Re: [arin-ppml] Recommended Draft Policy ARIN-2024-1: Definition of Organization ID/Org ID

[Tom Fantacone via ARIN-PPML]

With the definition proposed here:



"An Organizational Identifier (Org ID) is an identifier assigned to resource 
holders in the ARIN registry."



does that mean that an organization that applies for and receives an Org ID 
doesn't really have an Org ID until they receive resources?  Is it a "Pre-Org 
ID" at that point?



I believe this was discussed a few months back, with terms like "wish" and 
"intend" suggested in the definition.   Maybe something like this would be more 
accurate, if less concise:



"An Organizational Identifier (Org ID) is an identifier assigned to an entity 
that holds resources or may attempt to receive resources in the ARIN registry."



Regards,



Tom Fantacone







 On Tue, 21 May 2024 12:28:05 -0400 ARIN  wrote ---



On 16 May 2024, the ARIN Advisory Council (AC) advanced the following Draft 
Policy to Recommended Draft Policy status: 

* ARIN-2024-1: Definition of Organization ID/Org ID

The text of the Recommended Draft Policy is below, and may also be found at: 

https://www.arin.net/participate/policy/drafts/2024_1/

You are encouraged to discuss all Recommended Draft Policies on PPML prior to 
their presentation at the next ARIN Public Policy Consultation (PPC). PPML and 
PPC discussions are invaluable to the AC when determining community consensus. 

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,
 
Eddie Diego
Policy Analyst
American Registry for Internet Numbers (ARIN)


Recommended Draft Policy ARIN-2024-1: Definition of Organization ID/Org ID

AC Assessment of Conformance with the Principles of Internet Number Resource 
Policy:

Recommended Draft Policy ARIN-2024-1 conforms to the principles of the ARIN 
Policy Development Process.  This policy, if adopted, will add clarity to the 
NPRM by providing a clear definition of an Organization Identifier as section 
2.18.  It is fair, impartial, technically sound and has received support from 
the community.

Problem Statement:

During work on a related policy proposal, the NRPM Working Group determined 
that a definition of Organization Identifier (Org ID) should be included in the 
NRPM to add clarity to the term and unify NRPM references to match the use of 
the term in other ARIN publications such as ARIN online.

Policy Statement:

Current: None

Proposed:

Section 2.18. Organization Identifier (Org ID)

An Organizational Identifier (Org ID) is an identifier assigned to resource 
holders in the ARIN registry.

Comments:

This definition had previously been included in an earlier policy proposal 
(ARIN-2023-7), but community feedback recommendations on that proposal showed a 
preference for adding the definition separately from that proposal. As such the 
definition is now being proposed as a standalone proposal, and the language 
will be removed from the current ARIN-2023-7 proposal, allowing the two 
sections of that proposal to be evaluated separately.

Timetable for Implementation: Immediate



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Re: [arin-ppml] Tenfold fee increases?

[Tom Fantacone]

Heather,



I wish I could have posted this on arin-discuss@, but it's been shut down as 
you know.  



While ARIN's fee structure is not set by policy, extravagant fee increases do 
have a very practical effect on the implementation of policy, and I think it's 
appropriate to discuss here, as prior excessive fee increases have been 
discussed in the past.  For instance, were ARIN to increase resource transfer 
fees from $500 to $50,000, it would certainly impact Section 8 transfers.  Were 
ARIN to increase IPv6 annual resource fees by a factor of 10, that would impact 
IPv6 deployment and could induce members suggest policy changes to compensate.



I'm not questioning the board's right to set fees.  I'm questioning their 
judgment.  The board may have good reasons for large fee increases, but I'm 
skeptical and suggest when contemplating very large increases, or changes to 
fee structures that greatly impact certain organizations (like billing end 
users Orgs as ISPs), there be some transparency and requests for community 
comments BEFORE it's a done deal.



The moderators can shut this down if they choose.  I'd prefer to hear some 
feedback from those who made the decisions on these fee hikes.



Regards,



Tom Fantacone







 On Sat, 03 Jun 2023 10:19:59 -0400 Heather Schiller 
 wrote ---



ARIN moderators -- please consider moving or closing this thread.  



Folks, ARIN fees are not set through the Policy Development Process.  The board 
sets fees and has the fiduciary responsibility to ARIN.  Direct complaints to 
the Board, maybe the suggestion process, ARIN feedback surveys or the open 
discussion at membership portion of meetings.  



arin-discuss@ would have been the appropriate forum.  Perhaps general-members@ 
is a better fit.



 --h



On Fri, Jun 2, 2023 at 5:03 PM Mike Burns <mailto:m...@iptrading.com> wrote:

 


“All that said, I couldn’t find any justification for the increase from $1,000 
to $10,000. If there is justification or other details regarding the increase, 
I’d appreciate a pointer to them.”


 

 

Hi David,

 

Reading the new contract it’s clear that ARIN’s intention here is to avoid any 
liability through imputed approval of listed brokers.

So there is a twofold  approach. First, have all the brokers more explicitly 
abjure any legal connection with ARIN and second, reduced the likelihood of a 
problem by filtering out risky brokers.

 

I wonder if the board became spooked by something.  Seems like even bolder 
disclaimers on the broker page could have handled the liability risk, but IANAL.

 

It brings to mind this suggestion: 
https://www.arin.net/vault/participate/acsp/suggestions/2018-20-suggestion.pdf

 

Speaking as a broker who can easily qualify, this will certainly benefit us as 
it will limit our competitor’s access.

And not just small brokers, but overseas brokers! Thanks ARIN, we can be listed 
brokers at the other trading RIRs, and also at ARIN!

So you can’t be a sole proprietor because you need two responsible contacts. 
And you have to be organized as a business.

There are a few brokers I know who are good brokers, but not really full-time 
brokers, who are on the list.

Anyway, the insurance requirement, the background checks, the $10K annual fee, 
all these make sense if you understand the intention of reducing ARIN risk 
exposure.

The loss of small and overseas brokers, the reduced competition, well those are 
collateral damages that the board seems to have accepted.

 

I do agree with David that $100 was too low and with Tom (and many other 
brokers) that $10,000 is too high. And that there should be some venue for 
discussion of fees. 

 

I wonder why ARIN alone feels this pressure, the other RIR broker lists don’t 
seem to.

 

Regards,
Mike
 

PS I am not buying the argument that ARIN feels compelled to do this to protect 
innocent members from bad brokers, but I will admit that could be a motivation







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[arin-ppml] Tenfold fee increases?

[Tom Fantacone]

I was a bit stunned this morning to see our organization's ARIN fees 
would be going up by a factor of 10.  We live in inflationary times, 
but that's an increase of, let's see, I guess 1,000%?


Before the rest of you resource holders on the list have a coronary, 
let me qualify that this fee increase is for just for registered 
facilitators (brokers) and most of you won't be affected.  This 
time.  But the more general issue of ARIN raising fees in an 
extravagant manner with no solicitation for public discussion of the 
impact affects all of us.


When ARIN began the facilitators' program the annual fee was just 
$100.  A few years later the fee was raised tenfold to $1,000.  Today 
we learned that another tenfold increase would go into effect making 
our annual fee $10,000.  So it's actually a 100-fold increase in 
about a decade.


Our own organization won't be too affected by this.  We can handle 
it, and most of the larger IP brokers can as well.  It may even help 
us by driving away some competition.  But that shouldn't be the 
point.  There are smaller organizations that are facilitators that 
will be severely impacted.  We work with some of these and while they 
may not handle the volume of transactions we do, they do an excellent 
job in moving IPv4 resources to organizations that need them and 
educating the parties along the way.


