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

[Martin Hannigan]

On Tue, Aug 27, 2019 at 5:10 AM Owen DeLong  wrote:

>
>
> On Aug 26, 2019, at 18:09 , Martin Hannigan  wrote:
>
>
>
> On Thu, Aug 15, 2019 at 5:10 PM Owen DeLong  wrote:
>
>> 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.
>>
>
> Data: see "reserved"
>
> https://www.arin.net/vault/knowledge/statistics/2018.html
>
> If you look at the numbers you can see a mild acceleration and then what
> looks like it could be a deceleration of assignments from this pool (and
> many others ironically). Note, the time period is only a year. My
> conclusions aren't rock solid as a result. I'm really just eyeballing.
>
>
>>
>> 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.
>>
>
> Do you think having pools of the magnitude and current use profile of 4.10
> and perhaps even 4.10 are in need of being re-evaluated?
>
> Admittedly, its a little re-arranging of the deck chairs. However, if the
> waiting list is truly stocked with people who have a need and aren't just
> using it to hedge against a transfer they already completed it may make
> sense to make adjustments. And to potentially apply it there. I won't speak
> to the authors intention on 4.10, but I had a hand in 4.4. I determined and
> argued for the pool size based on conditions on the ground at the time.
> Today I would argue IXP growth in NA is somewhat flat, that most are
> commercial in nature and won't have trouble using the transfer market. Yes,
> there are some that aren't for profit, but even those usually have an easy
> time fundraising.
>
>
> I think that IXPs are a sufficiently important benefit to peering density
> and interconnection that even if they are commercial, I don’t mind holding
> a carve-out for them. Note also that 4.4. covers some TLD and Root server
> addressing needs as well.
>

Noted. And agreed on IXPs. The pools primary intention, at least as I
recall the expansion some years back, was to protect against the unknown of
the market. I don't think anyone had a clue about what the cost of
addresses were going to be and when. Today, from my seat on the Internet, I
see stability.


> I think that the current sizes are working well for not. If we get a
> couple of years down the road and see that they really aren’t being used
> (and IPv4 is still perceived as a vital growth commodity), I’d be
> potentially willing to re-evaluate at that time, but in that case, if we
> shrank the pools, I’d probably want to use whatever we released to drain
> the waiting list queue (which I know will make the author’s skin crawl).
>
>
Whether it is the waiting list or something else, I'm not sure it matters.
And we said we'd re-evaluate the pools a few years down the road then IIRC.

If anything should have a pool, a small pool for the Caribbean makes sense.
> The contrast in economic conditions and market norms justify it easily in
> my opinion. Such as the US large volume transit price per mb/s between
> $0.05 and $0.15 nd for most there we're substantially north of a $1.00.
>
>
> I’m not sure what the relationship is between transit pricing and the need
> for IPv4 addresses. If anything, most of the Caribbean economies have a
> slight advantage in the IPv4 market place as few of them need short
> prefixes.
>

Sorry if I wasn't clear. Transit pricing is orthogonal to IXP value. The
more costly transit is, the more valuable in many ways the IXP becomes.
Thinking about ARIN's service region mainland bits are cheap. Island bits
are expensive due to much history, incumbency and granted monopolization.


> I also think that Caribbean transit prices will continue to fall and while
> they might not reach parity with the US in the next few years, the gap will
> close.
>
>
Its sort of interesting in that a successful IXP benefits transit,
especially on an island. Curacao is the case study. The more caching that
took place and saved costs for local networks, the more transit was needed.
I'm near certain that it caused growth in transit use albeit the ratio is
where the savings and offsets made that occur.

YMMV.
>
> However, if you do feel that such a carveout would be desirable, please
> submit  a policy proposal. Make sure to cover where the addresses to stock
> the pool are supposed to come from and what, exactly, are the criteria for
> consuming from the pool. Lots of details to mask many devils in there, IMHO.
>
>
I know a lot about the 

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

[Owen DeLong]

