Hi Rob,

 

Thanks for compiling the information as you did. I will top-post because my 
discussion is orthogonal to the discussion, but I would like for the AC to 
consider these points.

 

I’m not sure we need to fix anything with the current waitlist policy if we can 
anticipate a dwindling source of addresses which feed the list.  As a 
community, I don’t think we considered that the refilling of the wait list 
would include more than IANA returned addresses, which have petered out in size 
to the almost-vanishing point.

 

So if we address the remaining supply sources, maybe we can solve this problem. 

 

The first unexpected source is addresses returned to ARIN for non-payment or 
voluntarily. 

It would be extremely unlikely that any dues in arrears would be more than the 
value of the blocks themselves on the market.

Why wouldn’t an address holder arrange a loan to pay the dues, sell the block, 
and repay the loan while keeping the profit?

We certainly have done this for sellers in similar straits. Dues get paid, 
block gets sold to somebody in need, all is good.

Anything that facilitates this process would reduce waitlist inventory growth.

 

In the event of a voluntary return, this is even harder to understand.  Would 
these potential sellers insist on the return of their blocks to ARIN if they 
knew that ARIN would prefer them to actually sell the block on the market?  I 
doubt it, but also I doubt that the ARIN community has reached the same 
conclusion that I have, which is the presence of a free pool distorts the 
market adversely, and the free pool should be starved into eventual elimination.

 

I actually think these two sources of addresses could be attenuated by 
application of raw economics, but the other source is more problematic.  That 
source is the recovery of abandoned blocks by ARIN. I believe this could be a 
persistent and large source of space that could serve to bring relatively large 
blocks to the waiting list. 

 

I would prefer, if ARIN feels that now is an appropriate time to begin(?) or 
ramp up this process, that the recovered blocks go back to IANA for 
distribution to the 5 RIRs, which I would hope would minimize this source of 
waiting list inventory by 80%. Probably many are old legacy blocks which could 
only have been registered at ARIN, making it more reasonable to return to IANA. 
 Is the disposition of these recovered blocks covered by policy which mandates 
their placement into waiting list inventory?

 

If we could anticipate the list being starved of new supply, then I would be 
willing to accept that a few bad actors apparently gamed the system, but the 
limited number of these events doesn’t rise to the level requiring significant 
changes to the waitlist policy.

 

Regards,
Mike Burns

 

 

 

 

From: ARIN-PPML <[email protected]> On Behalf Of Rob Seastrom
Sent: Thursday, March 14, 2019 3:24 PM
To: [email protected]
Subject: Re: [arin-ppml] Policy action menu for Waiting List (4.1.8) - feedback 
requested.

 

 

Just a reminder that I’d love to get comments on any and all aspects of this 
list by Friday (tomorrow) night.

 

The AC has a call next Thursday (a week from today) and I would like plenty of 
time to collate them into a summary for discussion.

 

Regards,

 

-r

 

PS:  I am sure it was fairly clear from the context, but I should have 
mentioned last week that the use of first person pronouns such as “I” and “We” 
in these comments reflects the opinions of individual reviewers not the AC.

 





On Mar 7, 2019, at 1:34 PM, Rob Seastrom <[email protected] 
<mailto:[email protected]> > wrote:

 

 

Dear Colleagues,

Starting immediately after our annual meeting in late January, the ARIN AC 
began curating a list of possible policy actions to take in response to the 
Board's suspension of the waiting list policy.  We would like to share that 
list of possible actions and comments with the Community.  While the attached 
list of actions is not a policy proposal we hope that it will stimulate 
constructive discussion regarding ARIN-2019-2, and possibly even lead to 
submission of additional or supplementary policy proposals.  Current 
discussions have already covered many of the topics that we raised.

I have incorporated feedback on 2019-2 on PPML up to 1315 EST today.

I'll be incorporating feedback on this thread into our working documents on 
Friday, March 15th, so please expedite your thoughtful responses.