There are some other changes to the facilitator program, including 
requiring liability insurance for ARIN, background checks, customer 
references, etc.  I assume this is to keep some of the riff-raff out 
and may be helpful.  I don't see how outrageous fee increases help anyone.


Other sharp fee increases have been brought up and complained about 
on this list, always after the fact.  The recent resource holder fee 
increases that saw end user organizations suddenly treated as ISPs 
comes to mind.  Recently, transfer fees spiked from $300 to $500 per 
transfer and were suddenly appled to source organizations in all 
transfers (it used to be just transfers from end user orgs).  As if 
that wasn't enough, ARIN started charging transfer recipients an 
additional transfer fee.  I can tell you from first-hand experience 
this hurt small organizations looking to acquire IPv4 blocks.


I recommend ARIN transparently solicit public input when pondering 
fee increases of such magnitude.  Hopefully before our fee goes up 
another 1,000%.


Regards,

Tom Fantacone


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Re: [arin-ppml] Draft Policy ARIN-2022-3: Remove Officer Attestation Requirement for 8.5.5

[Tom Fantacone]

I don't believe either form (Acknowledgement or Attestation) are currently 
optional.  Only the Acknowledgement form needs to be notarized, however.







 On Sun, 26 Jun 2022 17:58:21 -0400 Sylvain Baya  wrote 
---



Dear ARIN-PPML,

Please find my comments below, inline...



Thanks.

Le samedi 25 juin 2022, Tom Fantacone <mailto:t...@iptrading.com> a écrit :
Owen,



This is actually the link for the sample Officer Attestation:










Hi Tom,

Thanks for adding more clarifications, brother :-) 

 



https://www.arin.net/about/corporate/agreements/OfficerAttestation_watermark.pdf



The link you provided was for the "Officer Acknowledgement".  












Right, thanks!







The Officer Acknowledgement is a notarized form 










Here, you seem to have kickly generalised an 

optional act :-/ 



It's not what the documented [1] procedure states:





"*No notarization is necessary*. Note that the form 

will be provided to you and is not available via our 

website."




__

[1]: 
https://www.arin.net/about/corporate/agreements/attestation/#:~:text=No%20notarization%20is%20necessary,not%20available%20via%20our%20website.



 



signed by the Seller of the resources verifying, among other things, that the 
signer is authorized on behalf of the source entity to make the resource 
transfer.  








 

...it would be really useful to render this attestation

 mandatory, imho; as it appears to be optional [1].







That helps to avoid a situation where an unauthorized employee with ARIN online 
access could make a resource transfer without permission.










Thanks for mentioning this valuable detail.



FWIW, the tool is available; but it's still [2] optional :'-(

 



"Officer Acknowledgment 



The Officer Acknowledgment form , *when signed* 

*and notarized*, *is required to be provided* to 

ARIN *by a source organization* (current registrant)

 for a Transfer to Specified Recipients in the ARIN 

Region (8.3) or an Inter-RIR Transfer (8.4). An 

officer of the source organization needs to sign this

 form, have it notarized, and provide it to ARIN."



__

[2]: 
https://www.arin.net/about/corporate/agreements/#:~:text=Officer%20Acknowledgment,notarized%2C%20and%20provide%20it%20to%20ARIN.





Would you like it to become mandatory?



 





The Officer Attestation is a simpler form signed by the Buyer attesting to the 
accuracy of the justification data and doesn't require notarization.  












Tom, could you, please, explain why?



...imho! the new resource holder *must* be an org 

which is willing to demonstrate its *need* of INRs.



 





That's the one the draft policy seeks to eliminate.












This is a new information, at least for me, and i 

thank you for this useful clarification, brother.



...i see it, at least, become optionally validated.

As you explained; the interest in validating the 

Officer Acknowledgement document, is to add 

more confidence to the process, for the new 

resource holder.

Why not also validate Officer Acknowledgement 

documents?

If the new resource holder's right representative 

could sign a notarized document, then the new 

destination of those INRs, being transfered, might 

be more safe, and the numbering community 

would celebrate that happy end...imho :-/



Rather than supporting this attempt to prevent the 

use of  Officer Attestation documents, i recommend

 that its validation becomes the norm & its non 

validation an exception. This would add more 

protection against INRs reservation, imho.



Thanks to let me know if i misunderstood something...



This is where, i have to call John again...or anyone, 

with clue, from ARIN's Staff...for help :-)



Shalom,

--sb.



 





Best Regards,



Tom Fantacone







 On Sat, 25 Jun 2022 00:41:46 -0400 Owen DeLong via ARIN-PPML 
<mailto:arin-ppml@arin.net> wrote ---





>
 > [...]
 >
 













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Re: [arin-ppml] Draft Policy ARIN-2022-3: Remove Officer Attestation Requirement for 8.5.5

[Tom Fantacone]

Owen,



This is actually the link for the sample Officer Attestation:



https://www.arin.net/about/corporate/agreements/OfficerAttestation_watermark.pdf



The link you provided was for the "Officer Acknowledgement".  The Officer 
Acknowledgement is a notarized form signed by the Seller of the resources 
verifying, among other things, that the signer is authorized on behalf of the 
source entity to make the resource transfer.  That helps to avoid a situation 
where an unauthorized employee with ARIN online access could make a resource 
transfer without permission.



The Officer Attestation is a simpler form signed by the Buyer attesting to the 
accuracy of the justification data and doesn't require notarization.  That's 
the one the draft policy seeks to eliminate.



Best Regards,



Tom Fantacone







 On Sat, 25 Jun 2022 00:41:46 -0400 Owen DeLong via ARIN-PPML 
 wrote ---



Easy enough to check for yourself…

https://www.arin.net/about/corporate/agreements/office_acknowledgement.pdf



The attestation form is at the link above.



No mention of perjury, but most business contracts aren’t signed under penalty 
of perjury.



You don’t really need to sign under penalty of perjury to put yourself on the 
hook for civil and criminal fraud liability if you

signed the contract with intent to deceive in order to acquire something of 
value.



Owen



On Jun 24, 2022, at 19:40 , Sylvain Baya <mailto:absc...@gmail.com> wrote:


Dear ARIN-PPML,

Hope this email finds you in good health!

Please find my comments below, inline...


Le vendredi 24 juin 2022, Ronald F. Guilmette <mailto:r...@tristatelogic.com> a 
écrit :
In message 
<mailto:cagbmp+j5zr+-dfubvh6rqoomfpmembfes0nmntm0_nung2q...@mail.gmail.com>
 Matthew Wilder <mailto:matthew.wil...@telus.com> wrote:
 
 >Would-be fraudsters on the transfer market would
 >now face significant cost to execute a transfer, and presumably, an
 >organization operating in bad faith could easily provide officer
 >attestation.
 
 Are these attestations signed "under penality of perjury"?
 






John, could you, please, take also that question?



Thanks for asking, Ronald :-)






"declaration under penalty of perjury 

A statement that has been signed by a declarant 

who will be found guilty of perjury if the facts 

declared in the statement are shown to be 

materially false." 



__

https://www.law.cornell.edu/wex/declaration_under_penalty_of_perjury#:~:text=declaration%20under%20penalty%20of%20perjury,shown%20to%20be%20materially%20false.





It would certainly add more security to the process.



Thus, imho, the policy manual should be keeped as

 is or only improved to add more protection against

 potential *reservation* plans.



Shalom,

--sb.



 





If so, it may be worthwhile to keep requiring them.  Fraudsters may yet
 balk at adding yet another crime on top of whatever ones they are already
 committing.  (That is my thinking anyway.)
 
 
 Regards,
 rfg
[...]



