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

[Fernando Frediani]

Totally support this draft policy. It makes sense and is fair and logic 
to the IP assignment process.

Fernando

On 25/07/2019 13:26, ARIN wrote:
> 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.
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