Anticipating at least one complaint (and suffering from lack of confidence that 
PPML won’t strip the RTF and render something entirely incomprehensible) please 
accept my apologies for non-pure-ASCII email and accept my pointer to this 
document in PDF format at 
https://technotes.seastrom.com/assets/2019-03-07-NRPM-4-1-8-Policy-Actions/2019-03-07-NRPM-4-1-8-Policy-Actions.pdf

Kind regards,

-r

 


Problem Space


1.      Returned and/or reclaimed number resources, are stranded at ARIN absent 
policy enabling their distribution. These resources are of two primary sources: 
organizations quitclaiming (voluntarily surrendering) prefixes and number 
resources that are revoked due to non-compliance with the RSA (primarily 
non-payment of fees).
2.      This pool must be drained in an orderly fashion. This must be 
sustainable to provide a buffer/queue system to manage any future free pools, 
with an orderly in/out sequence. At some point the demand vs return rate of 
IPv4 space will be such that we transition rapidly back and forth between 
having an ephemeral free pool and a waiting list and it is important to 
consider fair and impartial issue of number resources under that circumstance.
3.      A non-trivial fraction of the space issued under the 4.1.8 waitlist 
policy is "flipped" as soon as it becomes eligible, after the current hold down 
of 1 year post-issue. This problem seems exacerbated in larger allocations 
(shorter prefixes). Conversations in the wake of 4.1.8’s suspension (both 
private and public) suggest that the now-suspended waiting list policy is not 
aligned with its original intent.
4.      Policy action taken could reduce the incentive for fraudulent 
applications or making misrepresentations to registration services (which have 
existed since time immemorial). The observed flipping pattern raises serious 
concerns about the legitimacy of the "documented need" attached to some 
applications.
5.      The ARIN community established the waiting list intentionally without 
many controls with the expectation that we would need to adjust it over time 
with the benefit of experience and observation.
6.      While by no means a universal sentiment, several people have raised the 
issue of serving organizations that are unable to otherwise participate in the 
transfer market in a meaningful way. This implies certain NGOs, smaller 
organizations, new entrants, etc.

Discussion:

*       While I generally agree with the problem statements...  I'm not sure 
they are all problems that the wait-list policy update needs to "solve".  
Specifically problem 6.  While I think its nice that the wait-list is available 
to organizations which may not have the funds available to get a block on the 
market.  The “economist” in me says that if that an organization really needs 
IPv4 addressing then they will put their resources (dollars) to work to find a 
block (even via transfer).  If they don't really "need" a block, they will 
likely use (borrow/lease) someone else's or substitute NAT.   And that might 
just be OK.
*       While all things being equal, I could potentially agree, the reality is 
that these blocks aren't on the transfer market for whatever reason and I don't 
think ARIN should be in the business of providing opportunities for others to 
monetize them (isn't that the whole issue that caused the policy suspension in 
the first place?). Thus, I think that the class most in need and least likely 
to look at monetization is, in fact, the groups identified in item 6 above.
*       a meta-issue to consider is whether there should be any difference 
between IPv4 issuance via waiting list and IPv4 issuance via NRPM 4.2/4.3 when 
resources are available; i.e.  should NRPM 4.1.8 simply read that ARIN will 
maintain an ordered waiting list when resources are not available and fullfil 
in that order once space becomes available – and then simplified criteria for 
how a party receives IP space is put in NRPM 4.2 and NRPM 4.3.  If this is not 
the strategy taken, then a party put on the waiting list last week and then 
receiving space today (due to new influx of resources) will be treated quite 
differently under a revised 4.1.8 policy than parties applying and issued space 
from the replenished pool tomorrow.  Such oscillations are nethier predictable 
nor particularly equitable, and yet will be a reality (particular if the 
resources issued under revised waiting list policy are limited in size.)   This 
is another way of characterizing problem #2 above - differences between waiting 
list policy and "regular" issuance only increase the inequity and thus morst of 
the policy options on the menu below probablem shouldn't indicate they address 
statement #2... 
*       An alternative approach to avoid oscillation would be to make the gate 
into waiting list behavior a one-way gate. Once the waiting list is activated, 
even if the queue is drained, all new applications would be placed on the 
waiting list and immediately filled if possible. 
*        Certainly a possibility (one way gate... all new applications would be 
placed on the waiting list and immediately filled if possible.) for addressing 
the issue. 
*       I could get behind part of the fix eliminating the possibility of 
oscillation by the wait list becoming the universal front door; everyone in on 
the wait list all the time and just the wait is short when resources are 
plentiful.
*       It is not reasonable to ask the Community to weigh in policies based on 
allegations of fraud without data from Registration Services ( + 3)
*       Summary data posted to PPML in Message-ID: 
<[email protected] 
<mailto:[email protected]> >
*       Sweeting's Policy Experience Report from ARIN 42 in Vancouveris 
available in the following locations:

