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

[ARIN]

On 18 July 2019 the ARIN Advisory Council (AC) advanced the following 
Draft Policy to Recommended Draft Policy status:

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

The text of the Recommended Draft Policy is below, and may also be found at:

https://www.arin.net/participate/policy/drafts/2019_1/

You are encouraged to discuss all Recommended Draft Policies on PPML 
prior to their presentation at the next ARIN Public Policy Consultation 
(PPC). PPML and PPC discussions are invaluable to the AC when 
determining community consensus.

The PDP can be found at:

https://www.arin.net/participate/policy/pdp/

Draft Policies and Proposals under discussion can be found at:

https://www.arin.net/participate/policy/drafts/

Regards,

Sean Hopkins
Policy Analyst
American Registry for Internet Numbers



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

AC assessment of Conformance with the Principles of Internet Number 
Resource Policy:

"This Draft Policy is is fair, impartial, and technically sound. This 
draft policy is an attempt to clarify the waiting period to only 
prohibit requests for IPv4 allocations under Section 4 of the NRPM.

Additionally, it disallows organizations that have transferred space to 
other parties within the past 36 months from applying for additional 
IPv4 space under NRPM Section 4."

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:

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 36 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. 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.

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. During ARIN 43 it was 
proposed to the community that the two policy statements were severable, 
however, there was sufficient community support behind keeping both.

There have been updates to section 4 since the beginning of the work on 
this policy. Text has been updated to reflect current NRPM.