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

Tom Fantacone tom at iptrading.com
Wed May 15 14:47:34 EDT 2019

When ARIN originally suspended the waiting list and we were asked for 
input on ways to curtail abuse of the waiting list, the evidence of 
abuse was largely statistical.  Namely, there were organizations 
receiving addresses from the waiting list and transferring them out 
just after 1 year, organizations that merged after receiving waiting 
list addresses and transferring them out before 1 year, and 
organizations with large IPv4 holdings returning to the waiting list 
for more.  The statistics indicated substantial fraud in terms of the 
number of addresses (because they were large blocks), but that it was 
likely restricted to a small number of entities (most waiting list 
requests are for small blocks are are legitimate).

In light of the recent news that ARIN has stopped one of the 
fraudsters, and that this fraudster was actually operating through 
multiple shady "entities", I think this raises some questions that 
need to be answered to help us decide how to proceed with ARIN's 
Advisory Council recommendation regarding the waiting list.

If we remove the waiting list activity of this one fraudster, how 
much "statistically likely" fraud is left?
Was this one bad actor so bad that he accounted for almost all the 
likely fraud on the waiting list?
Do we still even have a waiting list problem?

Perhaps we still want to take strong measures to prevent this from 
happening in the future, but before making that determination, I'd 
like to know the answers to the above.

And on a related note, can anyone at ARIN tell us the total aggregate 
space that is currently being requested on the waiting list?

 > 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, and of the Numbering
 > Resource Policy Manual:
 > Replace section 4.1.8 as follows, then reinstate the full operation of
 > sections 4.1.8, and 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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