> On Aug 15, 2019, at 14:47, Mike Burns <m...@iptrading.com> wrote:
> 
> Hi Owen,
>  
> It’s hard to predict when the useful IPv4 lifetime will end, so it’s hard to 
> say whether runout of these reserved pools is unlikely, especially if 
> conditions change.

If IPv4 continues to plague the internet for another 20+ years, then we have 
much bigger problems. 

>  
> If  you feel 4.4 and 4.10 are severely overstocked, maybe a proposal to 
> release those “sequestered” addresses should be forthcoming, as maintaining 
> those pools at those levels is counter to our mission?

I think what is there is fine. I think adding to them at this point makes 
little sense. 

> Do you have any comments on the problem statement, and the idea that the 
> haphazard and unpredictable influx of addresses into the waiting list is 
> problematic? For example, doesn’t the current constitution of the waiting 
> list encourage virtually all ARIN members to enter the lottery for a /22? The 
> size is small, the justification options pretty generous, the downside 
> minimal.

I don’t agree that it is problematic. I don’t see any problem with a /22 
lottery for the patient, frankly. I don’t see it as being any worse than US 
green card policy. 

> In my mind the waiting list is a fraud magnet and has outlived its  
> usefulness, and yes, this is an attempt to eliminate it without going down 
> the auction route.  The addresses haven’t been destroyed, just taken off the 
> market, adding the tiniest bit to the existing pools, whose size was approved 
> by the community.

I think it was, and yet, we’ve only got good evidence of a single bad actor. I 
think the recent adjustments to the policy seriously reduce the incentives for 
fraud and significantly increase the risks of detection. 

Owen

> I support the policy as written and amended.
>  
> Regards,
> Mike
>  
>  
>  
> From: ARIN-PPML <arin-ppml-boun...@arin.net> On Behalf Of Owen DeLong
> Sent: Thursday, August 15, 2019 5:10 PM
> To: WOOD Alison * DAS <alison.w...@oregon.gov>
> Cc: arin-ppml <arin-ppml@arin.net>
> Subject: Re: [arin-ppml] Draft Policy ARIN-2019-17: Returned Addresses to the 
> 4.10 Reserved Pool
>  
> 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
> 
> 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> 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
> >> _______________________________________________
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> >
> >
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