Hello Mike
I didn't say those things, you are putting words in my mouth.
What I said is that in current time things like new entrants, critical
infrastructure, and usage like the 4.10 pool should be prioritized for
various reasons and organizations under these circumstances should not
be directed to the market as their first option therefore RIRs should
not shape their policies to push people to the transfer market which is
not a natural thing and ideally should not exist. I however understand
the need of it new a days and that this should be a option for
organizations who already hold IP space.
With regards the shutdown of the waiting list by the executive board I
personally consider that a correct decision. They have detected a fraud
and risk of that happening again and it is their role to do such things
in order to protect the RIR and ourselves in order to make sure that a
few organizations needs is not on the top of everybody needs. The
favoring of small members is another correct thing as well.
With regards opening a office in Africa to get "free" addresses
fortunately the RIR doesn't allow inter-RIR transfers and according to
what have been discussed in the list so far they are not willing to
allow it anytime soon.
There is no sense to put new entrants to get space from 4.4 or 4.10 as
they are for a different and reasonable propose and pushing them to
market is exactly shaping policies to favor private business like yours
which is not the function of a RIR and this community who develop these
policies.
Things change over time and we have do adapt to new scenarios (the
policies allowing transfers intra and inter RIR is a example), but we
must never forget some principles that has always been base for correct
IP space allocations.
Regards
Fernando
On 16/08/2019 10:43, Mike Burns wrote:
Hi Fernando,
Thanks for your input.
I think you are completely wrong in your interpretation of how IPv4
addressing should be managed.
You cling to old processes and thoughts associated with the free pool
era, which is gone.
Without the presence of the free pool, the market is the “necessary
and fair” way to manage resources.
With both the presence of the free pool and the market, there are
problems that manifested themselves in overt fraud.
This situation caused unprecedented events like the unilateral
shutting down of the waiting list by the executive board, the virtual
writing of policy by the Advisory council, the changing of waiting
list rules mid-game, the rationale of justifying the need for a block
and then maintaining that same need for an indeterminate time before
allocation, the creation of another class of addresses in ARIN space
(not easily distinguished), the favoring of small members over large
members, the FUD injected into project developments, the incentives to
lease space to maintain waiting-list need, etc.
We only have to look across the pond to see that any pool of “free”
addresses will be plundered by those willing to skirt the rules for
new entrants in RIPE or open an empty office in Africa in order to
access “free” addresses. You don’t have to limit your thoughts to
addresses, just think about any situation where a valuable resource is
available for “free” and you will find fraud.
My hope was the recent fraud recovery would provide an opportunity to
provide a block to everybody on the waiting list and then be able to
shut it down without anybody left on it who was waiting for a long
time. I think it’s the right time to shutter the waiting list. Should
any more tinkering with the rules become necessary, it will likely
impact many more people adversely in the future if the waiting list is
more populated, as I believe it will, with members placing their
lottery bets. How many new ORG-IDs will be granted to members holding
more than a /20, for the purpose of avoiding that new rule limiting
the waiting list to those with less than a /20? Whatever rule is
imposed, a way around it will be sought.
I think it should be shut down, and new entrants buy from the market,
or adhere to the rules for 4.10 and 4.4.
Regards,
Mike
*From:*ARIN-PPML <[email protected]> *On Behalf Of *Fernando
Frediani
*Sent:* Thursday, August 15, 2019 6:04 PM
*To:* [email protected]
*Subject:* Re: [arin-ppml] Draft Policy ARIN-2019-17: Returned
Addresses to the 4.10 Reserved Pool
The waiting list is a necessary and fair way to manage what is left
for the RIR to distribute to organizations according to its mission
and based on similar rules that were ever used. If there is fraud so
let's fix rules for the addresses from these pools as it has been
discussed recently about the minimal wait period for transfers.
What is out of the RIR's mission is shape its policies to favor the
transfer market which should never be seen as something normal or
natural or first option.
Fernando
On 15/08/2019 18:47, Mike Burns 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 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?
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.
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 support the policy as written and amended.
Regards,
Mike
*From:* ARIN-PPML <[email protected]>
<mailto:[email protected]> *On Behalf Of *Owen DeLong
*Sent:* Thursday, August 15, 2019 5:10 PM
*To:* WOOD Alison * DAS <[email protected]>
<mailto:[email protected]>
*Cc:* arin-ppml <[email protected]> <mailto:[email protected]>
*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
<[email protected] <mailto:[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] <mailto:[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] <mailto:[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
>> _______________________________________________
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>
>
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