*       Transcript:  
https://www.arin.net/vault/participate/meetings/reports/ARIN_42/ppm1_transcript.html#anchor_5
 
*       Youtube: https://www.youtube.com/watch?v=MJHgs4wWO58
*       Presentation: 
https://www.arin.net/vault/participate/meetings/reports/ARIN_42/PDF/PPM/sweeting-policy.pdf
 

*        






Potential Policy Actions


For brevity, the reclaimed or returned IPv4 resources received by ARIN 
currently handled by the waitlist is referred to below as “4.1.8 space”.

 

 


Policy Menu for discussion


A.      Regardless of any other policy options pursued for 4.1.8 space, we will 
need to determine the fate of the current wait list entries. Do we use the new 
waitlist policy as a forcing function (i.e. if there is a change in maximum 
prefix size do we trim all existing justifications to be limited as under the 
new policy), or do we grandfather prefix length, grants per org, etc under the 
policy in effect as of the suspension date of the 4.1.8 policy (Wednesday, 16 
January 2019) or the publication of the Board minutes (7 February 2019)? Other 
cutoff dates seem less fair.

a.      Addresses: 1, 2, 5 plus overlay on particular policy actions
b.      Does not address: overlay on particular policy actions
c.      Discussion

*       If "new policy applies to all unfilled requests". If an org takes a 
haircut on what they can get from the waiting list, what happens to the 
remainder? Do they lose it? Should they be able to turn it into a preapproval 
for 8.3?  We believe that there are folks on the list *right now*, in the 
larger allocation space, who are likely to "flip" space.  Is allowing them to 
keep their place in line fair?
*       Agreed. Given some existing applications could be fraudsters, the new 
policy possibly should apply to existing applicants; OTOH new listers are the 
only ones who knew the rules were changing. We should allow folks current on 
the list who do not wish to participate in the new policy (fees, additional 
paperwork, whatever) the option to delist without issue. Given some of the 
options (eg, only one chance, no if you have other resources, etc) we would be 
forcing many off the list regardless.
*       reducing the size allocated will likely reduce the fraud potential.  I 
feel that those on the list should be given the opportunity to keep their place 
on the list (assuming we keep the list, but their max size would be reduced to 
the new agreed max size.
*       Tackling this first seems cart before the horse to me. I think that 
what we decide on the other topics (how the policy actually changes) should 
inform what we determine will be most fair to those on the existing waiting 
list. In terms of if we reduce the maximum prefix size, then I would suggest 
that perhaps we could pursue a compromise where those on the waiting list prior 
to suspension aren't completely grandfathered, but are permitted a somewhat 
(perhaps 2 bits or x4) larger maximum prefix size than the new limit. (e.g. if 
we take the new limit to /24, those grandfathered would be eligible up to a 
/22).
*       It is a meta topic; these are only ordinal to be managable, feel free 
to skip consideration until we assess the rest, but IMO that goes against the 
grain of the desire to think things through well before discussing with the 
community. As far as prefix size, I'm 100% against adding one-off bit-math 
exception complexity. Simple grandfather or not is a reasonable discussion to 
have but making a temporary new rule category is a bad idea.

