[arin-ppml] Draft Policy ARIN-2020-2: Grandfathering of Organizations Removed from Waitlist by Implementation of ARIN-2019-16

[Isaiah Olson]

Hi all,

On behalf of my organization, I would also like to voice support for this policy. As much as I find some arguments against the policy compelling, namely that nobody is guaranteed to receive any space within any kind of time frame when using the waiting list, I think it’s pretty clear to the community that an error was made in moving the target out from underneath companies who had already been patiently waiting on the list in accordance with the requirements at the time they were added. 

As far as implementation details, I absolutely believe that two of the most important measures to prevent fraud were the introduction of the /22 limit and the 60 month waiting period to transfer wait list issued space. Although we may have erred in retroactively removing orgs based on the new /20 limit for total space held, I think that the grandfathered orgs should be subject to the same treatment as the orgs who remained on the list after 2019-16 was implemented. Otherwise, I believe we would once again be creating a situation of unequal treatment for the orgs who had to reduce their request size to a /22 after the implementation of 2019-16, and were subject to the new 60 month waiting period upon issuance.

With regards to the proposed /18 limit, I do find that there is little to support this arbitrary boundary when the original waitlist policy specified no such condition. Since we are remedying a one time error, I think that we shouldn’t be too particular about which of the aggrieved parties are allowed to make use of that remedy. Although I personally believe that most organizations holding greater than a /18 could probably afford to obtain space in other ways, I think the duty of ARIN to be fair and impartial requires us to take a bit broader view. Asking an organization to take a smaller allocation, or wait longer to transfer allocated space, seems to me to be a much less onerous retroactive application of new policy than drawing any boundary which results in complete ineligibility for some.

Isaiah Olson
Olson Tech, LLC 
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