Agree with Brian and Owen.  Also oppose this policy proposal.

Sent from my iPad

> On Aug 16, 2019, at 10:50 AM, Brian Jones <[email protected]> wrote:
> 
> I oppose this policy as written, mainly for the reasons Owen outlines. This 
> would eliminate the wait list and possibly lock up useful resources now that 
> may not be as relevant or useful in the future. It does also seem contrary to 
> ARIN's mission in my view. 
> 
> —
> Brian Jones, CSP, CSM, CSPO
> NIS Virginia Tech
> [email protected]
> 
> 
>> On Thu, Aug 15, 2019 at 5:10 PM Owen DeLong <[email protected]> wrote:
>> Really, it seems to me that this proposal is another attempt at eliminating 
>> the waiting list for unmet requests.
>> 
>> The first attempt (ARIN auctions the space) met with resistance from ARIN’s 
>> legal team (for good reason), so now this attempts to sequester the space 
>> where it will be hard to distribute rather than allowing the waiting list to 
>> have any potential to compete with the transfer market.
>> 
>> The proposed targets (4.4 and 4.10 pools) are well stocked and unlikely to 
>> run out in any useful IPv4 lifetime.
>> 
>> As such, restocking them from returned space strikes me as just a way to 
>> sequester this space where it cannot be used.
>> 
>> IMHO, this is counter to ARIN’s mission and should not be allowed.
>> 
>> I oppose the policy as written and as proposed to be amended.
>> 
>> Owen
>> 
>> 
>>> On Aug 15, 2019, at 13:55 , WOOD Alison * DAS via ARIN-PPML 
>>> <[email protected]> wrote:
>>> 
>>> Thank you for the continued input on this draft policy proposal.
>>>  
>>> I will be updating the text of the draft policy to include both 4.4 and 
>>> 4.10 pools.  Point of information, the 4.4 pool currently has approximately 
>>> 391 /24’s and 4.10 has approximately 15,753 /24’s available and are not 
>>> estimated to run out in the next five years.
>>>  
>>> Please keep your feedback coming, it is very helpful for the council.
>>>  
>>> -Alison
>>>  
>>> From: ARIN-PPML [mailto:[email protected]] On Behalf Of Fernando 
>>> Frediani
>>> Sent: Tuesday, July 30, 2019 6:44 AM
>>> To: arin-ppml <[email protected]>
>>> Subject: Re: [arin-ppml] Draft Policy ARIN-2019-17: Returned Addresses to 
>>> the 4.10 Reserved Pool
>>>  
>>> The point is that you treating IP marketing as something 'natural' or a 
>>> 'default route' which it is not and can never be. Natural is to receive 
>>> some addresses from the RIR in first place so they are treated as anyone 
>>> else was in the past and have a chance to exist in the Internet with same 
>>> conditions as all others. From that if they need extra space then fine to 
>>> seek for alternative ways.
>>> 
>>> I don't think a new entrants would automatically qualify for 4.10 in all 
>>> cases therefore any space left should be targeted also to them as well to 
>>> IPv6 transition and critical infrastructure. Otherwise the community will 
>>> be creating an artificial barrier to them in order to favor the IP market 
>>> while the RIR still has IPv4 space available for them.
>>> 
>>> Fernando
>>> 
>>> On 30/07/2019 10:30, Tom Fantacone wrote:
>>> I would think that the majority of new entrants would need at least some 
>>> allocation to help with IPv6 transition and would qualify for addresses 
>>> from the 4.10 pool.  Depending on what they receive from that pool and 
>>> when, they may not qualify for additional waiting list addresses and would 
>>> have to go to the transfer market for additional IPv4 space anyway.  Those 
>>> that don't qualify under 4.10 can still get smaller IPv4 blocks on the 
>>> transfer market readily, and the cost for blocks in the /24-/22 range is 
>>> not prohibitive.  Certainly an organization seeking a small IPv4 block for 
>>> multi-homing or other purposes is better off spending a few thousand 
>>> dollars to purchase a range than waiting a year on the waiting list to put 
>>> their plans in motion.
>>> 
>>> Note that while RIPE does not have a reserve pool specifically for IPv6 
>>> transition, the expectation of their final /8 policy was to allow new 
>>> entrants access to IPv4 to assist in this transition.  In reality, it 
>>> didn't work out that way and most of the /22 allocations to new LIRs from 
>>> the final /8 were to existing organizations who spun up new, related 
>>> entities in order to increase their IPv4 holdings:
>>> 
>>> https://labs.ripe.net/Members/wilhelm/so-long-last-8-and-thanks-for-all-the-allocations
>>> 
>>> I'm also sympathetic to new entrants, but don't see the current waiting 
>>> list as a great help to them vs. the 4.10 pool or the transfer market, both 
>>> of which allow you your allocation in a timely fashion.
