISPs operate in outlying areas
where IPv6 adoption will likely be slow, which will also hinder their
ability to push IPv6.    I’m not sure at what point an organization becomes
“large”, but the smaller organizations are the ones that will be hurt by
this limit.

What happens to organizations that are currently on the wait list that have
an aggregate of a /20 or more?  Do they still get  a /22.  Some of those
organizations have been on the list for over a year.   Assuming they played
by the rules and made decisions based on the assumption that they would get
an allotment of IPv4 addresses, denying them any addresses after they have
waited a year or more could be very detrimental to them. These policy
changes and decisions affect the smaller entities greatly, and they need
some clarity.

Thanks,

Tom Pruitt

Network Engineer

Stratus Networks

<image003.png>

*From:* ARIN-PPML <arin-ppml-bounces at arin.net> *On Behalf Of *Andrew Dul
*Sent:* Monday, May 6, 2019 4:09 PM
*To:* arin-ppml at arin.net
*Subject:* [arin-ppml] Fwd: Advisory Council Recommendation Regarding NRPM
4.1.8. Unmet Requests

Hello,

I'd like to bring your attention to another issue that may have been lost
in the flurry of other emails.  We are currently in a 14 day feedback
period for the AC's response to the Board's suspension of the wait-list.
Please note the following updated text for the wait-list.  Your comments on
this updated text are welcome.

Thanks,

Andrew

===

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, for which the organization is qualified, which in the case
of the waiting list shall not be larger than a /22, and the smallest block
size acceptable to the organization. An organization may not be added to
the waiting list if it already holds IPv4 resources amounting in aggregate
to more than a /20 of address space. Resources received via section 4.1.8
may not be transferred within 60 months of the issuance date.

-------- Forwarded Message --------

*Subject: *

[arin-ppml] Advisory Council Recommendation Regarding NRPM 4.1.8. Unmet
Requests

*Date: *

Mon, 29 Apr 2019 11:16:31 -0400

*From: *

ARIN <info at arin.net> <info at arin.net>

*To: *

arin-ppml at arin.net

Subject:

At their 16 January Meeting, the Board of Trustees suspended issuance of
number resources under NRPM section 4.1.8.2. (Fulfilling Unmet Needs), and
referred NRPM section 4.1.8 to the ARIN Advisory Council for their
recommendation.

The Advisory Council has provided its recommendation, and per ARIN's Policy
Development Process, the recommendation is hereby submitted to the Public
Policy Mailing List for a community discussion period of 14 days, to
conclude on 13 May.

Once completed, the Board of Trustees will review the AC’s recommendation
and the PPML discussion.

The full text of the Advisory Council's recommendation is below.

Board of Trustees meeting minutes are available at:

https://www.arin.net/about/welcome/board/meetings/2019_0116/

For more details on the Policy Development Process, visit:

https://www.arin.net/participate/policy/pdp/

Regards,

Sean Hopkins
Policy Analyst
American Registry for Internet Numbers (ARIN)

Advisory Council recommendation:

In accordance with section 10.2 of the ARIN Policy Development Process, the
ARIN Advisory Council recommends the following actions to the Board of
Trustees in response to the Board’s suspension of part of the operation of
sections 4.1.8, 4.1.8.1 and 4.1.8.2 of the Numbering Resource Policy Manual:

Replace section 4.1.8 as follows, then reinstate the full operation of
sections 4.1.8, 4.1.8.1 and 4.1.8.2 immediately.

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, for which the organization is qualified, which in the case
of the waiting list shall not be larger than a /22, and the smallest block
size acceptable to the organization. An organization may not be added to
the waiting list if it already holds IPv4 resources amounting in aggregate
to more than a /20 of address space. Resources received via section 4.1.8
may not be transferred within 60 months of the issuance date.

Repeated requests, in a manner that would circumvent 4.1.6, are not
allowed: an organization may only receive one allocation, assignment, or
transfer every 3 months, but ARIN, at its sole discretion, may waive this
requirement if the requester can document a change in circumstances since
their last request that could not have been reasonably foreseen at the time
of the original request, and which now justifies additional space.
Qualified requesters whose request cannot be immediately met will also be
advised of the availability of the transfer mechanism in section 8.3 as an
alternative mechanism to obtain IPv4 addresses.
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