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

[Tom Fantacone]

Keeping in mind that the original suspension of the waiting list and calls for restrictions was based upon statistical evidence that multiple actors were committing waiting list fraud, and that we've subsequently learned it was really one bad actor with multiple Orgs/identities, who has been caught, stopped and punished, I'm reluctant to go overboard on restrictions that harm the vast majority of fair players.  Still, we do want to change incentives to prevent this from happening again.

1. I support the /22 limit. 
I think the size limit for those on the current waiting list should be significantly larger, however.  I suggest an /18 or at least a /19.  These Orgs joined the waiting list with the expectation that they would receive at least the minimum size they requested in perhaps a year or so, made their business plans accordingly, and opted not to use the transfer market when they were approved.  Since then prices for IPv4 have risen significantly.  I believe it unfair to change the rules on them so drastically.  There is no evidence that there are a significant number of fraudsters still on the list.

2. I support that only Orgs holding a /20 or less can get on the waiting list.
I don't want it applied to existing Orgs on the list for the same reasons as in 1.

3. I oppose the 60 month waiting period before an 8.3 transfer.
It's too long.  Plenty of legitimate Orgs need the IPs, will use them for 2-3 years, but may not need them after that.  And this policy would incentivize them to sit on the addresses till the 60 months runs out, wasting valuable resources others could use, as others have pointed out.  I suggest a 24 month waiting period.


Regards,



Tom

---- On Fri, 24 May 2019 13:04:58 -0400 ARIN <mailto:info at arin.net> wrote ----


At their 16 May meeting, the Advisory Council revised their 
recommendation regarding NRPM 4.1.8. Unmet Requests.

The revised recommendation is hereby submitted to the Public Policy 
Mailing List for a second community discussion period of 14 days, to 
conclude on 7 June.

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

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

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



Advisory Council recommendation:

This is an updated version which incorporates feedback from the ARIN 
staff and was approved for further community consultation at the ARIN AC 
meeting on May 16, 2019.

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 et. seq. 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 ARIN Waitlist

ARIN will only issue future IPv4 assignments/allocations (excluding 4.4 
and 4.10 space) from the ARIN Waitlist. The maximum size aggregate that 
an organization may qualify for at any one time is a /22. Organizations 
will be able to elect a smaller block size than they qualify for down to 
a /24. Only organizations holding a /20 or less of IPv4 address space 
may apply and be approved. Address space distributed from the waitlist 
will not be eligible for transfer for a period of 60 months. This policy 
will be applied to all future distributions from the waitlist to include 
those currently listed.

Repeated requests, in a manner that would circumvent 4.1.6, are not 
allowed: an organization currently on the waitlist must wait 90 days 
after receiving a distribution from the waitlist before applying for 
additional space. 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 will also be advised of the 
availability of the transfer mechanism in section 8.3 as an alternative 
mechanism to obtain IPv4 addresses.

4.1.8.1 Sequencing

The position of each qualified request on the waiting list will be 
determined by the date it was approved. Each organization may have one 
approved request on the waiting list at a time.

4.1.8.2 Fulfillment

ARIN will fulfill requests on a first-approved basis, subject to the 
size of each available address block as address blocks become available 
for distribution. A timely review of the original request may be 
conducted by ARIN staff. Requests will not be partially filled. Any 
requests met through a transfer will be considered fulfilled and removed 
from the waiting list.
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