I support Draft Policy ARIN-2019-2. IMO limiting waiting list recipients to a /22 is a reasonable approach that somewhat reduces the gains for fraudulent activity, and ensures that ARIN can serve more legitimate requests for each block it reclaims/receives. Organizations needing more than a /22 should be getting it from the transfer market anyway, so I don’t see much downside to such a restriction on waiting list allocations.
Scott > On Feb 26, 2019, at 9:49 AM, ARIN <[email protected]> wrote: > > On 21 February 2019, the ARIN Advisory Council (AC) accepted "ARIN-prop-261: > Waiting List Block Size Restriction" as a Draft Policy. > > Draft Policy ARIN-2019-2 is below and can be found at: > https://www.arin.net/policy/proposals/2019_2.html > > 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/policy/pdp.html > > Draft Policies and Proposals under discussion can be found at: > https://www.arin.net/policy/proposals/index.html > > Regards, > > Sean Hopkins > Policy Analyst > American Registry for Internet Numbers (ARIN) > > > > Draft Policy ARIN-2019-2: Waiting List Block Size Restriction > > Problem Statement: > > A substantial amount of misuse of the waiting list is suspected by ARIN > staff. 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. Most of these cases involve larger-sized > blocks, and many involve organizations that already have large IPv4 holdings. > Some organizations engage in this practice multiple times, rejoining the > waiting list shortly after transferring out blocks previously received on the > waiting list. There are even cases of multiple startup organizations > requesting approval to be placed on the waiting list where these > organizations' requests can all be tracked originating from the same IP > address. While it is possible that some of these cases are legitimate, and > while it is difficult for ARIN to prove fraud in most individual cases, the > large number of cases like these indicates a high likelihood that there is > significant misuse of the waiting list. Specifically, some organizations are > likely being dishonest in projecting their need for IPv4 space with the > intent of receiving blocks off the waiting list so that they can sell them > one year after receiving them. In the case of multiple startups, some > organizations that receive blocks on the waiting list subsequently perform a > 8.2 merger/acquisition, allowing them to sell the blocks even before the one > year waiting period. > > The problem is serious enough that the ARIN Board of Trustees has suspended > issuance of number resources while a solution to this problem is found, and > it is unfair to organizations with legitimate need on the waiting list that > they are being crowded out and delayed by those looking to game the system. > > Policy Statement: > > Actual Text: > > 4.1.8. Unmet requests > > In the event that ARIN does not have a contiguous block of addresses of > sufficient size to fulfill a qualified request, ARIN will provide the > requesting organization with the option to specify the smallest block size > they'd be willing to accept, equal to or larger than the applicable minimum > size specified elsewhere in ARIN policy. If such a smaller block is > available, ARIN will fulfill the request with the largest single block > available that fulfills the request. If no such block is available, 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 and the > smallest block size acceptable. > > New Text: > > 4.1.8. Unmet requests > > In the event that ARIN does not have a contiguous block of addresses of > sufficient size to fulfill a qualified request, ARIN will provide the > requesting organization with the option to specify the smallest block size > they'd be willing to accept, equal to or larger than the applicable minimum > size specified elsewhere in ARIN policy. If such a smaller block is > available, ARIN will fulfill the request with the largest single block > available that fulfills the request. If no such block is available, 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. > > Comments: > > Timeframe for Implementation: Immediate > > Anything Else: By limiting the maximum block size for waiting list recipients > to a /22, the financial incentive to misuse the waiting list to receive > blocks with the intent to sell them will be drastically reduced. The majority > of waiting list requests are for smaller block sizes, and these requests will > be more readily met as the abusers will no longer be crowding out the > legitimate organizations with need. The original intent of the waiting list > to help smaller organizations and new entrants will be realized. RIPE, APNIC > and LACNIC do not have waiting lists, but they each have an emergency pool > geared toward new recipients with a /22 limit which has largely curtailed > abuse. Organizations that genuinely qualify for larger blocks can still > obtain these in the marketplace through 8.3 transfers. > _______________________________________________ > 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]). 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