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

[hostmaster at uneedus.com]

Even at $10/address, we are already past the point where this is viable.

And of course, if the only asset of the new company is the IPv4 resources, 
selling the entire company to the new holder neatly bypasses any time
restrictions that the NRPM imposes.  Likely this will be done right after 
receipt of resources as was stated.

Even a "No transfer ever" restriction does not get around using companies 
that have no assets other than IPv4 selling itself to the new holder, 
since the company still holds the IPv4 resources.

Not really against the 60 month restriction, but not sure how that is 
really going to help for motivated persons that wish to game the list.

The only answer I can come up with as an answer is to have ARIN use the 
marketplace with all addresses it gets or place them in the dedicated 
pools that already exist and not have a waiting list at all.

Albert Erdmann
Network Administrator
Paradise On Line Inc.

On Tue, 21 Jul 2020, Fernando Frediani wrote:

> 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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