[arin-ppml] Recommended Draft Policy ARIN-2020-1: Clarify Holding Period for Resources Received via 4.1.8 Waitlist

[Fernando Frediani]

I remain opposed to this proposal for the same reasons stated before.

I don't see what can avoid that someone to register a new company, get 
into the waiting list, receive an allocation and right after that be 
"purchased" by another company which is not entitled to be in the 
waiting list anymore bypassing the 60 months restriction.

Although it may not be the easiest thing to do deal with all paperwork, 
bureaucracy and register company, depending on the rising price of IPv4 
in the market someone may find that became worth the efforts and this 
could (not right now, but at some point in the future) turn into a way 
to bypass the waiting list restriction as the mathematics will cover all 
the costs involved in the whole transaction.
This proposal may bring an issue in such scenario and perhaps there 
should still be some minimal time restriction that makes it more 
difficult for fraudsters to act with such intention.

Fernando

On 21/07/2020 12:02, ARIN wrote:
> On 16 July 2020, the ARIN Advisory Council (AC) advanced the following 
> Draft Policy to Recommended Draft Policy status:
>
> ARIN-2020-1: Clarify Holding Period for Resources Received via 4.1.8 
> Waitlist
>
> The text of the Recommended Draft Policy is below, and may also be 
> found at:
>
> https://www.arin.net/participate/policy/drafts/2020_1/
>
> You are encouraged to discuss all Recommended Draft Policies on PPML 
> prior to their presentation at the next ARIN Public Policy 
> Consultation (PPC). PPML and PPC discussions are invaluable to the AC 
> when determining community consensus.
>
> The PDP can be found at:
> https://www.arin.net/participate/policy/pdp/
>
> Draft Policies and Proposals under discussion can be found at:
> https://www.arin.net/participate/policy/drafts/
>
> Regards,
>
> Sean Hopkins
> Policy Analyst
> American Registry for Internet Numbers
>
>
>
> Recommended Draft Policy ARIN-2020-1: Clarify Holding Period for 
> Resources Received via 4.1.8 Waitlist
>
> AC Assessment of Conformance with the Principles of Internet Number 
> Resource Policy:
>
> Recommended Draft Policy ARIN-2020-1 (“RDP 2020-1”) clarifies that 
> IPv4 address space distributed from the waitlist will not be eligible 
> for transfer for a period of 60 months with the exception of transfers 
> under section 8.2 of the ARIN Number Resource Policy Manual (“NRPM”). 
> RDP 2020-1 enables fair and impartial number resource administration 
> by eliminating an ambiguity concerning whether NRPM section 8.2 
> transfers constitute an intended exception to the 60 month hold period 
> under the waitlist policy. RDP 2020-1 is technically sound by 
> fostering clarity and consistency in the application of the waitlist 
> policy, while meeting community needs expressed in section 8.2 of the 
> NRPM, all of which contributes to improved directory accuracy. RDP 
> 2020-1 enjoys community support.
>
> Problem Statement:
>
> A recent Policy Experience Report reported ambiguity on the part of 
> customers as to whether or not the 60-month restriction on 
> transferring resources received via NRPM Section 4.1.8 applies to M&A 
> transfers under NRPM Section 8.2. This proposal clarifies this 
> restriction to exempt 8.2 transfers from this restriction.
>
> Policy Statement:
>
> Update NRPM Section 4.1.8 as follows:
>
> Original Text: Address space distributed from the waitlist will not be 
> eligible for transfer for a period of 60 months.
>
> New Text: Address space distributed from the waitlist will not be 
> eligible for transfer, with the exception of Section 8.2 transfers, 
> for a period of 60 months.”
>
> Timetable for Implementation: Immediate
>
>
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