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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Tom Fantacone]

Hi John,



These days it's pretty hard to find an LIR who will bundle a substantial number 
of addresses at no additional charge with a circuit, and that's assuming they 
have the addresses available to bundle.  With IPv4 scarcity, we more often see 
an LIR client request, say, an /18, and perhaps be able to justify it, but 
their ISP can only allocate a /22 or /21 given their own shortage of addresses. 
 Those LIRs that do have the space are charging for it, either directly or by 
bundling it into the circuit price.  Nevertheless, there are still certainly 
cases where what you are saying is true, and the client can get what they need 
from their upstream LIR.



What I was comparing is the cost of an end user purchasing a block on the 
transfer market vs. leasing one from a 3rd party lessor.  These might be the 
only 2 options for the client for the reasons I mentioned above, or because 
they want to multi-home, or because they want the flexibility of moving 
providers without having to renumber, or for whatever reason network operators 
currently purchase IPv4 space on the transfer market vs. trying to get them 
from their upstream.



Regards,



Tom Fantacone







 On Fri, 11 Mar 2022 18:04:52 -0500 John Santos  wrote 



I disagree.  The addresses are useless unless they ALSO purchase access and 
routing from another network operator.  How is this cheaper?

It is and always has been allowed to lease bundled access of addresses and 
connectivity from a LIR, without any expense for purchasing those addresses.


On 3/11/2022 12:13 PM, Tom Fantacone wrote:
> I support the proposal as written.
> 
> It facilitates the provision of a valuable service to a large swath of the 
> ARIN 
> community, namely the ability of network operators with an operational need 
> to 
> lease IPv4 addresses from 3rd party lessors at a fraction of the cost of 
> purchasing those addresses.  Too often we have seen network operators justify 
> their need for IPv4 space only to find that they can't afford to make the 
> purchase.  They end up using CGNAT or some other sub-optimal solution.
> 
> Bill, regarding your point "B", by providing IPv4 leasing, these 3rd parties 
> are 
> certainly performing a function that ARIN does not.
> 
> 
> 
>  On Thu, 10 Mar 2022 17:46:36 -0500 *William Herrin 
> <mailto:b...@herrin.us>* wrote 
> 
> On Wed, Mar 9, 2022 at 8:24 PM ARIN <mailto:i...@arin.net 
> <mailto:mailto:i...@arin.net>>
> wrote:
>  > * ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining
> Utilization for Future Allocations
> 
> I continue to OPPOSE this proposal because:
> 
> A) It asks ARIN to facilitate blatant and unapologetic rent-seeking
> behavior with changes to public policy.
> 
> B) It proposes that third parties perform precisely and only the
> functions that ARIN itself performs without any credible compliance
> mechanism to assure the third party performs to ARIN's standards or in
> accordance with the community's established number policy.
> 
> Regards,
> Bill Herrin
> 
> 
> -- 
> William Herrin
> mailto:b...@herrin.us <mailto:mailto:b...@herrin.us>
> https://bill.herrin.us/ <https://bill.herrin.us/>
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-- 
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Evans Griffiths & Hart, Inc.
781-861-0670 ext 539
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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Tom Fantacone]

Bill,



We can quibble about semantics, but let's go with your verbiage:



If I run a network and qualify 
for an /18 right now, can I go to ARIN and lease one?   I must either pay 
someone to release their addresses to ARIN to lease to me or lease one from a 
(non-ARIN) 3rd party.



And the amount I must pay (commonly referred to as the Purchase Price in most 
IPv4 transfer contracts, whether I'm technically "buying" it or not), is 
significantly more than either typical lease rates or ARIN's annual fees.  My 
point is that 3rd party lessors do provide a service that ARIN does not.



Regards,



Tom Fantacone







 On Fri, 11 Mar 2022 12:42:52 -0500 William Herrin  wrote 




On Fri, Mar 11, 2022 at 9:40 AM Tom Fantacone <mailto:t...@iptrading.com> 
wrote: 
> If I run a network and qualify for an /18 right now, can I got to ARIN and 
> lease one?   I must either buy one on the transfer market 
 
Tom, 
 
I think you misunderstand the transfer market. You don't buy addresses 
on the transfer market. You lease addresses from ARIN and then pay 
someone on the transfer market to release their addresses to ARIN for 
lease to you. 
 
Regards, 
Bill Herrin 
 
 
-- 
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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Tom Fantacone]

Bill,



If I run a network and qualify for an /18 right now, can I got to ARIN and 
lease one?   I must either buy one on the transfer market or lease one from a 
(non-ARIN) 3rd party.



Your analogy makes some sense regarding previously allocated IPv4 space, but we 
are in exhaust.  This policy would not have made sense when there was a free 
pool, but it excludes waiting list addresses and so covers that base.


Regards,


Tom Fantacone







 On Fri, 11 Mar 2022 12:31:47 -0500 William Herrin  wrote 




On Fri, Mar 11, 2022 at 9:14 AM Tom Fantacone <mailto:t...@iptrading.com> 
wrote: 
> Bill, regarding your point "B", by providing IPv4 leasing, these 3rd parties 
> are certainly performing a function that ARIN does not. 
 
Oh really? ARIN doesn't charge an annual fee to retain the IP address 
assignment they've made? And they don't reclaim the addresses for use 
by someone else should you fail to pay? Your "leasing" differs from 
ARIN's only in that you charge much more money and perform 
questionable diligence with respect to enforcing number policy. 
 
Regards, 
Bill Herrin 
 
 
-- 
William Herrin 
mailto:b...@herrin.us 
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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Tom Fantacone]

I support the proposal as written.



It 
facilitates the provision of a valuable service to a large swath of the 
ARIN community, namely the ability of network operators with an 
operational need to lease IPv4 addresses from 3rd party lessors at a 
fraction of the cost of purchasing those addresses.  Too often we have 
seen network operators justify their need for IPv4 space only to find 
that they can't afford to make the purchase.  They end up using CGNAT or
 some other sub-optimal solution.



Bill, regarding your point "B", by providing IPv4 leasing, these 3rd parties 
are certainly performing a function that ARIN does not.







 On Thu, 10 Mar 2022 17:46:36 -0500 William Herrin  wrote 




On Wed, Mar 9, 2022 at 8:24 PM ARIN  wrote: 
> * ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining 
> Utilization for Future Allocations 
 
I continue to OPPOSE this proposal because: 
 
A) It asks ARIN to facilitate blatant and unapologetic rent-seeking 
behavior with changes to public policy. 
 
B) It proposes that third parties perform precisely and only the 
functions that ARIN itself performs without any credible compliance 
mechanism to assure the third party performs to ARIN's standards or in 
accordance with the community's established number policy. 
 
Regards, 
Bill Herrin 
 
 
-- 
William Herrin 
mailto:b...@herrin.us 
https://bill.herrin.us/ 
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Re: [arin-ppml] Draft Policy ARIN-2021-6: Remove Circuit Requirement

[Tom Fantacone]

I support the policy, with the caveat mentioned by others that leased addresses 
shouldn't be a justification to go on the waiting list.



With address scarcity, leasing is becoming more widespread and this policy 
encourages more accurate SWIPs of the addresses in use.



There's been some intimation in this discussion that because the proposal came 
from a broker it deserves greater scrutiny with an eye towards nefarious profit 
motives.  Proposals should be evaluated and discussed based solely on their 
merits, not on who proposes them or any imputed motivation.  Nonetheless, as a 
broker who has dealt with hundreds of organizations seeking IPv4 space, I can 
state that more and more of these organizations are considering leasing IPv4 as 
their only viable option.  Yes, some can go on the waiting list, but only if 
they can wait 3-4 months and don't already have a /20 of space.  Yes, some can 
purchase IPv4 on the transfer market, but prices have risen considerably and 
some of the small to mid-sized ISPs I deal with who have received transfers in 
the past no longer have the budget for it.  For more and more orgs, leasing is 
the only economical way to go.