> On Aug 26, 2019, at 18:09 , Martin Hannigan  wrote:
> 
> 
> 
> On Thu, Aug 15, 2019 at 5:10 PM Owen DeLong  > wrote:
> 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.
> 
> Data: see "reserved"
> 
> https://www.arin.net/vault/knowledge/statistics/2018.html 
> 
> 
> If you look at the numbers you can see a mild acceleration and then what 
> looks like it could be a deceleration of assignments from this pool (and many 
> others ironically). Note, the time period is only a year. My conclusions 
> aren't rock solid as a result. I'm really just eyeballing.
>  
> 
> 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.
> 
> Do you think having pools of the magnitude and current use profile of 4.10 
> and perhaps even 4.10 are in need of being re-evaluated?  
> 
> Admittedly, its a little re-arranging of the deck chairs. However, if the 
> waiting list is truly stocked with people who have a need and aren't just 
> using it to hedge against a transfer they already completed it may make sense 
> to make adjustments. And to potentially apply it there. I won't speak to the 
> authors intention on 4.10, but I had a hand in 4.4. I determined and argued 
> for the pool size based on conditions on the ground at the time. Today I 
> would argue IXP growth in NA is somewhat flat, that most are commercial in 
> nature and won't have trouble using the transfer market. Yes, there are some 
> that aren't for profit, but even those usually have an easy time fundraising. 

I think that IXPs are a sufficiently important benefit to peering density and 
interconnection that even if they are commercial, I don’t mind holding a 
carve-out for them. Note also that 4.4. covers some TLD and Root server 
addressing needs as well.

I think that the current sizes are working well for not. If we get a couple of 
years down the road and see that they really aren’t being used (and IPv4 is 
still perceived as a vital growth commodity), I’d be potentially willing to 
re-evaluate at that time, but in that case, if we shrank the pools, I’d 
probably want to use whatever we released to drain the waiting list queue 
(which I know will make the author’s skin crawl).

> If anything should have a pool, a small pool for the Caribbean makes sense. 
> The contrast in economic conditions and market norms justify it easily in my 
> opinion. Such as the US large volume transit price per mb/s between $0.05 and 
> $0.15 nd for most there we're substantially north of a $1.00. 

I’m not sure what the relationship is between transit pricing and the need for 
IPv4 addresses. If anything, most of the Caribbean economies have a slight 
advantage in the IPv4 market place as few of them need short prefixes.

I also think that Caribbean transit prices will continue to fall and while they 
might not reach parity with the US in the next few years, the gap will close.

YMMV.

However, if you do feel that such a carveout would be desirable, please submit  
a policy proposal. Make sure to cover where the addresses to stock the pool are 
supposed to come from and what, exactly, are the criteria for consuming from 
the pool. Lots of details to mask many devils in there, IMHO.

Owen


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

[Martin Hannigan]

On Thu, Aug 15, 2019 at 5:10 PM Owen DeLong  wrote:

> 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.
>

Data: see "reserved"

https://www.arin.net/vault/knowledge/statistics/2018.html

If you look at the numbers you can see a mild acceleration and then what
looks like it could be a deceleration of assignments from this pool (and
many others ironically). Note, the time period is only a year. My
conclusions aren't rock solid as a result. I'm really just eyeballing.


>
> 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.
>

Do you think having pools of the magnitude and current use profile of 4.10
and perhaps even 4.10 are in need of being re-evaluated?

Admittedly, its a little re-arranging of the deck chairs. However, if the
waiting list is truly stocked with people who have a need and aren't just
using it to hedge against a transfer they already completed it may make
sense to make adjustments. And to potentially apply it there. I won't speak
to the authors intention on 4.10, but I had a hand in 4.4. I determined and
argued for the pool size based on conditions on the ground at the time.
Today I would argue IXP growth in NA is somewhat flat, that most are
commercial in nature and won't have trouble using the transfer market. Yes,
there are some that aren't for profit, but even those usually have an easy
time fundraising.

If anything should have a pool, a small pool for the Caribbean makes sense.
The contrast in economic conditions and market norms justify it easily in
my opinion. Such as the US large volume transit price per mb/s between
$0.05 and $0.15 nd for most there we're substantially north of a $1.00.



> I oppose the policy as written and as proposed to be amended.
>
>
I already said I opposed it, but just in case. Yes, +1.


