My biggest objection is limiting of an organization to a specific size. Although I realize ARIN can change policies, I believe if an organization has in good faith followed the existing rules and been put on the waiting list that they should not come away with nothing especially those that were on the list before the current suspension began. If those organizations were watching the list, and moving up, it is likely that they have made business decisions based on that data with the assumption that they would get an allocation at some point. I believe the proposed allocation limit is being discussed as a method to discourage bad actors from receiving address space and then just holding them in order to sell them at a profit once they are allowed, but as you stated “the waiting list is primarily a mechanism to ensure resources are not stuck at ARIN”, that has nothing to do with the size of an organization requesting resources. I can support an allocation limit per allocation, and even extending the time an organization must wait before getting back on the wait list. That being said, if an organization is willing to wait on the list until the resources are available then they should get the allocation.
Thanks, Tom Pruitt Network Engineer Stratus Networks [stratus_networks_logo_FINAL] From: David Farmer <far...@umn.edu> Sent: Friday, May 10, 2019 3:44 PM To: Tom Pruitt <tpru...@stratusnet.com> Cc: arin-ppml@arin.net Subject: Re: [arin-ppml] Fwd: Advisory Council Recommendation Regarding NRPM 4.1.8. Unmet Requests If /20 is too small is their another size you would propose? a /19 or a /18 maybe? Do you have an argument for why that is the right number? When the AC looked at this there was strong support for limiting the size of the organization that could qualify to ensure these resources went to smaller organizations. But there were varying opinions on what that size should be, /20 was just the option with the most support amongst the AC. This formulation also provides a limit on how many times an organization can go back to the waiting list, allowing smaller organizations more times to return to the waiting list, while limiting lager organization to fewer times to return to the waiting list. And organizations that already have more than a /20 must go to the market. A /20 limit, gives a new organization (with no resources) the opportunity receive up to 5 allocations from the waiting list if they got a /22 each time. A /19 limit would allow a new ISP up to 9 allocations if they got a /22 each time. A /18 limit would allow a new ISP up to 17 allocations if they got a /22 each time. Please realize the waiting list is primarily a mechanism to ensure resources are not stuck at ARIN, it should not be seen as a reliable means of obtaining resources. Thanks On Fri, May 10, 2019 at 2:45 PM Tom Pruitt <tpru...@stratusnet.com<mailto:tpru...@stratusnet.com>> wrote: I do not support the new text, specifically the limit of a /20 per organization. The limiting of an organization to an aggregate of a /20 is a huge hinderance of the ability of a smaller ISP to compete. A smaller ISP that can win business on service and cost could lose that same business due to simply recouping the IPv4 costs. Large ISPs will often give the IPs away to win the business, and it costs them nothing as they received their IPV4 space for free. Additionally, many smaller ISPs operate in outlying areas where IPv6 adoption will likely be slow, which will also hinder their ability to push IPv6. I’m not sure at what point an organization becomes “large”, but the smaller organizations are the ones that will be hurt by this limit. What happens to organizations that are currently on the wait list that have an aggregate of a /20 or more? Do they still get a /22. Some of those organizations have been on the list for over a year. Assuming they played by the rules and made decisions based on the assumption that they would get an allotment of IPv4 addresses, denying them any addresses after they have waited a year or more could be very detrimental to them. These policy changes and decisions affect the smaller entities greatly, and they need some clarity. Thanks, Tom Pruitt Network Engineer Stratus Networks [stratus_networks_logo_FINAL] From: ARIN-PPML <arin-ppml-boun...@arin.net<mailto:arin-ppml-boun...@arin.net>> On Behalf Of Andrew Dul Sent: Monday, May 6, 2019 4:09 PM To: arin-ppml@arin.net<mailto:arin-ppml@arin.net> Subject: [arin-ppml] Fwd: Advisory Council Recommendation Regarding NRPM 4.1.8. Unmet Requests Hello, I'd like to bring your attention to another issue that may have been lost in the flurry of other emails. We are currently in a 14 day feedback period for the AC's response to the Board's suspension of the wait-list. Please note the following updated text for the wait-list. Your comments on this updated text are welcome. Thanks, Andrew === 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, for which the organization is qualified, which in the case of the waiting list shall not be larger than a /22, and the smallest block size acceptable to the organization. An organization may not be added to the waiting list if it already holds IPv4 resources amounting in aggregate to more than a /20 of address space. Resources received via section 4.1.8 may not be transferred within 60 months of the issuance date. -------- Forwarded Message -------- Subject: [arin-ppml] Advisory Council Recommendation Regarding NRPM 4.1.8. Unmet Requests Date: Mon, 29 Apr 2019 11:16:31 -0400 From: ARIN <i...@arin.net><mailto:i...@arin.net> To: arin-ppml@arin.net<mailto:arin-ppml@arin.net> Subject: At their 16 January Meeting, the Board of Trustees suspended issuance of number resources under NRPM section 4.1.8.2. (Fulfilling Unmet Needs), and referred NRPM section 4.1.8 to the ARIN Advisory Council for their recommendation. The Advisory Council has provided its recommendation, and per ARIN's Policy Development Process, the recommendation is hereby submitted to the Public Policy Mailing List for a community discussion period of 14 days, to conclude on 13 May. Once completed, the Board of Trustees will review the AC’s recommendation and the PPML discussion. The full text of the Advisory Council's recommendation is below. Board of Trustees meeting minutes are available at: https://www.arin.net/about/welcome/board/meetings/2019_0116/ For more details on the Policy Development Process, visit: https://www.arin.net/participate/policy/pdp/ Regards, Sean Hopkins Policy Analyst American Registry for Internet Numbers (ARIN) Advisory Council recommendation: In accordance with section 10.2 of the ARIN Policy Development Process, the ARIN Advisory Council recommends the following actions to the Board of Trustees in response to the Board’s suspension of part of the operation of sections 4.1.8, 4.1.8.1 and 4.1.8.2 of the Numbering Resource Policy Manual: Replace section 4.1.8 as follows, then reinstate the full operation of sections 4.1.8, 4.1.8.1 and 4.1.8.2 immediately. 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, for which the organization is qualified, which in the case of the waiting list shall not be larger than a /22, and the smallest block size acceptable to the organization. An organization may not be added to the waiting list if it already holds IPv4 resources amounting in aggregate to more than a /20 of address space. Resources received via section 4.1.8 may not be transferred within 60 months of the issuance date. Repeated requests, in a manner that would circumvent 4.1.6, are not allowed: an organization may only receive one allocation, assignment, or transfer every 3 months, but ARIN, at its sole discretion, may waive this requirement if the requester can document a change in circumstances since their last request that could not have been reasonably foreseen at the time of the original request, and which now justifies additional space. Qualified requesters whose request cannot be immediately met will also be advised of the availability of the transfer mechanism in section 8.3 as an alternative mechanism to obtain IPv4 addresses. _______________________________________________ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net<mailto:ARIN-PPML@arin.net>). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net<mailto:i...@arin.net> if you experience any issues. _______________________________________________ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net<mailto:ARIN-PPML@arin.net>). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net<mailto:i...@arin.net> if you experience any issues. -- =============================================== David Farmer Email:far...@umn.edu<mailto:email%3afar...@umn.edu> Networking & Telecommunication Services Office of Information Technology University of Minnesota 2218 University Ave SE Phone: 612-626-0815 Minneapolis, MN 55414-3029 Cell: 612-812-9952 ===============================================
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