As far as brokering leases goes, it's not a very desirable market for us, and 
most of the others I know in the broker community feel the same way.  Some just 
won't touch it.  Brokering a lease takes a lot more effort than brokering a 
transfer, and generates a much smaller fee.  When we do it, it's usually to 
help out a prior IPv4 transfer client who needs to lease space to keep their 
network operational.  Not that financial gain should be an issue, but FYI, it's 
practically done as a public service.  The reason a broker would initiate this 
proposal is that he sees a need for it based on his experience with hundreds of 
real world cases.



Regards,



Tom Fantacone







 On Wed, 22 Sep 2021 08:32:36 -0400 John Curran  wrote 




On 21 Sep 2021, at 10:25 PM, Mike Burns <mailto:m...@iptrading.com> wrote:

 



Hi Isaiah,



Thank you for your thoughtful response. I don't think the proposal is not in 
accord with any provisions of the PDP.



We can agree to disagree on certain issues, but we agree on one thing, the last 
thing in your message.

"Regardless, I hope this policy will be amended to specify that leased 
addresses cannot be considered as justified need for waiting list requests."



I am in full agreement here, but I am not sure how best to word this.  ...








Mike  -



If that is a desired policy goal, then one possible way such a result could be 
achieved by the explicit definition of the term “operational need” and then 
referencing that term in the waiting list policy.   In this manner, 
generalization of LIR would not
 create ambiguities in application of waiting list issuance. 



(I am certain there are many other ways to accomplish such a result, but 
provide the above as one possible approach in order to be responsive to your 
query and further discussion your policy goal.   Also note that parties 
purchasing rights to IP address
 blocks via specified transfers (NRPM 8.3 and 8.4) must per NRPM 8.5 have 
“operational use” – i.e. any transfers of number resources must be solely for 
the purpose of use on an operational network – and so doing an overall 
definition of that term instead and
 adjusting references is also a possible if that aligns with your policy goal.) 



Best wishes,

/John



John Curran

President and CEO

American Registry for Internet Numbers







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Re: [arin-ppml] Open Petition for ARIN-2020-2

[Tom Fantacone]

The petition process calls for volume (support of 25 separate orgs), and does 
not request "substance".  The substance has been discussed at length, and I 
assume the +1 votes from these network operators come about through 
substantive, rational thought.



But since you raised the issue of substance, here's the substance of the 
thinking for my own support for the petition.  I originally proposed the wait 
list block size limit of a /22 back in Feb, 2019 in response to well-discussed 
fraud issues.  At the time, I thought the waiting list fraud was massive and 
widespread and required a heavy hand to combat it.   I'm now more of the 
opinion that the fraud was massive but not that widespread (affecting a large 
number of IPs but not done by a large number of players).  My proposal was not 
implemented, but the one that was included the /22 limit as well as the /20 
limit for total holdings.  I think it's too stringent, but more importantly it 
punishes a lot of waiting list orgs that were playing by the rules and had a 
reasonable expectation that their waiting list needs would be met.



I imagine most of the support from these "newbies" is based on the essential 
unfairness of harming dozens of legitimate players in order to prevent 
potential fraud of a few.  But I don't want to put words in their mouths.  I 
welcome their input and look forward to their participation in the future.



Regards,



Tom Fantacone

IPTrading.com







 On Thu, 14 Jan 2021 22:41:50 -0500 Martin Hannigan  
wrote 







Not quite what I had in mind. However, you demonstrated the point. Volume != 
substance. Personally, I find the AC to be too activist on occasion. However I 
see nothing that needs repair here. I applaud use of the petition process as it 
is part of the pdp. The petition itself, while long and detailed, lacks enough 
substance itself to make me want to support it.  Your mileage may vary.



Warm regards,



-M<












On Wed, Jan 13, 2021 at 5:31 PM Tom Fantacone <mailto:t...@iptrading.com> wrote:

Well, since you asked, I do support the petition.



Tom Fantacone

IPTrading.com



--- Original Message ---

>From: Martin Hannigan[mailto:mailto:hanni...@gmail.com]

Sent: 1/13/2021 5:20:04 PM

To  : mailto:arin-ppml@arin.net

Cc  : 

Subject : RE: Re: [arin-ppml] Open Petition for ARIN-2020-2



 





Anyone else going to say it? 







On Wed, Jan 13, 2021 at 16:36 Annette Ogden 
<mailto:annet...@anderson-electric.com> wrote:

I support this petition.

 

Annette Ogden

Anderson Electric, Inc.

 



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Re: [arin-ppml] Open Petition for ARIN-2020-2

[Tom Fantacone]

Well, since you asked, I do support the petition.
Tom FantaconeIPTrading.com

--- Original Message ---
>From: Martin Hannigan[mailto:hanni...@gmail.com]
Sent: 1/13/2021 5:20:04 PM
To  : arin-ppml@arin.net
Cc  : 
Subject : RE: Re: [arin-ppml] Open Petition for ARIN-2020-2

 

Anyone else going to say it? 


On Wed, Jan 13, 2021 at 16:36 Annette Ogden  
wrote:








I support this petition.
 
Annette Ogden
Anderson Electric, Inc.
 



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Re: [arin-ppml] ARIN-2019-19 Require IPv6 before receiving Section 8 IPv4 Transfers

[Tom Fantacone]

I oppose the policy requiring IPv6 implementation either as part of an IPv4 
transfer or receipt of IPv4 on the waiting list.  Others have correctly pointed 
out that the policy will not have the desired effect of encouraging IPv6 
adoption, but my main objection is that it's an attempt to coerce behavior that 
should be voluntary - namely, the implementation of your preferred protocol.



In the spirit of consistency, I will offer that while I'm not a big fan of 
IPv6, I also would oppose policy requiring IPv4 adoption in order to receive an 
IPv6 allocation.



Fernando, some further comments inline below:



 On Mon, 13 Jan 2020 13:45:43 -0500 Fernando Frediani 
 wrote 



I believe this is some kind of political correctness way of dealing with 
this topic. While many support the adoption of IPv6 and recognize the 
critical need of it for the Internet ecosystem to continue work smoothly 
and to avoid many conflicts that will arise otherwise, they don't seem 
to want to offend others colleagues believing this will 'force' them to 
deploy IPv6...




If there is any political correctness at play here, it's in the other 
direction.  Those who don't buy into the IPv6 religion keep a low profile and 
often only express their views when others try and force adoption on them 
through policy.



It was already mentioned in the previous discussions this forum has full 
rights to establish how the registry is administered and the rules that 
apply to transfers. There is nothing illegal on that and it's nothing 
absurd or abrupt, so making this move is a little effort that 
contributed to something that will happen in a way or another, more 
smoothy if you choose to support this proposal or with pain if you do not.




Just because it's not illegal doesn't make it desirable.  The less coercive 
ARIN policy can be, the better.  I'll take the pain.  So far it's been 
unnoticeable.

Tom Fantaonce___
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Re: [arin-ppml] Draft Policy ARIN-2019-19: Require IPv6 Before Receiving Section 8 IPv4 Transfers

[Tom Fantacone]

At 05:05 PM 11/6/2019, Michel Py wrote:


John,

>> Michel Py wrote :
>> IPv6 has failed to deploy for twenty years. Open your eyes.

> John Curran wrote :
> That's a point that you'll need to prove to the community, if 
indeed you wish it to be considered in the development of policy.


It's fine to have discussions about this point, but no one should 
have to prove it to a community in order to be allowed to operate 
their own network using the protocols they choose (or to be not 
penalized by the community for not using the protocol du jour).



> sc...@solarnetone.org
> Now you have me really curious. Why are you opposed to IPv6?