B.      4.1.8 space to be held in a “replenishment pool” for 4.4/4.10 (or 
similar)

a.      Addresses: 1, 2, 3, 5
b.      Does not address: 6
c.      Discussion

*       Depending upon the expansion of “4.4/4.10 (or similar)” may or may not 
address item 4. Highminded and while “orderly” (2) I think would result in very 
little payout, eventually not addressing the pile (1). I doubt we’ll see 
community support.
*       Unlikely to see community support; also sends wrong message about the 
future of IPv4.
*       I'd suggest that using these blocks for 4.4/4.10 is possibly providing 
a way for ARIN to serve the "small" members of the community by creating a 
larger pool of small blocks that could be used for these new entrants.  Is it a 
lot of space, no, but you can do a lot with a /24.
*       I believe that this would create new incentives for fraud in the 4.10 
space which is already strongly incentivized towards fraud (almost with 
encouragement from the ARIN staff via a very liberal interpretation of 
"transition").

C.      Distribute 4.1.8 space with a one time issuance surcharge attached - 
"the board should consider implementing a fee structure."

a.      Addresses: 1, 2, 5
b.      Does not address: 6
c.      Discussion

*       Elevated fee for getting space from the waiting list. Possibly more 
fair than putting it on the market. Definitely better optics. But if the target 
recipients are organizations that are otherwise unable to participate in the 
transfer market, then at least some organizations will be priced out.
*       Possibly address items 3 & 4, but I’m concerned that the fee would have 
to be significantto outweigh the ROI for people already willing to both wait 
and risk their existing & future relationship with ARIN. Might be useful in 
combination with other actions.
*       I think the negatives of this approach for the classs defined in 6 
outweigh any possible positives for 1, 2, 5. I do not believe it will do 
anything for 3, 4 unless the fees are so high as to approach parity with the 
transfer market. I nominate this one for the considered and rejected bucket.

D.      Make 4.1.8 space non-transferrable (must return to ARIN).

a.      Addresses: 1, 2, 3, 5
b.      Does not address: 6
c.      Discussion

*       Does this mean just no 8.3? How about 8.2? Disadvantage - basically 
makes "off the books" transfers the only way to transfer the space. We have put 
a lot of effort into making the database right. This creates the problem that 
we have been trying to avoid.
*       Given the waiting list isn’t the only path to get v4 I’m not certain 
the risk of the underground market is very high. Were we back in the times 
before the transfer market, I would solidly agree. However I don’t think this 
would gain community support unless it was in combination with other actions. 
Given that response, whether or not item 4 is addressed seems to be in play.
*       non-transferable still means people can lease/reallocate. 
*       Let's be clear about this... I believe it should mean (no 8.3) and  no 
(8.4 except in case where would otherwise qualify under 8.2). Perhaps some 
additional hoops should be added for 8.2/8.2-related 8.4 (possibly restore the 
resource review and reclamation provisions where 4.1.8 space is involved?) . 
*       I don't see this as not adressing 6. I also think it strongly addresses 
4. It might not reduce incentives for fraudulent transfers of space received 
under this policy, but it does at least reduce the incentives to apply 
fraudulently in the first place. I would say Addresses: 1, 2, 3, 4, 5, 6 (to 
varying extents).
*       The reason I put 'does not address 6' is it does not specifically favor 
or disfavour.
*       I agree that the reduction of the incentives to apply and flip will be 
greatly reduced. I am concerned with M&A transfers as many times, equipment 
gets moved over and the IPs come along with that. Giving space back that 
happened to be from the waiting list at some point would impact companies 
greatly. There is an actual need for that space and not a resource flip for 
money. Reallocations would be allowed so I see no issues in that regard. This 
in conjunction with smaller aggs from the waiting list would probably give us 
the a very good start. 

