<div dir="auto"><div class="gmail_quote" dir="auto"><div dir="ltr" class="gmail_attr">I support Draft Policy ARIN-2019-2 as written. <br></div><div dir="auto"><div dir="auto"><br></div><div dir="auto">The community has the right to receive incremental improvement without achieving perfection. </div><div dir="auto"><br></div><div dir="auto">John Springer</div><div dir="auto"><br></div></div><br><div class="gmail_quote"><div dir="ltr" class="gmail_attr">On Tue, Feb 26, 2019, 09:50 ARIN <<a href="mailto:info@arin.net" target="_blank" rel="noreferrer">info@arin.net</a>> wrote:<br></div><blockquote class="gmail_quote" style="margin:0 0 0 .8ex;border-left:1px #ccc solid;padding-left:1ex">On 21 February 2019, the ARIN Advisory Council (AC) accepted <br>
"ARIN-prop-261: Waiting List Block Size Restriction" as a Draft Policy.<br>
<br>
Draft Policy ARIN-2019-2 is below and can be found at:<br>
<a href="https://www.arin.net/policy/proposals/2019_2.html" rel="noreferrer noreferrer noreferrer" target="_blank">https://www.arin.net/policy/proposals/2019_2.html</a><br>
<br>
You are encouraged to discuss all Draft Policies on PPML. The AC will <br>
evaluate the discussion in order to assess the conformance of this draft <br>
policy with ARIN's Principles of Internet number resource policy as <br>
stated in the Policy Development Process (PDP). Specifically, these <br>
principles are:<br>
<br>
* Enabling Fair and Impartial Number Resource Administration<br>
* Technically Sound<br>
* Supported by the Community<br>
<br>
The PDP can be found at:<br>
<a href="https://www.arin.net/policy/pdp.html" rel="noreferrer noreferrer noreferrer" target="_blank">https://www.arin.net/policy/pdp.html</a><br>
<br>
Draft Policies and Proposals under discussion can be found at:<br>
<a href="https://www.arin.net/policy/proposals/index.html" rel="noreferrer noreferrer noreferrer" target="_blank">https://www.arin.net/policy/proposals/index.html</a><br>
<br>
Regards,<br>
<br>
Sean Hopkins<br>
Policy Analyst<br>
American Registry for Internet Numbers (ARIN)<br>
<br>
<br>
<br>
Draft Policy ARIN-2019-2: Waiting List Block Size Restriction<br>
<br>
Problem Statement:<br>
<br>
A substantial amount of misuse of the waiting list is suspected by ARIN <br>
staff. A significant percentage of organizations that receive blocks <br>
from the waiting list subsequently issue these blocks to other <br>
organizations via 8.3 or 8.4 transfers shortly after the one year <br>
waiting period required before engaging in such outbound transfers. Most <br>
of these cases involve larger-sized blocks, and many involve <br>
organizations that already have large IPv4 holdings. Some organizations <br>
engage in this practice multiple times, rejoining the waiting list <br>
shortly after transferring out blocks previously received on the waiting <br>
list. There are even cases of multiple startup organizations requesting <br>
approval to be placed on the waiting list where these organizations' <br>
requests can all be tracked originating from the same IP address. While <br>
it is possible that some of these cases are legitimate, and while it is <br>
difficult for ARIN to prove fraud in most individual cases, the large <br>
number of cases like these indicates a high likelihood that there is <br>
significant misuse of the waiting list. Specifically, some organizations <br>
are likely being dishonest in projecting their need for IPv4 space with <br>
the intent of receiving blocks off the waiting list so that they can <br>
sell them one year after receiving them. In the case of multiple <br>
startups, some organizations that receive blocks on the waiting list <br>
subsequently perform a 8.2 merger/acquisition, allowing them to sell the <br>
blocks even before the one year waiting period.<br>
<br>
The problem is serious enough that the ARIN Board of Trustees has <br>
suspended issuance of number resources while a solution to this problem <br>
is found, and it is unfair to organizations with legitimate need on the <br>
waiting list that they are being crowded out and delayed by those <br>
looking to game the system.<br>
<br>
Policy Statement:<br>
<br>
Actual Text:<br>
<br>
4.1.8. Unmet requests<br>
<br>
In the event that ARIN does not have a contiguous block of addresses of <br>
sufficient size to fulfill a qualified request, ARIN will provide the <br>
requesting organization with the option to specify the smallest block <br>
size they'd be willing to accept, equal to or larger than the applicable <br>
minimum size specified elsewhere in ARIN policy. If such a smaller block <br>
is available, ARIN will fulfill the request with the largest single <br>
block available that fulfills the request. If no such block is <br>
available, the organization will be provided the option to be placed on <br>
a waiting list of pre-qualified recipients, listing both the block size <br>
qualified for and the smallest block size acceptable.<br>
<br>
New Text:<br>
<br>
4.1.8. Unmet requests<br>
<br>
In the event that ARIN does not have a contiguous block of addresses of <br>
sufficient size to fulfill a qualified request, ARIN will provide the <br>
requesting organization with the option to specify the smallest block <br>
size they'd be willing to accept, equal to or larger than the applicable <br>
minimum size specified elsewhere in ARIN policy. If such a smaller block <br>
is available, ARIN will fulfill the request with the largest single <br>
block available that fulfills the request. If no such block is <br>
available, the organization will be provided the option to be placed on <br>
a waiting list of pre-qualified recipients, listing both the block size <br>
qualified for or a /22, whichever is smaller, and the smallest block <br>
size acceptable, not to exceed a /22.<br>
<br>
Comments:<br>
<br>
Timeframe for Implementation: Immediate<br>
<br>
Anything Else: By limiting the maximum block size for waiting list <br>
recipients to a /22, the financial incentive to misuse the waiting list <br>
to receive blocks with the intent to sell them will be drastically <br>
reduced. The majority of waiting list requests are for smaller block <br>
sizes, and these requests will be more readily met as the abusers will <br>
no longer be crowding out the legitimate organizations with need. The <br>
original intent of the waiting list to help smaller organizations and <br>
new entrants will be realized. RIPE, APNIC and LACNIC do not have <br>
waiting lists, but they each have an emergency pool geared toward new <br>
recipients with a /22 limit which has largely curtailed abuse. <br>
Organizations that genuinely qualify for larger blocks can still obtain <br>
these in the marketplace through 8.3 transfers.<br>
_______________________________________________<br>
ARIN-PPML<br>
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