I am not opposed to IPv6. What I am opposed to is zealots who have 
been telling me the same broken records for 20 years, trying to 
shove it down my throat by any means possible including taxing it. 
My ecosystem is IPv4 and it's big enough to survive on its own forever.
IPv6 is not the Internet. The IPv4 Internet does not need IPv6. My 
network, my rules.


If you don't want the balkanization of the Internet, stop trying to 
force-feed me.

IPv6 is a solution looking for a problem that I do not have.

Michel.



Agreed.  If IPv6 is so advantageous, network operators will use it by 
choice.  Some have.  Many have not.  The ones who have not are not 
backwards or crazy or evil.  They simply haven't been swayed by the 
arguments for IPv6 as applied to their particular situation.  After 
decades of IPv6 promotion by all the RIRs, some large corps and other 
zealots, and after a modest, but somewhat disappointing uptake, is 
the "solution" now to force network operators to deploy IPv6 or 
penalize them under policy for not doing so?



With all the respect, 30%+ global IPv6 traffic, I think somebody 
else should open the eyes!


China already mandated it to the ISPs, even if we aren't able to 
measure it correctly (yet), you can guess that being a country with 
1.4 billion inhabitants, this will, in just a couple of years, 
double the % of IPv6 traffic..


Regards,
Jordi
@jordipalet


I'm sure China mandating IPv6 to ISPs increases utilization, just as 
their one-child policy reduces population growth, but I want none of it.

Let the protocols fall where they may.

Regards,

Tom Fantacone


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Re: [arin-ppml] Draft Policy ARIN-2019-19: Require IPv6 Before Receiving Section 8 IPv4 Transfers

[Tom Fantacone]

At 02:20 PM 11/6/2019, hostmas...@uneedus.com wrote:
If you choose to ignore IPv6, I think it is reasonable for ARIN to 
tell you no new IPv4 addresses for you.


Why is that reasonable?   I think it's reasonable that an 
organization may choose to deploy IPv6.  I also think it's reasonable 
that they don't.  Those who deploy IPv6 should do so because of the 
inherent advantages they feel it provides to their business.  Those 
who don't see the advantages or feel the costs and disadvantages 
outweigh the advantages should not be forced to deploy IPv6, 
especially by a registry whose chief function is that of stewardship.


I personally think it is not responsible in todays world to NOT have 
IPv6 in place in your network. Already, there exists IPv6 networks 
that your IPv4 only world cannot reach.


There are far more IPv4 networks that an IPv6 only world cannot 
reach.  All joking about legacy technologies aside, I suspect the 
current utilization of IPv4 is a tad higher than the current 
utilization of Windows 3.1 systems running on 10Base2.  If you like 
IPv6, use it, and try to convince others to use it by touting its 
advantages, not through force and penalization.


I oppose the proposal.


Albert Erdmann
Network Administrator
Paradise On Line Inc.

On Wed, 6 Nov 2019, Michel Py wrote:

I oppose this proposal. If I am ever in a position where ARIN is 
trying to force me to request or use IPv6, I will sue ARIN for 
imposing an undue burden.


I am serious. If ARIN generates more work for me, I will explore 
all options to be compensated.


Michel.


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Re: [arin-ppml] Draft Policy ARIN-2019-17: Returned Addresses to the 4.10 Reserved Pool

[Tom Fantacone]

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 
<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/
>>

Re: [arin-ppml] Draft Policy ARIN-2019-17: Returned Addresses to the 4.10 Reserved Pool

[Tom Fantacone]

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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Re: [arin-ppml] Looking for final show of support on revised Advisory Council Recommendation Regarding NRPM 4.1.8. Unmet Requests

[Tom Fantacone]

No - oppose.  But I would support it if the 60 month waiting period was reduced 
to 12 or 24 months.  60 months means companies who no longer need the resources 
will just sit on them till they can sell them.  Not an efficient way to get 
them into the hands of those who need them.

And also that it shouldn't affect current waiting list participants who planned 
their networks based on prior policy.


 On Thu, 06 Jun 2019 13:20:40 -0400 John Curran  
wrote 


Folks - 



We’ve had excellent discussion of various options for the revised “Advisory 
Council Recommendation Regarding NRPM 4.1.8. Unmet Requests"  proposed policy 
change – some of which is likely to have to further informed folks initial 
views on the matter
 (as well as on future policy proposals in this area), but at this time it is 
fairly important that we receive focused feedback on the revised policy text as 
written, with due consideration to the discussion that has occurred online. 



To that end, at this time it would be good to know from everyone: 



1.  Are you in favor of ARIN making the policy change specified in the revised  
"Advisory Council Recommendation Regarding NRPM 4.1.8. Unmet Requests”  ?



(“Yes” obviously indicative that you’d like ARIN to proceed with its adoption 
and resumption of wait list issuance under its revised guidelines, and 

 “No” being indicative that you’d rather have the suspension of wait list 
issuance continue unless/until some other policy change in this area reaches 
consensus.) 



2.  If you are not supportive of ARIN making the change specified in the 
revised "Advisory Council Recommendation Regarding NRPM 4.1.8. Unmet Requests”,

is there any modification to the proposed policy change that would enable you 
to support it?



I would ask that PPML participants take a moment to consider the proposed 
policy change as written and please reply regarding the questions above. 



Thanks!

/John



John Curran

President and CEO

American Registry for Internet Numbers



Begin forwarded message:


From: ARIN 

Subject: [arin-ppml] Revised - Advisory Council Recommendation Regarding NRPM 
4.1.8. Unmet Requests

Date: 24 May 2019 at 1:04:58 PM EDT

To: 


At their 16 May meeting, the Advisory Council revised their recommendation 
regarding NRPM 4.1.8. Unmet Requests.
 
 The revised recommendation is hereby submitted to the Public Policy Mailing 
List for a second community discussion period of 14 days, to conclude on 7 June.
 
 Once completed, the Board of Trustees will review the AC’s recommendation and 
the PPML discussion.
 
 The full text of the Advisory Council's revised recommendation is below.
 
 Sean Hopkins
 Policy Analyst
 American Registry for Internet Numbers (ARIN)
 
 
 
 Advisory Council recommendation:
 
 This is an updated version which incorporates feedback from the ARIN staff and 
was approved for further community consultation at the ARIN AC meeting on May 
16, 2019.
 
 In accordance with section 10.2 of the ARIN Policy Development Process, the 
ARIN Advisory Council recommends the following actions to the Board of Trustees 
in response to the Board’s suspension of part of the operation of sections 
4.1.8, 4.1.8.1 and 4.1.8.2
 of the Numbering Resource Policy Manual:
 
 Replace section 4.1.8 et. seq. as follows, then reinstate the full operation 
of sections 4.1.8, 4.1.8.1 and 4.1.8.2 immediately.
 
 4.1.8 ARIN Waitlist
 
 ARIN will only issue future IPv4 assignments/allocations (excluding 4.4 and 
4.10 space) from the ARIN Waitlist. The maximum size aggregate that an 
organization may qualify for at any one time is a /22. Organizations will be 
able to elect a smaller block size
 than they qualify for down to a /24. Only organizations holding a /20 or less 
of IPv4 address space may apply and be approved. Address space distributed from 
the waitlist will not be eligible for transfer for a period of 60 months. This 
policy will be applied
 to all future distributions from the waitlist to include those currently 
listed.
 
 Repeated requests, in a manner that would circumvent 4.1.6, are not allowed: 
an organization currently on the waitlist must wait 90 days after receiving a 
distribution from the waitlist before applying for additional space. ARIN, at 
its sole discretion, may
 waive this requirement if the requester can document a change in circumstances 
since their last request that could not have been reasonably foreseen at the 
time of the original request, and which now justifies additional space. 
Qualified requesters whose request
 will also be advised of the availability of the transfer mechanism in section 
8.3 as an alternative mechanism to obtain IPv4 addresses.
 
