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

[Kat Hunter]

That's a great suggestion. Does anyone else have a similar
opinion/suggestion on the same?

Kat

On Fri, Dec 13, 2019 at 12:20 PM Scott Leibrand <scottleibrand at gmail.com>
wrote:

> Does this open up the possibility that an organization performs its 8.2
> transfer to a wholly-owned subsidiary, and then sells that subsidiary to a
> third party, to bypass the limitation on applying for more IPv4 space?  Do
> we need to change "was a subsidiary" to "was, and remains, a subsidiary" or
> similar?
>
> -Scott
>
> On Fri, Dec 13, 2019 at 8:34 AM Kat Hunter <takokat81 at gmail.com> wrote:
>
>> 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.
>> -------
>> 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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>
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