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

[John Santos]

I generally support the goal of this proposal, but I wonder if a 
one-time exception should be carved out for and organization which is 
switching to IPv6, no longer needs a large IPv4 allocation or 
assignment, and wishes to replace it with a new, much smaller 
distribution?  Would they be able to apply for and receive a new IPv4 
/24 from the wait list, transfer market or the special IPv6 pool, and 
then sell their existing space under 8.2?  Or would they run afoul of 
the timing requirements of the proposed wording?  If they were permitted 
to do this, then I support.  (They could obviously carve out a /24 from 
their existing space and sell the rest, but that would greatly increase 
fragmentation.)

On 7/29/2019 11:18 AM, Fernando Frediani wrote:
> 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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-- 
John Santos
Evans Griffiths & Hart, Inc.
781-861-0670 ext 539