Owen
>
>
> On Aug 15, 2019, at 13:55 , WOOD Alison * DAS via ARIN-PPML <
> arin-ppml@arin.net> wrote:
>
> Thank you for the continued input on this draft policy proposal.
>
> I will be updating the text of the draft policy to include both 4.4 and
> 4.10 pools.  Point of information, the 4.4 pool currently has approximately
> 391 /24’s and 4.10 has approximately 15,753 /24’s available and are not
> estimated to run out in the next five years.
>
> Please keep your feedback coming, it is very helpful for the council.
>
> -Alison
>
> *From:* ARIN-PPML [mailto:arin-ppml-boun...@arin.net
> ] *On Behalf Of *Fernando Frediani
> *Sent:* Tuesday, July 30, 2019 6:44 AM
> *To:* arin-ppml 
> *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

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

[Fernando Frediani]

nput.
>
> 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 
>  *On Behalf Of *Fernando Frediani
> *Sent:* Thursday, August 15, 2019 6:04 PM
> *To:* 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 
>  *On Behalf Of *Owen DeLong
> *Sent:* Thursday, August 15, 2019 5:10 PM
> *To:* WOOD Alison * DAS  
> *Cc:* arin-ppml  
> *Subject:* Re: [arin-ppml] Draft Policy ARIN-2019-17: Returned Addresse

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

[Mueller, Milton L]

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 <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 <mailto:arin-ppml-boun...@arin.net> 
On Behalf Of Owen DeLong
Sent: Thursday, August 15, 2019 5:10 PM
To: WOOD Alison * DAS <mailto:alison.w...@oregon.gov>
Cc: arin-ppml <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 
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 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 
al

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

[John]

Agree with Brian and Owen.  Also oppose this policy proposal.

Sent from my iPad

> On Aug 16, 2019, at 10:50 AM, Brian Jones  wrote:
> 
> I oppose this policy as written, mainly for the reasons Owen outlines. This 
> would eliminate the wait list and possibly lock up useful resources now that 
> may not be as relevant or useful in the future. It does also seem contrary to 
> ARIN's mission in my view. 
> 
> —
> Brian Jones, CSP, CSM, CSPO
> NIS Virginia Tech
> bjo...@vt.edu
> 
> 
>> On Thu, Aug 15, 2019 at 5:10 PM Owen DeLong  wrote:
>> 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 
>>>  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 
>>> 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:
>>> 
>&g

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

[Brian Jones]

I oppose this policy as written, mainly for the reasons Owen outlines. This
would eliminate the wait list and possibly lock up useful resources now
that may not be as relevant or useful in the future. It does also seem
contrary to ARIN's mission in my view.

—
Brian Jones, CSP, CSM, CSPO
NIS Virginia Tech
bjo...@vt.edu


On Thu, Aug 15, 2019 at 5:10 PM Owen DeLong  wrote:

> Really, it seems to me that this proposal is another attempt at
> eliminating the waiting list for unmet requests.
>
> The first attempt (ARIN auctions the space) met with resistance from
> ARIN’s legal team (for good reason), so now this attempts to sequester the
> space where it will be hard to distribute rather than allowing the waiting
> list to have any potential to compete with the transfer market.
>
> The proposed targets (4.4 and 4.10 pools) are well stocked and unlikely to
> run out in any useful IPv4 lifetime.
>
> As such, restocking them from returned space strikes me as just a way to
> sequester this space where it cannot be used.
>
> IMHO, this is counter to ARIN’s mission and should not be allowed.
>
> I oppose the policy as written and as proposed to be amended.
>
> Owen
>
>
> On Aug 15, 2019, at 13:55 , WOOD Alison * DAS via ARIN-PPML <
> arin-ppml@arin.net> wrote:
>
> Thank you for the continued input on this draft policy proposal.
>
> I will be updating the text of the draft policy to include both 4.4 and
> 4.10 pools.  Point of information, the 4.4 pool currently has approximately
> 391 /24’s and 4.10 has approximately 15,753 /24’s available and are not
> estimated to run out in the next five years.
>
> Please keep your feedback coming, it is very helpful for the council.
>
> -Alison
>
> *From:* ARIN-PPML [mailto:arin-ppml-boun...@arin.net
> ] *On Behalf Of *Fernando Frediani
> *Sent:* Tuesday, July 30, 2019 6:44 AM
> *To:* arin-ppml 
> *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
> >* 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.
>
> Howev

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

[Fernando Frediani]

Hello

On 16/08/2019 12:41, Mike Burns wrote:


Hi Fernando,



But absent the free pool, that mechanism is not necessary and fair, it 
is the opposite of that.  In fact, you seem to be injecting items that 
could be considered obviously unfair, such as favoring new entrants 
and smaller companies.


