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

[Mike Burns]

Why would anybody buy the rare company with a lowly /22 instead of just buying one of the ubiquitous /22s on the market?

If the buyer is complicit in the original fraud on the waiting list, they make themselves an obvious target for potential revocation after engaging in the subsequent 8.2 transfer.

If the buyer is engaged in needs-test-avoidance, the waitlist is a separate issue and other options are easier and cheaper.

Somebody has to provide a notarized attestation of fraudulent need or spend the time and money necessary to make it a real need.

None of this changes as prices rise or fall.



-----Original Message-----
From: ARIN-PPML <arin-ppml-bounces at arin.net> On Behalf Of Rob Seastrom
Sent: Tuesday, July 21, 2020 1:40 PM
To: Fernando Frediani <fhfrediani at gmail.com>
Cc: arin-ppml at arin.net
Subject: Re: [arin-ppml] Recommended Draft Policy ARIN-2020-1: Clarify Holding Period for Resources Received via 4.1.8 Waitlist



> On Jul 21, 2020, at 11:29 AM, Fernando Frediani <fhfrediani at gmail.com> 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.

Remember that the waitlist is section 4.1.8; it is an animal of section 4 and therefore the “show need” requirements are much more stringent than for 8.3 (specified transfer).  A new company (that has no previous history with ARIN and no reassignments from upstreams) will qualify for a /24 (see 4.2.2).

> 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.

Sure, and tweaks over time may become necessary if this turns out to not be enough friction for a shady transaction.  I don’t believe anyone ever thought this will 100.000% eliminate all questionable transactions, only that by keeping a lid on the upside for gaming the system we could minimize the harm without making things unduly difficult on organizations that need space but can wait for it.

> 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.

The counter argument is that putting such time restrictions in place is not aligned with accuracy in whois, which is of benefit to everyone.

> 
> Fernando

-r

> 
> 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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