[arin-ppml] Draft Policy ARIN-2019-1: Clarify Section 4 IPv4 Request Requirements

[ARIN]

On 21 February 2019, the ARIN Advisory Council (AC) accepted 
"ARIN-prop-260: Clarify Section 4 IPv4 Request Requirements" as a Draft 
Policy.

Draft Policy ARIN-2019-1 is below and can be found at:
https://www.arin.net/policy/proposals/2019_1.html

You are encouraged to discuss all Draft Policies on PPML. The AC will 
evaluate the discussion in order to assess the conformance of this draft 
policy with ARIN's Principles of Internet number resource policy as 
stated in the Policy Development Process (PDP). Specifically, these 
principles are:

* Enabling Fair and Impartial Number Resource Administration
* Technically Sound
* Supported by the Community

The PDP can be found at:
https://www.arin.net/policy/pdp.html

Draft Policies and Proposals under discussion can be found at:
https://www.arin.net/policy/proposals/index.html

Regards,

Sean Hopkins
Policy Analyst
American Registry for Internet Numbers (ARIN)



Draft Policy ARIN-2019-1: Clarify Section 4 IPv4 Request Requirements

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 12 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 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 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.

Proposed new language:

Repeated requests, in a manner that would circumvent 4.1.6 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 less than three months prior, or if the 
organization has transferred space to another party under Section 8 less 
than 12 months prior. ARIN, at its sole discretion, may 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.

Comments:

This proposal incorporates two related policy goals, combined for 
convenience in one proposal as both can addressed via modification of 
the same section and sentence of the NRPM. These policy goals are 
severable if the community prefers to address them independently.