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

[Scott Leibrand]

On 1/26/2010 8:48 PM, Steve Bertrand wrote:
> 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 ;)
>    

Thanks: good feedback.

>
> 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.
>    

I like this, and may steal some of your language.  :-)

> 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.
>    

I'm not convinced that we want to inject PPML into the process in-line.  
Given that the current policy process cycle is about 6 months, I'm not 
sure if we could do an [expedited pace] that would actually be faster 
than waiting the 3 months...

However, I definitely want to see transparency in how this policy is 
being used.  We do have an existing mechanism for ARIN staff to report 
back to the community on how policies are working out: at every ARIN 
meeting staff (Leslie) gives a Policy Experience Report, detailing how 
one or more aspects of policy are actually working in practice, and 
suggesting changes where necessary.  And, of course, she takes questions 
as well.  So I'm thinking maybe we'd want to have staff report on the 
number of waivers requested and granted, and any interesting details of 
the circumstances surrounding the requests...

Thoughts?
Scott