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

[Steve Bertrand]

Scott Leibrand wrote:
> 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.

Given that this deals with runout, I'll take my first crack... all
criticism very welcome (I'm bracing for it ;)


A5: The use of this 'emergency safety valve' would have the burden of
proof put upon the requester, as to force them to adequately document a
significant change in circumstance. The requesters documentation would
include information on their proper initial due diligence, and reasoning
for not have been able to foresee such a situation at the time of the
original request.

Any and all requests that fall under this 'clause' category shall be
presented to the ARIN PPML mailing list without any identifying
information, other than the number of IP blocks that the requester has
requested within the last 12 months, the number and size of IP blocks
the requester has received within the last 18? months, and the [due
diligence] documentation presented with the 'emergency' request.

The blocks will be provided for distribution to the requester upon
community consensus, following the same procedures of the PDP, but at
[expedited pace] timeframe.

Steve