 4.1.8.1 Sequencing
 
 The position of each qualified request on the waiting list will be determined 
by the date it was approved. Each organization may have one approved request on 
the waiting list at a time.
 
 4.1.8.2 

Re: [arin-ppml] Revised - Advisory Council Recommendation Regarding NRPM 4.1.8. Unmet Requests

[Tom Fantacone]

Keeping in mind that the original suspension of the waiting list and calls for 
restrictions was based upon statistical evidence that multiple actors were 
committing waiting list fraud, and that we've subsequently learned it was 
really one bad actor with multiple Orgs/identities, who has been caught, 
stopped and punished, I'm reluctant to go overboard on restrictions that harm 
the vast majority of fair players.  Still, we do want to change incentives to 
prevent this from happening again.

1. I support the /22 limit. 
I think the size limit for those on the current waiting list should be 
significantly larger, however.  I suggest an /18 or at least a /19.  These Orgs 
joined the waiting list with the expectation that they would receive at least 
the minimum size they requested in perhaps a year or so, made their business 
plans accordingly, and opted not to use the transfer market when they were 
approved.  Since then prices for IPv4 have risen significantly.  I believe it 
unfair to change the rules on them so drastically.  There is no evidence that 
there are a significant number of fraudsters still on the list.

2. I support that only Orgs holding a /20 or less can get on the waiting list.
I don't want it applied to existing Orgs on the list for the same reasons as in 
1.

3. I oppose the 60 month waiting period before an 8.3 transfer.
It's too long.  Plenty of legitimate Orgs need the IPs, will use them for 2-3 
years, but may not need them after that.  And this policy would incentivize 
them to sit on the addresses till the 60 months runs out, wasting valuable 
resources others could use, as others have pointed out.  I suggest a 24 month 
waiting period.


Regards,



Tom

 On Fri, 24 May 2019 13:04:58 -0400 ARIN  wrote 


At their 16 May meeting, the Advisory Council revised their 
recommendation regarding NRPM 4.1.8. Unmet Requests.

The revised recommendation is hereby submitted to the Public Policy 
Mailing List for a second community discussion period of 14 days, to 
conclude on 7 June.

Once completed, the Board of Trustees will review the AC’s 
recommendation and the PPML discussion.

The full text of the Advisory Council's revised recommendation is below.

Sean Hopkins
Policy Analyst
American Registry for Internet Numbers (ARIN)



Advisory Council recommendation:

This is an updated version which incorporates feedback from the ARIN 
staff and was approved for further community consultation at the ARIN AC 
meeting on May 16, 2019.

In accordance with section 10.2 of the ARIN Policy Development Process, 
the ARIN Advisory Council recommends the following actions to the Board 
of Trustees in response to the Board’s suspension of part of the 
operation of sections 4.1.8, 4.1.8.1 and 4.1.8.2 of the Numbering 
Resource Policy Manual:

Replace section 4.1.8 et. seq. as follows, then reinstate the full 
operation of sections 4.1.8, 4.1.8.1 and 4.1.8.2 immediately.

4.1.8 ARIN Waitlist

ARIN will only issue future IPv4 assignments/allocations (excluding 4.4 
and 4.10 space) from the ARIN Waitlist. The maximum size aggregate that 
an organization may qualify for at any one time is a /22. Organizations 
will be able to elect a smaller block size than they qualify for down to 
a /24. Only organizations holding a /20 or less of IPv4 address space 
may apply and be approved. Address space distributed from the waitlist 
will not be eligible for transfer for a period of 60 months. This policy 
will be applied to all future distributions from the waitlist to include 
those currently listed.

Repeated requests, in a manner that would circumvent 4.1.6, are not 
allowed: an organization currently on the waitlist must wait 90 days 
after receiving a distribution from the waitlist before applying for 
additional space. ARIN, at its sole discretion, may waive this 
requirement if the requester can document a change in circumstances 
since their last request that could not have been reasonably foreseen at 
the time of the original request, and which now justifies additional 
space. Qualified requesters whose request will also be advised of the 
availability of the transfer mechanism in section 8.3 as an alternative 
mechanism to obtain IPv4 addresses.

4.1.8.1 Sequencing

The position of each qualified request on the waiting list will be 
determined by the date it was approved. Each organization may have one 
approved request on the waiting list at a time.

4.1.8.2 Fulfillment

ARIN will fulfill requests on a first-approved basis, subject to the 
size of each available address block as address blocks become available 
for distribution. A timely review of the original request may be 
conducted by ARIN staff. Requests will not be partially filled. Any 
requests met through a transfer will be considered fulfilled and removed 
from the waiting list.
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Re: [arin-ppml] Of interest?

[Tom Fantacone]

 On Sat, 18 May 2019 20:57:02 -0400 John Curran  
wrote 

Ronald - 
 
ARIN requires the verification of organization as an active, legally registered 
business, in good standing, within the ARIN region.   This does involved 
confirming the the incorporation of the business against the state business 
registry in the state provided by the applicant.  We do not presently check 
whether the organization has registered in any other states to conduct 
business, nor do we restrict an organization or its points of contact from 
changing their postal address as desired. 
 
Thanks, 
/John 
 
John Curran 
President and CEO 
American Registry for Internet Numbers 
 
 
 



As far as verifying the organization is legally registered, I think that's all 
ARIN should do.   John, as you point out, it's not much of a deterrent to fraud 
to require foreign registration in other states where the org has a presence 
since it's so easy to do.  



Furthermore, I don't really see the point of checking other state 
registrations.  Maybe some states require it if you've got a physical presence 
there or employees there (though most states are pretty ambiguous about their 
exact requirements for this - a mail drop may not require it).  But lots of 
businesses don't bother to register in every state outside of their main state 
of incorporation, and that doesn't make them any less of an active, legally 
registered business.



Should ARIN also check that orgs file timely tax returns?  And put up posters 
explaining employees' rights under Worker's Comp Insurance?  Businesses are 
supposed to do this, but if they don't they can still be a legally registered 
business with a justifiable need for number resources.  ARIN is a regional 
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Re: [arin-ppml] Advisory Council Recommendation Regarding NRPM 4.1.8. Unmet Requests

[Tom Fantacone]

At 06:18 PM 5/15/2019, John Curran wrote:

On 15 May 2019, at 2:47 PM, Tom Fantacone  wrote:
> If we remove the waiting list activity of this one fraudster, how much
> "statistically likely" fraud is left?
> Was this one bad actor so bad that he accounted for almost all the likely
> fraud on the waiting list?
> Do we still even have a waiting list problem?

Approximately half of the address blocks that were received from the 
waiting list and subsequently transferreed are affiliated with MICFO entities.


That's a lot of addresses and a high percentage of all waiting list 
allocations.  The genesis of ARIN suspending the waiting list and 
requesting/recommending changes to it to prevent fraud was the 
appearance of  "likely fraud" based on the behavior of a small 
handful of bad actors robbing the waiting list of a large number of 
addresses.  Am I right to assume that there was really one bad actor 
(with a handful of bad aliases)?


Obviously ARIN cannot state with certainty that there is no other 
fraud on the list, but if Micfo and its entities had never done what 
they did, would ARIN have even seen a problem with the waiting list?


John Sweeting's presentation of suspected waiting list abuse is here:
Youtube:
<https://www.youtube.com/watch?v=MJHgs4wWO58>https://www.youtube.com/watch?v=MJHgs4wWO58
Transcript:
https://www.arin.net/vault/participate/meetings/reports/ARIN_42/ppm1_transcript.html#anchor_5 



If virtually all this misbehavior was this one guy, and he's been 
stopped, do we still want to change the waiting list system and hurt 
the overwhelming majority of honest players?



