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 
> <arin-ppml@arin.net> 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:arin-ppml-boun...@arin.net] On Behalf Of Fernando 
> Frediani
> Sent: Tuesday, July 30, 2019 6:44 AM
> To: arin-ppml <arin-ppml@arin.net>
> 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
>  
> <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 
> <fhfredi...@gmail.com <mailto:fhfredi...@gmail.com>> 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/ 
> >> <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/ 
> >> <https://www.arin.net/participate/policy/pdp/>
> >>
> >> Draft Policies and Proposals under discussion can be found at:
> >> https://www.arin.net/participate/policy/drafts/ 
> >> <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
> >> _______________________________________________
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> >
> >
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