[arin-ppml] Draft Policy 2020-10: Requirement to Demonstrate, Utilization of Reassignments and Reallocations for ISPs Seeking, Initial Allocation from ARIN

[Isaiah Olson]

I think concerns related to fraud are the primary issues I would have 
with the implementation of this policy as written, and any elimination 
of the current requirement to demonstrate efficient utilization of past 
allocations. I also disagree with the premise of the policy. My 
understanding from organizations that have applied under the current 
policy is that new ISP organizations without any IP allocations or 
re-allocations cannot simply request space without providing some 
documentation of a contract to receive network connectivity, and other 
similar items that may not be required of networks with existing 
re-allocations and operating networks. It doesn't seem to me like there 
is a clear disparity, only that different information is required of 
organizations in differing situations. In some cases, it could possibly 
be even harder for an organization with no existing holdings to acquire 
address space if they ran into issues demonstrating their plan to 
actually get connected, or if they were unable to sign a contract for 
services when they weren't sure if/when they would get address space or 
not. Overall, I just don't see an organization having no holdings as 
having a clear advantage or disadvantage within the waiting list 
process, and I don't support this policy.

However, I would like to ask ARIN staff for clarification on this part 
of the problem statement:

> An organization without reassignments or reallocations doesn’t need to 
> provide any justification other than submitting the request and 
> providing an officer attestation.

Can we get some idea of the accuracy of this statement? Are there 
actually any ISPs that are brand new corporations who received an 
initial allocation with nothing besides an officer attestation? If so, 
how does ARIN determine when extra documentation is required?

Isaiah Olson
Olson Tech, LLC

> I have some major concerns with fraud. My day job sometimes involves/has
> involved reviews when business customers would like space. On occasion,
> ARIN has already denied them. After further review, our security teams find
> out these people aren't who they say they are, don't own the physical
> address they list, etc. Speaking for myself and not for my company, I am
> very concerned that we are opening a huge door to fraud if there are zero
> checks in place for requirements. I don't feel ARIN should be less
> stringent than orgs that get space from them. If the main concern is
> customers are claiming it's too difficult, I have a lot of questions there
> as well. It should be easy to prove you are who you say you are and have a
> valid reason to use the space.
>
> Kat Hunter
> Comcast
> ARIN AC VC