I reject the ad-hominem implication that this proposal is designed to
favor my business. Please consider my arguments and not your personal
interpretations of my motives in any future replies. This is a
frequent occurrence for me as a broker and it bothers me.
Regards,
Mike
*From:*ARIN-PPML <arin-ppml-boun...@arin.net> *On Behalf Of *Fernando
Frediani
*Sent:* Friday, August 16, 2019 11:17 AM
*To:* arin-ppml@arin.net
*Subject:* Re: [arin-ppml] Draft Policy ARIN-2019-17: Returned
Addresses to the 4.10 Reserved Pool
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 <arin-ppml-boun...@arin.net>
<mailto:arin-ppml-boun...@arin.net> *On Behalf Of *Fernando Frediani
*Sent:* Thursday, August 15, 2019 6:04 PM
*To:* arin-ppml@arin.net <mailto:arin-ppml@arin.net>
*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 <arin-ppml-boun...@arin.net>
<mailto: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>
<mailto:alison.w...@oregon.gov>
*Cc:* arin-ppml <arin-ppml@arin.net> <mailto: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 <mailto: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
<mailto: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
<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/
>>
>> 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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