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[ppml] Policy Proposal 2007-10 - Staff Assessment

Policy Proposal 2007-10
End Site Immediate Need Policy

ARIN Staff Assessment

The assessment of this proposal includes comments from ARIN staff and
the ARIN General Counsel. It contains analysis of procedural, legal, and
resource concerns regarding the implementation of this policy proposal
as it is currently stated. Any changes to the language of the proposal
may necessitate further analysis by staff and Counsel.

I.	Proposal

   Policy Proposal 2007-10 is available as Annex A below and at:
   http://www.arin.net/policy/proposals/2007_10.html

II.	Understanding of the proposal

   ARIN staff understands that if Policy Proposal 2007-9: Modernization
of ISP Immediate Need is adopted, then Policy Proposal 2007-10: End Site
Immediate Need Policy would establish the immediate need policy for
end-users. The minimum assignment would be the ARIN’s minimum assignment
as defined elsewhere in the NRPM, and the maximum would be a /16 IPv4
address block.  The policy also defines a 30 day utilization window of
the IP address space.  If Policy Proposal 2007-9: Modernization of ISP
Immediate Need is not adopted, then Policy Proposal 2007-10: End Site
Immediate Need would require replicating the text from the existing ISP
Immediate Need policy into the end user section of NRPM.

III.	Issues and concerns

   A.	ARIN Staff

     Text should have 'allocation' changed to 'assignment' because this
refers to end-user assignments.

   B.	ARIN General Counsel

   The policy as proposed poses no significant legal risks for ARIN.  We
also believe that this policy is beneficial because it treats categories
of applicants equally.

IV.	Resource Impact - Minimum

The resource impact of implementing this policy is viewed as minimum.
Barring any unforeseen resource requirements, this policy could be
implemented within 90 days from the date of the ratification of the
policy by the ARIN Board of Trustees. Implementation would not require
the acquisition of staff personnel or equipment. It will require the
following:

- Revisions to registration guidelines
- Staff Training

Respectfully submitted,

Member Services
American Registry for Internet Numbers (ARIN)


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Annex A

Policy Proposal 2007-10
End Site Immediate Need Policy

Proposal type: new

Policy term: permanent

Policy statement:

Create new section in NRPM 4.3.6. to mirror the intent of 4.2.1.6, but
modified for end sites. If pending proposal "Modernization of ISP
Immediate Need Policy" is ratified, this new section will read:

     4.3.6 Immediate Need: If an end-user has an immediate need for
address space, and can provide justification to show that the address
space will be utilized within 30 days of the request, ARIN may issue a
block of address space, not larger than a /16 nor smaller than ARIN's
customary minimum allocation, to that organization. These cases are
exceptional.

In the absence of ratification of ""Modernization of ISP Immediate Need
Policy", this proposal is to add section 4.3.6 with a modification of
the current text of 4.2.1.6 to make it apply to end-users:

     4.3.6 Immediate Need: If an end-user has an immediate need for
address space, i.e., the need exists the day of the request, ARIN may
issue a /20 if the organization, such as a new company, shows
justification. However, these cases are exceptional.

Rationale:

ARIN staff has expressed the concern that the current policy is
self-contradictory, in one place stating that the Immediate Need Policy
applies to ISPs, and in another place stating that end users can qualify
under it. The communication received was:
     * The policy as written allows ARIN to issue a /20 to an ISP only.

However, section 4.3.4. "Additional Considerations" of the End User
Policy in the NRPM states that "End-users may qualify for address space
under other policies such as Immediate need [4.2.1.6] or
Micro-allocation [4.4].". In order to be consistent, the Immediate Need
policy language should be changed to reflect the fact that both ISPs and
end-users can qualify under this policy.

Timetable for implementation: Immediate