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

Fri May 24 18:41:05 EDT 2019

I support the /22 per-request limit and /20 total limit for 4.1.8. 

>> 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.

I do not think that organizations already on the list should get special treatment in any regard. There is clear abuse which was most recently demonstrated by Amir Golestan and there are likely to be fraudulent organizations on the list. ARIN is not here to serve only the interests of the handful of those that got in early on the list with large requests, but to serve the larger community as a whole. Thousands of small businesses will benefit from having up to a /20 of 4.1.8 space to kick start their operations.

I disagree with allowing the 4.1.8 IPs to be transferred full stop, with or without a 60 month limit. The "no-transfer" policy works well to curb abuse in 4.10 and would work well for 4.1.8 also. If you don't need IPs anymore, great, but you shouldn't get to profit off the transfer. Allowing even a 60 month transfer window still encourages abuse.

Full disclosure; I am a shareholder in 3 organizations that have /21+ requests on the waiting list.

Robert Clarke

> On May 24, 2019, at 3:17 PM, Michael Williams <michael.williams at glexia.com> wrote:
> 
> Why not send the IPs back to ARIN and let them transfer them to the next organisation? Why let orgs transfer them directly this incentives fraud or misuse. Any IP obtained from waiting list should go back to ARIN if no longer in use not sold or transferred on a secondary market.
> 
> Sent from my iPhone
> 
> On 25 May 2019, at 05:59, Tom Pruitt <tpruitt at stratusnet.com <mailto:tpruitt at stratusnet.com>> wrote:
> 
>> Well said,  this is pretty much exactly how I feel.
>>  
>> Thanks,
>> Tom Pruitt
>>  
>> From: ARIN-PPML <arin-ppml-bounces at arin.net <mailto:arin-ppml-bounces at arin.net>> On Behalf Of Tom Fantacone
>> Sent: Friday, May 24, 2019 2:38 PM
>> To: ARIN <info at arin.net <mailto:info at arin.net>>
>> Cc: arin-ppml <arin-ppml at arin.net <mailto:arin-ppml at arin.net>>
>> Subject: Re: [arin-ppml] Revised - Advisory Council Recommendation Regarding NRPM 4.1.8. Unmet Requests
>>  
>> 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 <info at arin.net <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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