[arin-ppml] ARIN Draft policy 2019-1 Clarify Section 4 IPv4 Request Requirements - Update Dec 2019

[Kat Hunter]

Happy Friday Everyone;
Draft Policy ARIN-2019-1 is below and can be found at:
https://www.arin.net/participate/policy/drafts/2019_1/

During the Austin meeting there was concern for some of the wording of
2019-1. It was suggested that the word "Repeated" was too vague and that
companies that performed M&A transfer that was a subsidiary, parent
company, or an organization under common ownership of the same parent
company as the applicant organization should not be removed or kept from
the waitlist because of a consolidation of resources. We've updated the
wording on 2019-1 and would appreciate discussion on the updates. Thanks so
much in advance.
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Problem Statement:

Per a recent ARIN Policy Experience Report and resulting AC discussion, it
was noted that the language of Section 4.1.8 is imprecise in that it can be
interpreted as specifying a waiting period for any allocation activity, as
opposed to being intended to limit only the frequency of IPv4 allocations
under Section 4.

The same Policy Experience Report also noted that ARIN staff has observed a
pattern where an organization transfers space under NRPM Section 8.2 to a
specified recipient, and then immediately applies for space under Section
4. This activity appears to be speculative in nature and not consistent
with sound address management policy.

The updated language in this proposal addresses the two issues above, as
both concerns can be addressed via modifications to the same section and
sentence thereof of the NRPM:

Clarifies the waiting period to only prohibit requests for IPv4 allocations
under Section 4 of the NRPM
Disallows organizations that have transferred space to other parties within
the past 36 months from applying for additional IPv4 space under NRPM
Section 4.
Policy Statement:

Current language found in NRPM Section 4.1.8 - Unmet Requests:

Repeated requests, in a manner that would circumvent 4.1.6, are not
allowed: an organization currently on the waitlist must wait 90 days after
receiving a distribution from the waitlist before applying for additional
space. ARIN, at its sole discretion, may waive this requirement if the
requester can document a change in circumstances since their last request
that could not have been reasonably foreseen at the time of the original
request, and which now justifies additional space. Qualified requesters
will also be advised of the availability of the transfer mechanism in
section 8.3 as an alternative mechanism to obtain IPv4 addresses.

Proposed new language:

Multiple requests are not allowed: an organization may not apply for IPv4
address resources under this section if they have received an allocation,
assignment, or transfer of IPv4 resources through a specified transfer
under sections 8.3 or 8.4 or waitlist allocation less than three months
prior, or if the organization has transferred IPv4 address resources to
another party under Section 8 less than 36 months prior to its application
under this section. However, an organization may apply for IPv4 address
resources under this section if they have transferred IPv4 address
resources under section 8.2 during the previous 36 months if the recipient
organization was a subsidiary, parent company, or an organization under
common ownership of the same parent company as the applicant organization.
ARIN may at its sole discretion, waive this restriction if the requester
can document a change in circumstances since their last request that could
not have been reasonably foreseen at the time of the original request, and
which now justifies additional space. Qualified requesters will also be
advised of the availability of the transfer mechanism in section 8.3 as an
alternative mechanism to obtain IPv4 addresses.

-Kat Hunter
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