This is quiet obvious for me, this is the way it has been done so far in 
other RIRs and I don't think they and the community who developed such 
policies are wrong. It doesn't take much thought to consider that 
existing companies who already hold IP space have ways to keep going,  
re-use and optimize the use of IPv4 in order to make more for less and 
as time goes it will be natural to use them more for transition 
mechanisms and survive. New entrants would be hugely discriminated if 
they become an AS and have to go straight to the market. Pushing them to 
it would be a way for current holders to protect themselves from new 
competition creating artificial barriers, using a wrong mechanism and 
also to not treat them the same way they were treated when they first 
asked they IP space in the past. Therefore is pretty fair and correct to 
assign space only to new entrants and other situations allowed by 
sections like 4.10.


I disagree with your opinions about markets being unnatural and not 
ideal, I hold the opposite view. Markets are the ideal method of 
fairly distributing scarce and valuable assets, and that is why they 
naturally evolve in every society.


Of course you do. I apologize if this argument bothers you, but it is a 
fact to me that trying to build such policies to push people that way 
only favors transfer market, not organizations and not the internet 
ecosystem, not for new companies to exist in the Internet.
Market is far from an ideal method for distributing scarce resources 
simply because who has more money will take them all and not necessary 
who need the most and new entrants are the case.
If we were talking about a private resource that companies purchased, 
own and is not irrevocable fine it belong to them and they may sell for 
whatever amount they like, but we are talking about IP space which is 
very different.


I also agree with the executive board decision to shut the waiting 
list while at the same time observe that this unpalatable action was 
only required due to the fraud magnet which is the waiting list.


Opening an office in Africa is to access the free pool remaining in 
AFRINIC and is unrelated to inter-RIR transfers.



If they do and use the addresses in Africa region then no problem at all.


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  *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 inp

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

[Mike Burns]

Hi Fernando,

 

Thanks for your reply and sorry if I misinterpreted you.

You used the words “necessary and fair” to refer to the old manner of 
allocation IPv4 space, which is ensconced in the waiting list policy. You also 
say that “we must never forget some principles that has always been base for 
correct IP space allocations”. What you claim are necessary and fair 
distribution mechanisms are related to the presence of a free pool. With a free 
pool, it is necessary and fair to allocate them as the RIRs historically did, 
with regard only to the justification of need as a determinant of receipt. 

 

But absent the free pool, that mechanism is not necessary and fair, it is the 
opposite of that.  In fact, you seem to be injecting items that could be 
considered obviously unfair, such as favoring new entrants and smaller 
companies. 

 

I disagree with your opinions about markets being unnatural and not ideal, I 
hold the opposite view. Markets are the ideal method of fairly distributing 
scarce and valuable assets, and that is why they naturally evolve in every 
society.

 

I also agree with the executive board decision to shut the waiting list while 
at the same time observe that this unpalatable action was only required due to 
the fraud magnet which is the waiting list.

 

Opening an office in Africa is to access the free pool remaining in AFRINIC and 
is unrelated to inter-RIR transfers.

 

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  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

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

[Fernando Frediani]

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  *On Behalf Of *Fernando 
Frediani

*Sent:* Thursday, August 15, 2019 6:04 PM
*To:* 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 pr

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

[Mike Burns]

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  On Behalf Of Fernando Frediani
Sent: Thursday, August 15, 2019 6:04 PM
To: 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  <mailto:arin-ppml-boun...@arin.net> 
 On Behalf Of Owen DeLong
Sent: Thursday, August 15, 2019 5:10 PM
To: WOOD Alison * DAS  <mailto:alison.w...@oregon.gov> 
Cc: arin-ppml  <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 t

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

[Martin Hannigan]

On Thu, Aug 15, 2019 at 5:10 PM Owen DeLong  wrote:

> 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.
>
>

For different reasons, but generally close enough, agree. +1











>
> On Aug 15, 2019, at 13:55 , WOOD Alison * DAS via ARIN-PPML <
> arin-ppml@arin.net> wrote:
>
> Thank you for the continued input on this draft policy proposal.
>
> I will be updating the text of the draft policy to include both 4.4 and
> 4.10 pools.  Point of information, the 4.4 pool currently has approximately
> 391 /24’s and 4.10 has approximately 15,753 /24’s available and are not
> estimated to run out in the next five years.
>
> Please keep your feedback coming, it is very helpful for the council.
>
> -Alison
>
> *From:* ARIN-PPML [mailto:arin-ppml-boun...@arin.net
> ] *On Behalf Of *Fernando Frediani
> *Sent:* Tuesday, July 30, 2019 6:44 AM
> *To:* arin-ppml 
> *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
> >* 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 ot

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

[Fernando Frediani]

Hello Albert

I would agree with most of what you said specially with the condition to 
have a prove use of IPv6 in order to receive any IPv4 if that is 
according to whatever policy for waitlist.
However the 4.10 conditions are very specific on how these resources 
must be used in order to be justified and for a new entrant that may not 
be the case for all possible scenarios and it would not be fair with 
them. Therefore things need to be differentiated for both cases and that 
doesn't exclude the need of prove IPv6 deployment, just without the 
bindings of 4.10 for new entrants.

