[arin-ppml] Policy Proposal 124: Clarification of Section 4.2.4.4

John Curran jcurran at arin.net
Tue Dec 7 19:28:07 EST 2010


On Dec 7, 2010, at 12:21 PM, David Farmer wrote:
> 
> So I guess I have a question for John Curran;  Would it be in order and sufficient for the AC to recommend to the Board that policy 2009-8 now section 4.2.4.4 of the NRPM have the triggering clause be implemented for new requests that are received after the triggering event, and that requests received before the trigger be grandfathered?

If the AC believes that the policy should be implemented differently, 
it simply needs to inform the President and that will be reviewed. 
ARIN is not infallible, and the AC is an important check to make sure 
we're correctly implementing policy.  I will review it with the senior 
staff and make sure that we're handling the policy implementation in 
a consistent manner.  Depending on the results of the review, we would
either revise or sustain the current implementation processes.

The more certain path to having a policy implemented via a specific
process, and that would be the adoption of specific language to that 
effect in the policy.  This avoids any chance of staff misinterpretation, 
but does needs the full policy process since there may have been others 
in the community who only supported the policy based on their thoughts 
on on its likely implementation and need to have an opportunity to speak 
for/against the new language and resulting implementation change.

I will note that in the case of this particular language, any ISP who 
only receives a 3 month allocation can come back (after 3 months with
2010-1 implemented) and qualify for additional space if they still 
need additional resources and such are available.  Given that the 
purpose of 2009-8 was to provide for equitable distribution post IANA 
depletion, suppressing the 3 month limit for allocations actually made 
after IANA runout simply because they are already the queue is likely 
to only encourage submissions today of not-quite-complete "placeholder" 
additional space requests to the queue, and similar attempts at gaming 
of the system.  This should not dissuade the ARIN AC for considering 
a policy change if they feel the current policy is flawed; it is only 
provided as insight into a implementation concern that arises from 
changing the process for existing requests in the queue at runout.

/John

John Curran
President and CEO
ARIN






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