Yes, it??s possible there is abuse with the small blocks off the waiting list
as well, but so far we aren??t seeing it (only 3% of smaller blocks have been
re-transferred vs. 42% of the larger blocks). Now, perhaps if we restrict the
waiting list block size to a /22 these bad actors will start playing the same
game with /22s, but we don??t have any evidence that will occur.
On Mar 1, 2019, at 10:26 AM, Tom Fantacone <[email protected]> wrote:
Hi Bill,
At 06:35 PM 2/28/2019, William Herrin wrote:
On Tue, Feb 26, 2019 at 9:49 AM ARIN <[email protected]> wrote:
A significant percentage of organizations that receive blocks
from the waiting list subsequently issue these blocks to other
organizations via 8.3 or 8.4 transfers shortly after the one year
waiting period required before engaging in such outbound transfers.
I'm shocked to learn that people are playing arbitrage with the
transfer process. Oh wait, no I'm not. I may have even expressed my
expectation that we'd see this sort of behavior back when we debated
the transfer policies. If I had the time, I might dig out my old
emails just so I could say I told you so.
While we have a problem with the waiting list that we??re trying to address
here, I think it's important to point out that the transfer market as a whole
has proven an excellent vehicle for moving number resources from those who no
longer need them to those who do. This ??gaming of the system?? is restricted
to a subset of the waiting list, and the number of blocks issued on the waiting
list is less than 10% of the blocks transferred in the ARIN region during the
same time period. (682 blocks have been issued via the waiting list, and a
quick look at ARIN??s transfer stats indicates roughly 8,000 blocks transferred
in the same time frame since 2015 if I??m reading it correctly). If we look at
the ratio in terms of total address space, I suspect the waiting list comprises
an even smaller percentage, though I can??t readily find those figures.
Furthermore, even within the waiting list, the problem appears with only a
small percentage of recipients (25 re-transfers out of 682 total), although
this does impact a high percentage of the waiting list block space since the
abusers are almost entirely doing this with larger blocks.
The point is that while ??The problem statement is pretty damning
?? (quoting Kevin Blumberg), the sky is not falling due to the transfer
markets. It??s damning within the small subset of re-transfers of blocks
received off the waiting list.
the organization will be provided the option to be placed on
a waiting list of pre-qualified recipients, listing both the block size
qualified for or a /22, whichever is smaller, and the smallest block
size acceptable, not to exceed a /22.
I fail to see how this solves the problem. For $20k a pop, I can clear
a tidy profit on a year, a shell company and some paperwork. Sure I'd
rather get $200k a pop but the change doesn't make the effort
unattractive. I really just need to create more shell companies.
This approach is reactive. Oh, the fraud is mostly on the big blocks
so stop that. Oh, now the fraud is on the smaller blocks, what do we
do? Don't react. Get ahead of the problem. That's what you do.
Yes, it??s possible there is abuse with the small blocks off the waiting list
as well, but so far we aren??t seeing it (only 3% of smaller blocks have been
re-transferred vs. 42% of the larger blocks). Now, perhaps if we restrict the
waiting list block size to a /22 these bad actors will start playing the same
game with /22s, but we don??t have any evidence that will occur.
Others have pointed out issues of abuse in RIPE where LIRs are spun up to grab
/22s from the final /8, but the 2 environments are different. First, there is
no justification requirement in RIPE. Form a corp, have a presence in the RIPE
region, and you get a /22 whether you can justify it or not. That may not
exactly be a noble action in support of the spirit of the RIPE community, but
for the most part, it is policy-compliant. In ARIN, you have to justify your
need and sign an affidavit affirming your justification which makes willful
misrepresentation fraudulent. That??s a much higher disincentive to go
through for a /22 than in RIPE, where basically it??s just frowned upon. And
per John Curran??s remarks, ARIN has revoked address space when investigating
why some of these actors are selling their waiting list space shortly after
receiving it. So these gamers could risk an audit of their full address
holdings in order to con ARIN out of a /22. The ??abuse?? in RIPE regarding
the final /8 is also heavily concentrated in a few member nations and, suffice
it to say, those same nations are not ARIN members.
Regards,
Tom
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