E.      Longer holddown period for transfer after receiving 4.1.8 space

a.      Addresses: 1, 2, 5
b.      Does not address: 6
c.      Discussion

*       Could be a disincentive for people who are gaming the system for 
financial gain. Might just end up turning transfers into LOAs and rentals. In 
the interests of database accuracy we still need to allow 8.2
*       I have the same concerns with items 3 & 4 as with policy option for 
“suggest fees to board”. We have a serious unknown WRT the level of 
disincentive needed. Might be useful in combination.
*       I think this is just a less-effective alternative to D. I nominate this 
one for the considered and rejected bucket on that basis.
*       If we are talking about 2+ years then I think we'd see an impact as 
companies would gamble the cost of the IP but I like option D better. 

F.      Only one 4.1.8 application / grant per applicant (no getting back in 
line/one bite at the apple)

a.      Addresses: 1, 2, 5, 6
b.      Does not address: 3, 4
c.      Discussion

*       Increases the overhead for milking the system (creating multiple 
corporate entities, etc) but this may not be as much overhead as we suppose; 
legitimate businesses spin up operating entities at the drop of a hat. Sends 
signal about "new entrants". Creates the problem that RIPE NCC has right now - 
because they did that for their final /8, there are a lot of shell LIRs that 
were created for the sole purpose of getting the space.
*       Similar to options for “suggest fees to board” & long holddown”, I 
think this only moves the line for fraud, and not very far. We should not 
ignore RIPE’s shell LIR experience and I don’t think their fix would apply for 
us. I don’t think this is a useful lever in conjunction with other options.
*       I think this is a high staff impact low fraudster impact mechanism for 
moving the bar on fraud only slightly. As such, I nominate it for the 
considered and rejected bucket.

G.      No 4.1.8 applications for any existing V4 resource holder

a.      Addresses: 1, 2, 5, 6
b.      Does not address: 3, 4
c.      Discussion

*       Same as “no getting back in line” - creating shell organizations for 
the purpose of getting space from ARIN. TODO - Get quotes from 
https://www.delreg.com <https://www.delreg.com/> for fixed and variable costs 
of setting up a shell corporation and add in the minimum documentation overhead 
to make a model.
*       I’m sure I could spend time finding current rates, but here’s 2015 
data, that sticks to my “very low” answer 
https://blog.corpnet.com/fees-incorporating-state-understand-costs-corporation/.
 I don’t think the community would support this nor that it would be meaningful 
in conjunction with other actions. I think this should be demoted to 
“considered and rejected”.
*       Last year, I needed to spin up an entity. I hired a service to do all 
of it beginning to end for $150 and about 15 minutes of filling out web forms. 
(If I had known what I was doing with the web forms, I probably could have done 
it in more like 2 minutes).
*       To me, this is just a more obnoxious form of F and I believe it should 
suffer the same suggested fate.
*       FWIW, APNIC is considering abolishment of their waiting list. Since 
they had a soft-landing policy, they are considering reserving reclaimed 
resources for new entrants only, similar to this option: 
https://www.apnic.net/community/policy/proposals/prop-129.

H.      Additional officer attestation at time of being placed on waiting list 
(or at time of issuance? or both?), under penalty of perjury of lack of 
relationship to any other organization that is on the waiting list.

a.      Addresses: 1, 2, 4
b.      Does not address: 3, 5, 6
c.      Discussion

*       This is out of the purview of the AC as it does not relate directly to 
number policy however it may be part of our guidance to the Board that they 
discuss such a measure with Counsel.  
*       I don’t know how much of the fraud this would actual cut into, being a 
reference to other entities on the list.
*       Rather than reference other entities on the list, I would suggest it 
reference other entities which have received 4.1.8 waiting list approval and/or 
space.
*       It might not reduce fraud by much (or it might reduce it a lot). 
However, it seems very low staff overhead with good potential. I think combined 
with other options, notably {D, I.(J, K, or L)}
*       My understanding is that formal attestations increase the hooks for 
hanging fraud-related complaints on should they be egregious enough to send to 
LE etc, so it may be inefficient at cutting into fraud yet still desirable.

