[arin-ppml] Draft Policy 2010-1: Waiting List for Unmet IPv4 Requests

[Scott Leibrand]

On 1/21/2010 11:45 AM, Member Services wrote:
>
> A. ARIN Staff Comments
>
> • In section 4.1.8, the author says “Repeated requests, in a manner that
> would circumvent 4.1.6, are not allowed: an organization may only
> receive one allocation, assignment, or transfer every 3 months, but
> ARIN, at its sole discretion, may waive this requirement if the
> requester can document an unforeseen change in circumstances since their
> last request”.
>
> As written, the portion of the policy that starts with “but ARIN, at its
> sole discretion” gives no concrete criteria for staff to use in its
> assessment of the request. This “exception clause” is open to
> interpretation and may not be applied consistently by staff if there are
> no guidelines or rules for staff to follow. It essentially allows ARIN
> staff to determine the policy criteria for who can or can’t qualify
> under this waiver.

To address this issue, I have added one more Q&A to the FAQ in the 
Rationale of this proposal:

Q5: What would constitute "an unforeseen change in circumstances since 
their last request" that would allow ARIN to waive the 3-month delay to 
receive a second block?

A5: This would, of course, be a matter of discretion for ARIN, but the 
idea here is that the burden of proof is on the requester to document 
some change in circumstances, that could not have been reasonably 
foreseen at the time of the original request, that now justifies 
additional space.  This is intended to be a rarely used safety valve.

Does anyone have any suggestions for a better way to address this?  IMO 
we've already made the proposal text as specific as we can without 
dramatically increasing the complexity to address corner cases, etc.  Of 
course, that may be simply a lack of imagination on my part, so ideas 
for alternate proposal text are welcome.

Thanks,
Scott