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

[Chris Woodfield]

Speaking as the policy author, I’ll make two points:

1. I’m aware that given the other discussions around waiting list policy that are ongoing, this proposal may well be rendered moot by future policy changes. I still believe that this is worth pursuing as there’s a current need for clarification and increased disincentives for bad behavior today.
2. I’m deliberately killing two not-terribly-related birds with one stone with this proposal, based on the fact that the two issues noted from the PER can be addressed by adding language to the same NRPM text. Happy to consider severing them if the community prefers.

Thanks,

-Chris

> On Mar 2, 2019, at 9:33 AM, hostmaster at uneedus.com wrote:
> 
> I think it is time to start the ball on the other policies.
> 
> +1 on this.  It seems focused on those gathering resources to resell.
> 
> Albert Erdmann
> Network Administrator
> Paradise On Line Inc.
> 
> On Tue, 26 Feb 2019, ARIN wrote:
> 
>> 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.
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