I.      Reduce maximum allocation for 4.1.8 space (general action - subsequent 
are more specific)

a.      Addresses: 1, 2, 4, 5, 6
b.      Does not address:
c.      Discussion

*        

*       Advantages

*       Increases the number of organizations that can be served.
*       Lessens the impact of "loophole applications" that make it through
*       The necessity of repeated transactions (grant events) in order to amass 
a significant amount of space increases the paper trail for detecting 
undesirable behavior.

*       Disadvantages

*       Some otherwise deserving organizations will not be able to get all the 
space they can justify regardless of how long they are willing to wait.
*       More grant events (i.e. more number blocks being handed out) and 
attendant shortening of waiting period may increase incidence of loophole or 
fraudulent applications.
*       Increased workload on Registration Services (operational issue outside 
of the scope of our policy discussion)

*       I think this is a required piece of any solution. Reduces but wouldn’t 
eliminate 3
*       I also think this is a required part of any solution as long as the 
solution isn't "transfer at market price"
*       Agree this is the single best action we can take and is likely improved 
by combining with other action(s) (notably D)
*       Per item 6, I'm less concerned about deserving organizations getting 
limited space.
*       While it does shorten the "waiting period", it wouldn't remove the 3 
month hold-down in the policy (unless we did so deliberately). We could combine 
with (E) to further address the "attendant shortening" issue.
*       Agree with the comments above that this needs to be part of the 
solution but not the only solution

J.      Reduce maximum 4.1.8 allocations to /24 (or more likely "minimum 
allocation as elsewhere in policy")

a.      Addresses: 1, 2, 3, 4, 5, 6
b.      Does not address: n/a
c.      Discussion

*        

*       Advantages

*       Serves the most number of organizations
*       Maximally reduces fraud incentive, particularly when combined with "one 
grant per applicant"
*       Maximizes grant events (see I.c.c above) for detecting activity by bad 
actors
*       RIPE is about to do it (see RIPE-2019-02:Reducing IPv4 Allocations to a 
/24) 
https://www.ripe.net/participate/policies/proposals/2019-02https://www.ripe.net/ripe/mail/archives/address-policy-wg/2019-February/012623.html

*       Disadvantages

*       Maximizes the number of organizations that could justify more yet are 
shortchanged

*       I think this is the biggest bang for our buck, solo or in combination. 
This and “recommend fees” and [another option] would be best IMO.
*       If we are going to reduce to a /24 why not just put these in the 4.10 
pool, then we give people a carrot to also do the right thing and get some v6 
to bootstrap their organization
*       Re 4.10 pool, That's not the original intent of 4.10, though it is how 
staff is currently advertising it. IMHO, we should move away from 4.10 being 
used for v4 for people who joined the v6 club and go back to actually requiring 
4.10 space be used for actual transition purposes.
*       I sort of agree but I feel that it might be more bang than is needed 
and that the downside to any but the smallest of the small may exceed the 
benefit.
*       This or K in combination with D would be my suggestion as well. I'm on 
the fence for /24 vs /22 as there are certainly pluses and minus to each 
approach. Also making specified transfered not able to use wait list space will 
really disincentivize the flippers. 

K.      Reduce maximum 4.1.8 allocations to /22

a.      Addresses: 1, 2, 5
b.      Does not address: 3, 4, 6
c.      Discussion

*        

*       Still substantially no questionable applications at this level under 
today's policies
*       Able to serve a greater diversity of organizations that could justify 
more space than a /24 (think WISP, boutique cloud providers).
*       RIPE has had documented experience with a /22 policy along with 
negligible amounts of documentation (pretty much a gimme for any new LIR). Note 
that ARIN != RIPE and we are not discussing getting rid of needs basis for 
this. Whether the RIPE experience counts as a success story is likely in the 
eyes of the beholder, but we have something to calibrate our expectations 
against.

