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

[hostmaster at uneedus.com]

I oppose this.

Even with IPv4 addresses being worth merely $10 each, the value of a /22 
of address space from the waiting list is $10,240.  Clearly that is enough 
of a value to incorporate.  In reality, the current market rate is much 
higher than that.  I think a total NO SELL agreement is the only thing 
that will prevent abuse of the waiting list, but if the party is a 
corporation, nothing would prevent corporate sale or transfer to avoid 
these restrictions.

I would rather eliminate the waiting list, and place this space into the 
4.10 pool, as at least that space requires a commitment to IPv6.

I do not know when we will reach the peak of the IPv4 marketplace, but it 
is clear that if the internet wishes to grow beyond 4.3B addresses, IPv6 
is the only currently available protocol that can grow beyond the 4.3B 
address limit of IPv4.

Albert Erdmann
Network Administrator
Paradise On Line Inc.

On Tue, 10 Mar 2020, Fernando Frediani wrote:

> Just to make it clear for record I oppose this proposal as written for the 
> reasons stated below and believe it requires necessary adjustments.
> Regards
> Fernando
>
> On 26/02/2020 02:54, Fernando Frediani wrote:
>> May I ask how this situation will avoid that someone to register a new 
>> company, get into the waiting list, receive a /22 and right after that be 
>> "purchased" by another company which is not entitled to be in the waiting 
>> list anymore bypassing the 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 effort 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.
>> 
>> At first seeing I identify this proposal may bring an issue in such 
>> scenario and perhaps there should still be some minimal time restriction, 
>> not necessarily 60 months, but something that makes it more difficult for 
>> fraudsters to act with such intention.
>> 
>> Regards
>> Fernando
>> 
>> On 25/02/2020 18:49, ARIN wrote:
>>> On 20 February 2020, the ARIN Advisory Council (AC) accepted 
>>> "ARIN-prop-284: Clarify Holding Period for Resources Received via 4.1.8 
>>> Waitlist" as a Draft Policy.
>>> 
>>> Draft Policy ARIN-2020-1 is below and can be found at:
>>> 
>>> https://www.arin.net/participate/policy/drafts/2020_1/
>>> 
>>> You are encouraged to discuss all Draft Policies on PPML. The AC will 
>>> evaluate the discussion in order to assess the conformance of this draft 
>>> policy with ARIN's Principles of Internet number resource policy as stated 
>>> in the Policy Development Process (PDP). Specifically, these principles 
>>> are:
>>> 
>>> * Enabling Fair and Impartial Number Resource Administration
>>> * Technically Sound
>>> * Supported by the Community
>>> 
>>> 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 (ARIN)
>>> 
>>> 
>>> 
>>> Draft Policy ARIN-2020-1: Clarify Holding Period for Resources Received 
>>> via 4.1.8 Waitlist
>>> 
>>> 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.”
>>> 
>>> Comments:
>>> 
>>> Timetable for implementation: immediate
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