Sure it definitely cuts down on the abuse, but that isn’t good enough. I don’t think we should support a policy that cuts out “most” of the abuse.
If there are other community members interested in co-authoring a policy for ARIN auctioning space, please give me a ping. Best Regards, Robert Clarke CubeMotion LLC [email protected] M: +1 (844) 244-8140 ex. 512 300 Lenora Street #454, Seattle, WA, 98121 > On Mar 2, 2019, at 10:16 AM, [email protected] wrote: > > This proposal is to lower the maximum to a /22. I believe that this is > justified to make the waiting list process serve mainly smaller players. > While the /22 size will still allow abuse, it clearly does make it harder on > the abusers versus the current policy. Changing the waiting list process to > an auction process is something that I think will require drafting a > different Draft Policy, and may have to address many other related matters > that have been discussed. > > When a Draft Policy to auction the waiting list space is proposed and appears > on the list, I will likely support it. However it is much out of scope for > this Draft Policy, whose main feature is to make the maximum waiting list > block size a /22. > > If you think an auction is best, draft a policy and lets see how that idea is > accepted. > > Albert Erdmann > Network Administrator > Paradise On Line Inc. > > On Sat, 2 Mar 2019, Robert Clarke wrote: > >> Hi Albert, >> >> As has been discussed previously in this thread, /22 requests still leave a >> serious disincentive problem on the table which is counter-productive in the >> community. Bad actors are incentivized to create multiple shell companies to >> hoard space. In my opinion we should work to come up with an alternative >> solution that puts the incentives back in alignment such as allowing ARIN to >> auction off the space for market rates. >> >> While ARIN hands out free money in the form of IPv4 under existing policies >> there will always be a problem with fraud in this community. >> >> Best Regards, >> >> Robert Clarke >> CubeMotion LLC >> [email protected] >> M: +1 (844) 244-8140 ex. 512 >> 300 Lenora Street #454, Seattle, WA, 98121 >> >>> On Mar 2, 2019, at 9:27 AM, [email protected] wrote: >>> >>> I think that changing the waiting list limit to a /22 has merit, even when >>> NOT considering those gaming the system and support the proposal. >>> >>> I think of the waiting list process is more for the benefit of the smaller >>> player, and making the limit a /22 is consistent with this. >>> >>> Those that are larger and seeking larger blocks can more aptly afford to >>> hire a broker, or exert internal resources to finding IPv4 space. >>> >>> I was looking thru the recent transaction list, and I can see that >>> people/brokers have been quite creative in finding space. I found a couple >>> of instances of smaller colleges who received a class B who have decided to >>> sell off the top half of that space. Since they were likely already behind >>> NAT with the student network and may have never actually used that upper >>> block of numbers, this allows them to make some needed cash for other >>> needs. Even some of the class A networks like the US Postal Service do not >>> seem to have exposed to the internet anything except the lowest ranges of >>> their allocation, and I guess once the "Price is Right" some of this space >>> may move as well. >>> >>> Since it has been over 8 years since the official exhaust of IPv4 at the >>> meeting in Miami, I believe that new actors should be instead of using the >>> transfer list to get space should be using the IPv6 deployment block. Since >>> every major OS already has IPv6 support baked in for many years, those >>> setting up new are fools not to be using IPv6 as well. ARIN should do all >>> it can in its policies to promote IPv6. >>> >>> Setting the waiting list to a /22 is a good start to eventually putting all >>> returns into the IPv6 deployment block. I also think that the time is soon >>> near to REQUIRE the receiver of transfered IPv4 space to have IPv6 in place >>> as a condition of receiving space. >>> >>> When we were talking about the use of passive theft detectors like at >>> supermarkets, I think ARIN has a very good one which is questioning why >>> those who just received numbers a year ago suddenly want to get rid of >>> them. This is such an unusual condition and should automatically trigger a >>> number review. As long as this is being done, we may not need to do these >>> other things to prevent abuse. >>> >>> The market is still bringing out IPv4 numbers to their highest and best >>> use, but eventually this will not be enough. Not starting to move toward >>> IPv6 is foolish in todays world, where most commercial circuits will >>> include it without extra charge, and the need for tunnel brokers have >>> therefore been greatly reduced. I have been doing IPv6 for 12 years, due >>> to a 2008 US Federal Government requirement, and it really is not that >>> hard. Even this mailing list is nearly always dispatched to me over IPv6 >>> protocol without any issue. Same with Gmail and other large email >>> providers. I do think we are close to the tipping point for IPv6. After >>> that point, the value of IPv4 numbers will began to drop. >>> >>> Albert Erdmann >>> Network Administrator >>> Paradise On Line Inc. >>> >>> On Fri, 1 Mar 2019, Robert Clarke wrote: >>> >>>> Hi Tom, >>>> >>>> I agree with your point that the transfer market has been an excellent >>>> vehicle for moving space around the ARIN community. If people want to lose >>>> 15% of their money to a broker vs. finding a buyer themselves, that is up >>>> to them. I don’t think this constitutes bad behavior to any parties >>>> involved and I am definitely for brokerage services operating in the space. >>>> >>>>> 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. >>>> >>>> >>>>> Yes, its possible there is abuse with the small blocks off the waiting >>>>> list as well, but so far we arent 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 dont have any evidence >>>>> that will occur. >>>> >>>> >>>> As I have mentioned on at least 2 occasions in the past few days; the >>>> re-transfers statistics are not an indication of the actual scale of the >>>> fraud problem we have here in the community. It is in ARIN’s policies that >>>> re-transfers are under careful supervision, and I’m sure any smart >>>> criminal wouldn’t think to transfer it out immediately but rather >>>> sub-lease the space in the meantime. Why are you clinging to the >>>> re-transfer stats and not acknowledging the basic misalignment of >>>> incentives with the current system? >>>> >>>> Best Regards, >>>> >>>> Robert Clarke >>>> CubeMotion LLC >>>> [email protected] >>>> M: +1 (844) 244-8140 ex. 512 >>>> 300 Lenora Street #454, Seattle, WA, 98121 >>>> >>>>> 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 were 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 ARINs >>>>> transfer stats indicates roughly 8,000 blocks transferred in the same >>>>> time frame since 2015 if Im 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 cant 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. Its 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, its possible there is abuse with the small blocks off the waiting >>>>> list as well, but so far we arent 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 dont 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. Thats a much higher disincentive to go >>>>> through for a /22 than in RIPE, where basically its just frowned upon. >>>>> And per John Currans 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 >>>>> >>>>> >>>>> _______________________________________________ >>>>> ARIN-PPML >>>>> You are receiving this message because you are subscribed to >>>>> the ARIN Public Policy Mailing List ([email protected]). >>>>> Unsubscribe or manage your mailing list subscription at: >>>>> https://lists.arin.net/mailman/listinfo/arin-ppml >>>>> Please contact [email protected] if you experience any issues. >>>> >>> _______________________________________________ >>> ARIN-PPML >>> You are receiving this message because you are subscribed to >>> the ARIN Public Policy Mailing List ([email protected]). >>> Unsubscribe or manage your mailing list subscription at: >>> https://lists.arin.net/mailman/listinfo/arin-ppml >>> Please contact [email protected] if you experience any issues. >>
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