I think concerns related to fraud are the primary issues I would have
with the implementation of this policy as written, and any elimination
of the current requirement to demonstrate efficient utilization of past
allocations. I also disagree with the premise of the policy. My
understanding from organizations that have applied under the current
policy is that new ISP organizations without any IP allocations or
re-allocations cannot simply request space without providing some
documentation of a contract to receive network connectivity, and other
similar items that may not be required of networks with existing
re-allocations and operating networks. It doesn't seem to me like there
is a clear disparity, only that different information is required of
organizations in differing situations. In some cases, it could possibly
be even harder for an organization with no existing holdings to acquire
address space if they ran into issues demonstrating their plan to
actually get connected, or if they were unable to sign a contract for
services when they weren't sure if/when they would get address space or
not. Overall, I just don't see an organization having no holdings as
having a clear advantage or disadvantage within the waiting list
process, and I don't support this policy.
However, I would like to ask ARIN staff for clarification on this part
of the problem statement:
An organization without reassignments or reallocations doesn’t need to
provide any justification other than submitting the request and
providing an officer attestation.
Can we get some idea of the accuracy of this statement? Are there
actually any ISPs that are brand new corporations who received an
initial allocation with nothing besides an officer attestation? If so,
how does ARIN determine when extra documentation is required?
Isaiah Olson
Olson Tech, LLC
I have some major concerns with fraud. My day job sometimes involves/has
involved reviews when business customers would like space. On occasion,
ARIN has already denied them. After further review, our security teams find
out these people aren't who they say they are, don't own the physical
address they list, etc. Speaking for myself and not for my company, I am
very concerned that we are opening a huge door to fraud if there are zero
checks in place for requirements. I don't feel ARIN should be less
stringent than orgs that get space from them. If the main concern is
customers are claiming it's too difficult, I have a lot of questions there
as well. It should be easy to prove you are who you say you are and have a
valid reason to use the space.
Kat Hunter
Comcast
ARIN AC VC
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