*       I think the RIPE experience pushes away from this, and that the line 
for fraud would just move here as a /22 is still highly valuable.
*        /22 seems like a good place to start the discussion on a new max block 
size
*       I agree with the /22.
*       Will the fraud line move here? Possibly, but the incentive to overhead 
ratio changes dramatically (1 application + 1 year = /16 = roughly $1,310,570 
($20/address - $150 ARIN fee) vs. 64 Entity spinups + 64 applications + 1 year 
= badly fragmented /16 equivalent = roughly $1,301,120 ($20/address - 64*$150 
ARIN fees)
*       I believe this combined with D is probably our best choice.
*       Increased number of transactions going past Registration Services is 
good for discerning patterns.
*       if increased transactions are good, then isn't that an even better 
argument for (J) and moving to /24s?
*       I'm having trouble squaring that 'overhead' and your comments under (G) 
- 64 orgs per your experience would be under 10k so the profit is barely 
touched (1.29M vs 1.31M). I have neverseen shell creation/shelf activation as a 
significant barrier; while they seem weird to us as engineers, criminal 
enterprises are very very used to them being a required part of doing illegal 
business.
*       I believe this or J in combination with D is the best choice. I could 
probably be convinced either way on /24 or /22. 
*       RIPE's experience has been a train wreck and organizations have 
plundered the /22 space to where certain recipients have amassed in the low 
hundreds of /22s each.
*       Not fair to equate RIPE's experience with /22s.  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.

L.      Reduce maximum 4.1.8 allocations to /21 or /20

a.      Addresses: 1, 2, 5
b.      Does not address: 3, 4, 6
c.      Discussion

*       :

*       Advantages

*       Still substantially no questionable applications at this level under 
today's policies

*       Disadvantages

*       at 8 or 16x the payout per transaction, a tempting place for attempted 
loopholing to land.
*       Nevertheless, a loophole /20 consumes 1/16 the resources of a loophole 
/16 (most of these are in the /17-/18 range but still...)

*        I don’t think this level of incrementalism will buy us much of 
anything.
*       /22 seems like a good place to start the discussion on a new max block 
size
*       I don't believe this gains us anything as this isn't small enough. 
Smaller allocations serve more members of the ARIN community. I'm more 
comfortable with a /22 or /24

 


Policy options considered and rejected


A.      No longer reissue 4.1.8 space (i.e. continue waiting list suspension 
indefinitely)

a.      Addresses: 3, 4, 5
b.      Does not address: 1, 2, 6
c.      Discussion

*       Functionally equivalent to eliminating the waiting list. Unlikely to 
get community support and with the (actually a little surprising) velocity of 
space reclamation ARIN will eventually end up with a non-trivial amount of 
space.
*       firmly agreed.
*       I wouldn't reject this one so quickly; it doesn't make any sense if we 
sit on the space, but if it could be redeployed (my favorite option: use as 
supply for crit infra allocations), this could be a viable path.
*       The counterpoint to that preference is that the current CI pool will 
last much longer than any of us want IPv4 to continue to be CI.

B.      ARIN Stops accepting applications for 4.1.8 space, only supporting 
transfer (8.x), critical infrastructure (4.4), or IPv6 transition (4.10) 
policies

a.      Addresses: 3, 4, 5
b.      Does not address: 1, 2, 6
c.      Discussion

*       Closes down the entry side of the policy, not the issuance side. Net 
result ends up being the same - can't have requests for the space, so it will 
pile up.
*       firmly agreed.
*       This is smilar to the B above, so why is this specifically rejected it 
seems similar.