>>> 
>>> Best Regards,
>>> 
>>> Tom Fantacone
>>> 
>>>  
>>> ---- On Mon, 29 Jul 2019 11:39:32 -0400 Fernando Frediani 
>>> <[email protected]> wrote ----
>>>  
>>> I find it interesting the idea of privileging the pool dedicated to 
>>> facilitate IPv6 Deployment and I also agree with the comments below in 
>>> the sense that it's not very beneficial do most ARIN members due to max 
>>> size, /22, cannot be holding more than a /20.
>>> 
>>> However one point I couldn't identify is where the new entrants stand in 
>>> this new possible scenario ? Will they only be able to apply under the 
>>> 4.10 reserved pool ? If so for a access/broadband ISPs may be easier to 
>>> fit, but not necessarily for other scenarios and types of ISPs. 
>>> Therefore if I didn't miss anything these returned addresses should also 
>>> be able to go to new entrants, not only to 4.10 reserved pool conditions.
>>> 
>>> Best regards
>>> Fernando Frediani
>>> 
>>> On 25/07/2019 17:32, Tom Fantacone wrote:
>>> > I found the wording of the Problem Statement on this one a bit 
>>> > confusing. However, after deciphering the effect of the actual policy 
>>> > change I support it.
>>> >
>>> > Essentially, all returned IPv4 space will no longer go to the waiting 
>>> > list but will supplement the 4.10 reserved pool used to enhance IPv6 
>>> > deployment.  This essentially kills off the waiting list.
>>> >
>>> > The recent restrictions placed on the waiting list to reduce fraud 
>>> > have hobbled it to the point where it's not very beneficial to most 
>>> > ARIN members.  (Max size, /22, cannot be holding more than a /20).  
>>> > It's essentially only useful to new entrants, but those that go on it 
>>> > still have to wait many months to receive their small allocation.  If 
>>> > they justify need now, but have to wait that long, how critical is 
>>> > their need if they're willing to wait that long?  Small blocks are not 
>>> > terribly expensive and can be quickly gotten on the transfer market.  
>>> > I can understand waiting that long for a large block needed for a 
>>> > longer term project due to prohibitive cost, but I don't see a great 
>>> > benefit to the waiting list as it stands.
>>> >
>>> > Also, if there's any fraud left on the waiting list, this would kill it.
>>> >
>>> > I would hope, however, that if implemented, those currently on the 
>>> > waiting list would be grandfathered in.  I do think some entities with 
>>> > legitimate need got burned on the last change made to the waiting list.
>>> >
>>> > At 04:05 PM 7/23/2019, ARIN wrote:
>>> >> On 18 July 2019, the ARIN Advisory Council (AC) accepted 
>>> >> "ARIN-prop-276: Returned Addresses to the 4.10 Reserved Pool" as a 
>>> >> Draft Policy.
>>> >>
>>> >> Draft Policy ARIN-2019-17 is below and can be found at:
>>> >>
>>> >> https://www.arin.net/participate/policy/drafts/2019_17/
>>> >>
>>> >> 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/participate/policy/pdp/
>>> >>
>>> >> Draft Policies and Proposals under discussion can be found at:
>>> >> https://www.arin.net/participate/policy/drafts/
>>> >>
>>> >> Regards,
>>> >>
>>> >> Sean Hopkins
>>> >> Policy Analyst
>>> >> American Registry for Internet Numbers (ARIN)
>>> >>
>>> >> Draft Policy ARIN-2019-17: Returned Addresses to the 4.10 Reserved Pool
>>> >>
>>> >> Problem Statement:
>>> >>
>>> >> An inconsistent and unpredictable stream of address space is an 
>>> >> unsuitable method of populating the waiting list (4.1.8.1) and 
>>> >> fulfilling subsequent requests.
>>> >>
>>> >> Policy statement:
>>> >>
>>> >> Change "4.10. Dedicated IPv4 Block to Facilitate IPv6 Deployment" to 
>>> >> "4.10 Dedicated IPv4 Pool to Facilitate IPv6 Deployment"
>>> >>
>>> >> Change" When ARIN receives its last /8 IPv4 allocation from IANA, a 
>>> >> contiguous /10 IPv4 block will be set aside and dedicated to 
>>> >> facilitate IPv6 deployment. Allocations and assignments from this 
>>> >> block " to "In addition to the contiguous /10 IPv4 block set aside 
>>> >> and dedicated to facilitate IPv6 deployment, all returns and 
>>> >> revocations of IPv4  blocks will be added to the pool of space 
>>> >> dedicated to the facilitation of IPv6 deployment. Allocations and 
>>> >> assignments from this pool "
>>> >>
>>> >> Change "This block will be subject to a minimum size allocation of 
>>> >> /28 and a maximum size allocation of /24. ARIN should use sparse 
>>> >> allocation when possible within that /10 block." to "This pool will 
>>> >> be subject to a minimum size allocation of /28 and a maximum sized 
>>> >> allocation of /24. ARIN should use sparse allocation when possible 
>>> >> within the pool."
>>> >>
>>> >> Comments:
>>> >>
>>> >> Timetable for implementation: Immediate
>>> >> _______________________________________________
>>> >> ARIN-PPML
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>>> >
>>> >
>>> > _______________________________________________
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>>>  
>>>  
>>> _______________________________________________
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>> 
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