Regards
Fernando

On 15/08/2019 22:38, hostmas...@uneedus.com wrote:

I am in favor of this proposal.

4.10 will in effect become the new "waiting list", but with an 
additional condition that I feel is important.  That condition is a 
requirement for the use of IPv6. The only other real change from the 
existing waiting is the size of each "dip", and the total size that 
one can obtain.  The current waiting list is more generous versus this 
proposal.  I consider that "feature" to be a positive change.


I am ready for ARIN to start an IPv6 requirement whenever it allocates 
IPv4 space. The current waiting list has NO IPv6 requirement.  This 
proposal is a good start to that goal.


I would consider it not responsible at this point for a new entrant to 
not implement IPv6 at this point. Let those that want to continue or 
newly establish new IPv4 infrastructure to go to the marketplace, and 
reserve all IPv4 returns for those that have or will establish IPv6.


Albert Erdmann
Network Administrator
Paradise On Line Inc.

On Thu, 15 Aug 2019, Owen DeLong wrote:

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 
 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 
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 i

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

[hostmaster]

I am in favor of this proposal.

4.10 will in effect become the new "waiting list", but with an additional 
condition that I feel is important.  That condition is a requirement for 
the use of IPv6. The only other real change from the existing waiting is 
the size of each "dip", and the total size that one can obtain.  The 
current waiting list is more generous versus this proposal.  I consider 
that "feature" to be a positive change.


I am ready for ARIN to start an IPv6 requirement whenever it allocates 
IPv4 space. The current waiting list has NO IPv6 requirement.  This 
proposal is a good start to that goal.


I would consider it not responsible at this point for a new entrant to not 
implement IPv6 at this point. Let those that want to continue or newly 
establish new IPv4 infrastructure to go to the marketplace, and reserve 
all IPv4 returns for those that have or will establish IPv6.


Albert Erdmann
Network Administrator
Paradise On Line Inc.

On Thu, 15 Aug 2019, Owen DeLong wrote:


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 
 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 
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 
 wrote 
 
  I find it interesting the idea of 

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

[Owen DeLong]

> On Aug 15, 2019, at 14:47, 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 IPv4 continues to plague the internet for another 20+ years, then we have 
much bigger problems. 

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

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

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

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

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

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

Owen

> I support the policy as written and amended.
>  
> Regards,
> Mike
>  
>  
>  
> From: ARIN-PPML  On Behalf Of Owen DeLong
> Sent: Thursday, August 15, 2019 5:10 PM
> To: WOOD Alison * DAS 
> Cc: arin-ppml 
> 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 
>  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 
> 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 the

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

[Fernando Frediani]

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  *On Behalf Of *Owen DeLong
*Sent:* Thursday, August 15, 2019 5:10 PM
*To:* WOOD Alison * DAS 
*Cc:* arin-ppml 
*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
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 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
/

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

[Mike Burns]

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  On Behalf Of Owen DeLong
Sent: Thursday, August 15, 2019 5:10 PM
To: WOOD Alison * DAS 
Cc: arin-ppml 
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 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 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:

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

[Steven Ryerse via ARIN-PPML]

I agree
-1


Steven Ryerse
President
100 Ashford Center North, Suite 110, Atlanta, GA  30338
770.656.1460 - Cell
770.399.9099 - Office
770.392.0076 - Fax

[cid:image001.jpg@01D55390.2480E240]℠ Eclipse Networks, Inc.
Conquering Complex Networks℠

From: ARIN-PPML  On Behalf Of Owen DeLong
Sent: Thursday, August 15, 2019 5:10 PM
To: WOOD Alison * DAS 
Cc: arin-ppml 
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 
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 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 
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.
Therefor

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

[Owen DeLong]

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 
>  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 
> 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
>  
> <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 a

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

[WOOD Alison * DAS via ARIN-PPML]

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 
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 
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.
>

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

[Fernando Frediani]

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 
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

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 
 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 

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

[Fernando Frediani]

Hello Mike

What about new entrants ? I firmly see that new entrants and the most 
important to be looked at as having a minimal allocation from the RIR is 
the bare minimal condition for them to exist in the Internet in first 
place and do minimal business, therefore any recovered addresses should 
be prioritized to be given to these new entrants. After that in terms of 
importance comes the 4.10 and 4.4 sections that are equally important as 
they apply to Autonomous Systems that already exist in the Internet. As 
mentioned 4.10 doesn't necessarily apply to all types of ISP or End-users.
If new entrants are not privileged with any space that ARIN has to 
distribute they become an ASN, receive a IPv6 and must go to market to 
get *any* IPv4 space which would be not only unfair with them but also 
but a quiet big block for them to exist as business.