> Perhaps we still want to take strong measures to prevent this from
> happening in the future, but before making that determination, I'd like
> to know the answers to the above
>
> And on a related note, can anyone at ARIN tell us the total aggregate
> space that is currently being requested on the waiting list?

The entire waiting list is available here - 
https://www.arin.net/resources/guide/ipv4/waiting_list/


Thanks, John.  I was looking for totals but the list was easy enough 
to import into a spreadsheet and tally up.  By my count the space 
being requested totals to roughly 825K addresses, and about 775K is 
the "minimum acceptable size" total.  The 500K addresses ARIN is 
reclaiming will go a long way in satisfying that demand.


Are any of the existing waiting list requests from Micfo entities or 
have those already been scrubbed?




Thanks!
/John

John Curran
President and CEO
American Registry for Internet Numbers


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Re: [arin-ppml] Draft Policy ARIN-2019-2: Waiting List Block Size Restriction

[Tom Fantacone]

It's a good question, and I also thought it would best be handled by ARIN 
during implementation.

Andrew, am I right in assuming that ARIN is under no obligation to follow the 
current policy for organizations on the waiting list if this new policy is 
implemented?  When they joined the waiting list, they understood the policy at 
the time, but was it with the further understanding that ARIN could change the 
policy?

I can understand why an organization on the list with a legitimate need for, 
say, a /20, would feel cheated if they waited a year and then were suddenly 
told they could only get a /22.  It's like waiting in a long line at the 
supermarket, and then the cash register malfunctions just before it's your 
turn.  But if ARIN has the right to do this, they probably should, since some 
of the larger block requests on the current waiting list are potential abusers 
we're trying to curb.

If they take the /22, at least they'd still have the pre-approval for the 
remainder of their needs and if they really need it, they can go to the 
transfer market.

Tom



 On Thu, 07 Mar 2019 12:53:18 -0500 Andrew Dul 
 wrote 



The draft policy does not specifically   state what happens.  I think the 
best would be to give an   organization currently on the list the option of 
adjusting their   minimum size to the new maximum, if their current minimum 
is less   than the new maximum.  We could include this in the 
implementation   notes or include it in updated draft policy text if 
desired.



Andrew



On 3/7/2019 9:47 AM, Robert Clarke   wrote:





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Forgive me if this has been addressed, but what happens to anyone   on the 
waiting list with a /21+ minimum acceptable allocation   after this 
proposed draft goes into effect? 



Best Regards,



Robert   Clarke

 CubeMotion LLC

 mailto:rob...@cubemotion.com

 M: +1 (844) 244-8140 ex. 512

 300 Lenora Street #454, Seattle, WA, 98121







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Re: [arin-ppml] Draft Policy ARIN-2019-1: Clarify Section 4 IPv4 Request Requirements

[Tom Fantacone]

Chris,



Thanks for the clarification.  I support the policy.



In terms of implementation, I'm guessing when an organization seeks 
pre-approval for a particular block size, if they've transferred out space 
within the last 12 months, ARIN will advise them that their pre-approval will 
only allow them to receive space on the transfer market.  If they haven't 
transferred space out in the last 12 months, they'll have the option, as they 
do now, of receiving space via transfer or going on the waiting list.



Tom





 On Sun, 03 Mar 2019 13:02:35 -0500 Chris Woodfield  
wrote 



Hi Tom - responses inline. 

 

One additional point - the current policy places a limit on how often an 
organization can receive resources from the waiting list. This draft changes 
the hold-down timer so that it now applies to *applications* for new 
allocations under the waiting list policy, not the receipt of resources from 
it. 

 

> On Mar 3, 2019, at 7:18 AM, Tom Fantacone <mailto:t...@iptrading.com> wrote: 

> 

> Chris, 

> 

> The "clarification" part of your proposal seems to be a no brainer (the 
> waiting period is meant to apply to allocations only under section 4).  I 
> assume ARIN staff is already interpreting it this way since that was the 
> intent of the section.  So I wouldn't sever it unless the full policy doesn't 
> gain support in which case we could revisit just inserting the clarification 
> part. 

> 

 

That assumption is my understanding as well. 

 

> Regarding this: 

> "- Disallows organizations that have transferred space to other parties 
> within the past 12 months from applying for additional IPv4 space under NRPM 
> Section 4. " 

> 

> I want to make sure I understand it correctly.  If you transfer out space via 
> 8.2/8.3/8.4, does this restriction mean you just can't receive space via the 
> waiting list for 12 months, or via any mechanism (waiting list/transfer) for 
> 12 months?  I think it means from the waiting list only, but want to be sure. 

> 

 

That is correct - note the phrase “...under this section...” in the proposal 
text. 

 

Thanks, 

 

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Re: [arin-ppml] Draft Policy ARIN-2019-1: Clarify Section 4 IPv4 Request Requirements

[Tom Fantacone]

Chris,



The "clarification" part of your proposal seems to be a no brainer (the waiting 
period is meant to apply to allocations only under section 4).  I assume ARIN 
staff is already interpreting it this way since that was the intent of the 
section.  So I wouldn't sever it unless the full policy doesn't gain support in 
which case we could revisit just inserting the clarification part.



Regarding this:

"- Disallows 
organizations that have transferred space to other parties within the 
past 12 months from applying for additional IPv4 space under NRPM 
Section 4. "



I want to make sure I understand it correctly.  If you transfer out space via 
8.2/8.3/8.4, does this restriction mean you just can't receive space via the 
waiting list for 12 months, or via any mechanism (waiting list/transfer) for 12 
months?  I think it means from the waiting list only, but want to be sure.



Tom







 On Sat, 02 Mar 2019 13:48:01 -0500 Chris Woodfield  
wrote 



Speaking as the policy author, I’ll make two points:



1. I’m aware that given the other discussions around waiting list policy that 
are ongoing, this proposal may well be rendered moot by future policy changes. 
I still believe that this is worth pursuing as there’s a current need for 
clarification and increased disincentives for bad behavior today.

2. I’m deliberately killing two not-terribly-related birds with one stone with 
this proposal, based on the fact that the two issues noted from the PER can be 
addressed by adding language to the same NRPM text. Happy to consider severing 
them if the community prefers.



Thanks,



-Chris



> On Mar 2, 2019, at 9:33 AM, mailto:hostmas...@uneedus.com wrote:

> 

> I think it is time to start the ball on the other policies.

> 

> +1 on this.  It seems focused on those gathering resources to resell.

> 

> Albert Erdmann

> Network Administrator

> Paradise On Line Inc.

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Re: [arin-ppml] Draft Policy ARIN-2019-2: Waiting List Block Size Restriction

[Tom Fantacone]

Hi Bill,

At 06:35 PM 2/28/2019, William Herrin wrote:

On Tue, Feb 26, 2019 at 9:49 AM ARIN  wrote:
> A significant percentage of organizations that receive blocks
> from the waiting list subsequently issue these blocks to other
> organizations via 8.3 or 8.4 transfers shortly after the one year
> waiting period required before engaging in such outbound transfers.

I'm shocked to learn that people are playing arbitrage with the
transfer process. Oh wait, no I'm not. I may have even expressed my
expectation that we'd see this sort of behavior back when we debated
the transfer policies. If I had the time, I might dig out my old
emails just so I could say I told you so.


While we have a problem with the waiting list 
that we’re trying to address here, I think it's 
important to point out that the transfer market 
as a whole has proven an excellent vehicle for 
moving number resources from those who no longer 
need them to those who do.  This “gaming of the 
system” is restricted to a subset of the waiting 
list, and the number of blocks issued on the 
waiting list is less than 10% of the blocks 
transferred in the ARIN region during the same 
time period.  (682 blocks have been issued via 
the waiting list, and a quick look at ARIN’s 
transfer stats indicates roughly 8,000 blocks 
transferred in the same time frame since 2015 if 
I’m reading it correctly).  If we look at the 
ratio in terms of total address space, I suspect 
the waiting list comprises an even smaller 
percentage, though I can’t readily find those figures.