C.      Prioritize "not for profit" organizations’ applications for 4.1.8 
space, potentially to the exclusion of all others.

a.      Addresses: 1, 2, 5, 6
b.      Does not address: 3, 4
c.      Discussion

*       such status is merely an artifact of national tax laws; they say 
nothing about budgets or size.
*       agreed; would include superPACs in the US.
*       I think there is value in considering this as an option for discussion. 
 I suspect it doesn't go anywhere, but I think its worth while.
*       Could limit it to "organizations eligible to receive tax deductible 
donations" which would eliminate PACs (including superPACs). Would still allow 
some very large organizations (e.g. Red Cross, UNICEF), but I'm not sure that's 
entirely bad if we include the size limits under discussion as subcategories 
for I (especially J or K).
*       I agree that this should be modified and discussed, not rejected out of 
hand.
*        "tax deductiblity" is a rathole you don't want to go down unless you 
want to be incredibly US/Canada-centric about it (which I don't).
*       I don't see how this could be tuned into effectiveness across our 
entire service area, and strongly underscore the point that scope and budget of 
"not for profit" doesn't limit to 'good works' organizations and for that 
matter expressly excludes B corporations.
*       I take issue with characterizing any of this work done as 'out of 
hand'; the text here is a summary and tiny fraction of the discussions. The 
only "quick" decision was 'business as usual' being a non-starter.

D.      Return to waiting list Business As Usual (Status quo - we decide that 
we are OK with continuing on the previous path)

a.      Addresses: 1, 2
b.      Does not address: 3, 4, 5, 6
c.      Discussion

*       In view of the circumstances that caused the Board to suspend the 
policy, I don’t believe this is viable.
*       agreed.
*       I agree we can reject this option
*       Given the board's suspension of the policy, I doubt such an action 
would be favored by the board. I agree this is not a viable option.
*       Agreed.

E.      Distribute 4.1.8 space via the transfer market

a.      Addresses: 1, 2, 3, 4, 5
b.      Does not address: 6
c.      Discussion

*       Obviously this is 8.3 not 8.2  :) Money would go to ARIN, is there 
something that this money could go to? Membership cost reduction? Fellowship? 
Education? Bad optics because it looks like ARIN is incented to be aggressive 
about reclaiming space.
*       Actually addresses many of the currently-defined issues, but it smells 
bad to me.
*       This is similar to setting of a fee for wait-list allocations, only 
that it is done with the assistance of a 3rd party setting the price.  I prefer 
a simple fee which would be adjusted annually which is a discount from the 
anticipated market price.
*       The boquet of limburger with the appearance of Medusa... Yeah, you are 
right about the optics and aroma.
*       I'm not so skeptical that this approach should be rejected. 
Removing/reducing the profit motive for fraudulent applications would be an 
effective path to curbing the abuse, and I feel that at least this should be 
floated as an option with the community.
*       removing the profit motive this way is very punitive to organizations 
that are legitimately on the waiting list. I'd hate to see ARIN end up chasing 
its tail the way ICANN is with their new domain make money fast slush fund.
*       At least three strong statements of support on PPML for this.

F.      Reduce maximum 4.1.8 allocation to /19 or /18

a.      Addresses: 1, 2, 5
b.      Does not address: 3, 4, 6
c.      Discussion

*        

*       Disadvantages

*       Doesn't really move the needle when we are seeing questionable 
applications in this range already
*       More a BAU policy than a smaller maximum allocation policy (current max 
waitlist is not codified in 4.1.8. but as a practical manner tops out around a 
/16 or maybe a /15?).
*       Extremely large waitlist prefixes that take literally years to bear 
fruit cause one to question the legitimacy of the "need" that was documented to 
ARIN.

*       again, minor incrementalism that if anything will teach the fraudsters 
how to adapt.
*       limited value in the promotion of larger blocks.  If the community 
really wants larger blocks they will say so when we publish the new max size of 
"/22"

 

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