Therefore I can only support this draft if it's changed to reflect this 
scenario.


Best regards
Fernando Frediani

On 29/07/2019 18:32, Mike Burns wrote:


Hi Mike,

My purpose in authoring this proposal was to starve the Waiting list 
to death by preventing further unpredictable influxes of addresses.


I would support allocating returned addresses to both 4.10 and 4.4 
pools, or whichever might need them most.


I know the 4.10 pool is largely untapped, but I’m not sure about the 
4.4 pool, so maybe it would be better to place returned space there.


Regards,
Mike

*From:* ARIN-PPML  *On Behalf Of *Mike 
Arbrouet

*Sent:* Monday, July 29, 2019 5:03 PM
*To:* Fernando Frediani ; arin-ppml@arin.net
*Subject:* Re: [arin-ppml] Draft Policy ARIN-2019-17: Returned 
Addresses to the 4.10 Reserved Pool


Having read the Problem Statement and understood what is being 
proposed, I'd kindly advise that this policy should also consider 
allocating the returned addresses not only to the ARIN 4.10 reserved 
pool - but also the ARIN 4.4 micro-allocation pool for critical 
infrastructure providers of the Internet , specifically public 
exchange points. Both would help on the improvement of the end-user 
experience given the actual depletion of IPv4


Mike Arbrouet, CISSP- CISM



*From:*ARIN-PPML <mailto:arin-ppml-boun...@arin.net>> on behalf of Fernando Frediani 
mailto:fhfredi...@gmail.com>>

*Sent:* Monday, July 29, 2019 10:39:32 AM
*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


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"

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

[Mike Burns]

Hi Mike,

 

My purpose in authoring this proposal was to starve the Waiting list to
death by preventing further unpredictable influxes of addresses.

I would support allocating returned addresses to both 4.10 and 4.4 pools, or
whichever might need them most.

I know the 4.10 pool is largely untapped, but I'm not sure about the 4.4
pool, so maybe it would be better to place returned space there.

 

Regards,
Mike

 

 

From: ARIN-PPML  On Behalf Of Mike Arbrouet
Sent: Monday, July 29, 2019 5:03 PM
To: Fernando Frediani ; arin-ppml@arin.net
Subject: Re: [arin-ppml] Draft Policy ARIN-2019-17: Returned Addresses to
the 4.10 Reserved Pool

 

Having read the Problem Statement and understood what is being proposed, I'd
kindly advise that this policy should also consider allocating the returned
addresses not only to the ARIN 4.10 reserved pool - but also the ARIN 4.4
micro-allocation pool for critical infrastructure providers of the Internet
, specifically public exchange points. Both would help on the improvement of
the end-user experience given the actual depletion of IPv4

 

 

Mike Arbrouet, CISSP- CISM

 

  _  

From: ARIN-PPML mailto:arin-ppml-boun...@arin.net> > on behalf of Fernando Frediani
mailto:fhfredi...@gmail.com> >
Sent: Monday, July 29, 2019 10:39:32 AM
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 

 

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)
>>
>&g

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

[Mike Arbrouet]

Having read the Problem Statement and understood what is being proposed, I'd 
kindly advise that this policy should also consider allocating the returned 
addresses not only to the ARIN 4.10 reserved pool - but also the ARIN 4.4 
micro-allocation pool for critical infrastructure providers of the Internet , 
specifically public exchange points. Both would help on the improvement of the 
end-user experience given the actual depletion of IPv4



Mike Arbrouet, CISSP- CISM



From: ARIN-PPML  on behalf of Fernando Frediani 

Sent: Monday, July 29, 2019 10:39:32 AM
To: arin-ppml@arin.net
Subject: Re: [arin-ppml] Draft Policy ARIN-2019-17: Returned Addresses to the 
4.10 Reserved Pool

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 

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

[Fernando Frediani]

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

[ARIN]

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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