Furthermore, even within the waiting list, the 
problem appears with only a small percentage of 
recipients (25 re-transfers out of 682 total), 
although this does impact a high percentage of 
the waiting list block space since the abusers 
are almost entirely doing this with larger blocks.


The point is that while “The problem statement is 
pretty damning…” (quoting Kevin Blumberg), the 
sky is not falling due to the transfer 
markets.  It’s damning within the small subset of 
re-transfers of blocks received off the waiting list.



> the organization will be provided the option to be placed on
> a waiting list of pre-qualified recipients, listing both the block size
> qualified for or a /22, whichever is smaller, and the smallest block
> size acceptable, not to exceed a /22.

I fail to see how this solves the problem. For $20k a pop, I can clear
a tidy profit on a year, a shell company and some paperwork. Sure I'd
rather get $200k a pop but the change doesn't make the effort
unattractive. I really just need to create more shell companies.

This approach is reactive. Oh, the fraud is mostly on the big blocks
so stop that. Oh, now the fraud is on the smaller blocks, what do we
do? Don't react. Get ahead of the problem. That's what you do.


Yes, it’s possible there is abuse with the small 
blocks off the waiting list as well, but so far 
we aren’t seeing it (only 3% of smaller blocks 
have been re-transferred vs. 42% of the larger 
blocks).  Now, perhaps if we restrict the waiting 
list block size to a /22 these bad actors will 
start playing the same game with /22s, but we 
don’t have any evidence that will occur.


Others have pointed out issues of abuse in RIPE 
where LIRs are spun up to grab /22s from the 
final /8, but the 2 environments are 
different.  First, there is no justification 
requirement in RIPE.  Form a corp, have a 
presence in the RIPE region, and you get a /22 
whether you can justify it or not.  That may not 
exactly be a noble action in support of the 
spirit of the RIPE community, but for the most 
part, it is policy-compliant.  In ARIN, you have 
to justify your need and sign an affidavit 
affirming your justification which makes willful 
misrepresentation fraudulent.   That’s a much 
higher disincentive to go through for a /22 than 
in RIPE, where basically it’s just frowned 
upon.  And per John Curran’s remarks, ARIN has 
revoked address space when investigating why some 
of these actors are selling their waiting list 
space shortly after receiving it.  So these 
gamers could risk an audit of their full address 
holdings in order to con ARIN out of a /22.  The 
“abuse” in RIPE regarding the final /8 is also 
heavily concentrated in a few member nations and, 
suffice it to say, those same nations are not ARIN members.


Regards,

Tom


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Re: [arin-ppml] Draft Policy ARIN-2019-2: Waiting List Block Size Restriction

[Tom Fantacone]

1.5M IPv4 addresses have been allocated, 
in 700 allocations, to organizations meeting their continuing need for IPv4 
addresses, including a few larger allocations to presumably larger 
organizations, and many smaller allocations to presumably smaller organizations.



Unfortunately, it seems a small minority have decided to use this policy to 
profiteer.  This was recognized as a possible outcome of the original policy, 
but the community didn't want to limit the possibility of larger allocations 
from this policy only on the potential for abuse. Now that we have at least 
statistical evidence of abuse, it is therefore probably prudent to not allow 
further large allocations through this policy. The proposed /22 limit seems 
reasonable and should be effective in limiting the financial incentives to 
profiteer.  That is not to say it will completely eliminate the possibility of 
profiteering, however, good policy doesn't have to be perfect in this regard.  
I think we just need to eliminate the possibility of a gigantic windfall from 
these larger blocks. The benefits to the community of continuing to allocate 
smaller blocks seem to outweigh the relatively small risk of profiteering on 
these smaller block.



I support the general idea of this policy, however, I think we need to fully 
consider all the possibilities on how to adjust this policy. But, lets not 
forget overall this has been a very effective policy.



Thanks.





    



On Wed, Feb 27, 2019 at 10:31 AM Tom Fantacone <mailto:t...@iptrading.com> 
wrote:

Kevin,



I agree that statistical data should be used in this case to validate that the 
problem exists.  Not only do non-disclosures prevent ARIN from presenting most 
evidence of specific cases, but ARIN acknowledges that there may be specific 
instances where transferring out a block received from the waiting list is not 
fraudulent at all, but due to unusual but legitimate business circumstances.  
It would not be fair to publicly point out all actors in potential fraud when a 
few of them might not be culpable.  But the statistical evidence is strong 
enough to indicate that fraud exists.



In that regard, in addition to the data John Curran provided showing the high 
percentage of larger blocks that have been re-transferred, it's worth reviewing 
the presentation by John Sweeting at the ARIN 42 meeting last October where he 
discussed the evidence and solicited possible solutions from the community.



Transcript;

 
https://www.arin.net/vault/participate/meetings/reports/ARIN_42/ppm1_transcript.html#anchor_5
 



Youtube;

 https://www.youtube.com/watch?v=MJHgs4wWO58



Presentation;

 
https://www.arin.net/vault/participate/meetings/reports/ARIN_42/PDF/PPM/sweeting-policy.pdf
 



Specifically, John discusses the re-transfer statistics, the fact that several 
waiting list orgs already have at least a /16 of space, and the cases of 8.2 
mergers performed by orgs on the waiting list to consolidate their holdings, 
avoid the one year wait, and then perform an 8.3 transfer.



Regards,



Tom



At 03:06 AM 2/27/2019, Kevin Blumberg wrote:

 

Ronald,



To be clear. For the purposes of the Policy Proposal I'm perfectly content with 
the aggregate data that has been provided.



The problem statement from the author, in my view, matches up with the data 
provided by John Curran. 



Kevin





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Re: [arin-ppml] Draft Policy ARIN-2019-2: Waiting List Block Size Restriction

[Tom Fantacone]

Kevin,

I agree that statistical data should be used in this case to validate 
that the problem exists.  Not only do non-disclosures prevent ARIN 
from presenting most evidence of specific cases, but ARIN 
acknowledges that there may be specific instances where transferring 
out a block received from the waiting list is not fraudulent at all, 
but due to unusual but legitimate business circumstances.  It would 
not be fair to publicly point out all actors in potential fraud when 
a few of them might not be culpable.  But the statistical evidence is 
strong enough to indicate that fraud exists.


In that regard, in addition to the data John Curran provided showing 
the high percentage of larger blocks that have been re-transferred, 
it's worth reviewing the presentation by John Sweeting at the ARIN 42 
meeting last October where he discussed the evidence and solicited 
possible solutions from the community.


Transcript;
https://www.arin.net/vault/participate/meetings/reports/ARIN_42/ppm1_transcript.html#anchor_5

Youtube;
https://www.youtube.com/watch?v=MJHgs4wWO58

Presentation;
https://www.arin.net/vault/participate/meetings/reports/ARIN_42/PDF/PPM/sweeting-policy.pdf 



Specifically, John discusses the re-transfer statistics, the fact 
that several waiting list orgs already have at least a /16 of space, 
and the cases of 8.2 mergers performed by orgs on the waiting list to 
consolidate their holdings, avoid the one year wait, and then perform 
an 8.3 transfer.


Regards,

Tom

At 03:06 AM 2/27/2019, Kevin Blumberg wrote:

Ronald,

To be clear. For the purposes of the Policy Proposal I'm perfectly 
content with the aggregate data that has been provided.


The problem statement from the author, in my view, matches up with 
the data provided by John Curran.


Kevin


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