[arin-ppml] Revised - Advisory Council Recommendation Regarding NRPM 4.1.8. Unmet Requests

[Tomas Lynch]

On 5/24/2019 1:04 PM, ARIN wrote:
> At their 16 May meeting, the Advisory Council revised their 
> recommendation regarding NRPM 4.1.8. Unmet Requests.
> 
> The revised recommendation is hereby submitted to the Public Policy 
> Mailing List for a second community discussion period of 14 days, to 
> conclude on 7 June.
> 
> Once completed, the Board of Trustees will review the AC’s 
> recommendation and the PPML discussion.
> 
> The full text of the Advisory Council's revised recommendation is below.
> 
> Sean Hopkins
> Policy Analyst
> American Registry for Internet Numbers (ARIN)
> 
> 
> 
> Advisory Council recommendation:
> 
> This is an updated version which incorporates feedback from the ARIN 
> staff and was approved for further community consultation at the ARIN AC 
> meeting on May 16, 2019.
> 
> In accordance with section 10.2 of the ARIN Policy Development Process, 
> the ARIN Advisory Council recommends the following actions to the Board 
> of Trustees in response to the Board’s suspension of part of the 
> operation of sections 4.1.8, 4.1.8.1 and 4.1.8.2 of the Numbering 
> Resource Policy Manual:
> 
> Replace section 4.1.8 et. seq. as follows, then reinstate the full 
> operation of sections 4.1.8, 4.1.8.1 and 4.1.8.2 immediately.
> 
> 4.1.8 ARIN Waitlist
> 
> ARIN will only issue future IPv4 assignments/allocations (excluding 4.4 
> and 4.10 space) from the ARIN Waitlist. The maximum size aggregate that 
> an organization may qualify for at any one time is a /22. Organizations 
> will be able to elect a smaller block size than they qualify for down to 
> a /24. Only organizations holding a /20 or less of IPv4 address space 
> may apply and be approved. Address space distributed from the waitlist 
> will not be eligible for transfer for a period of 60 months. This policy 
> will be applied to all future distributions from the waitlist to include 
> those currently listed.
>

I do not agree with this part. We have been on the waiting list for one 
year requesting a /20 or, if impossible, a /21. We have setup our 
business plans for this prefix length while using our current /21 very 
carefully. We are currently using this prefix at 90% while deploying 
IPv6 to our customers. I do not think is fair for us, good standing ARIN 
members, to pay the price of a malicious enterprise.

> 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 whose request will also be advised of the 
> availability of the transfer mechanism in section 8.3 as an alternative 
> mechanism to obtain IPv4 addresses.
> 
> 4.1.8.1 Sequencing
> 
> The position of each qualified request on the waiting list will be 
> determined by the date it was approved. Each organization may have one 
> approved request on the waiting list at a time.
> 
> 4.1.8.2 Fulfillment
> 
> ARIN will fulfill requests on a first-approved basis, subject to the 
> size of each available address block as address blocks become available 
> for distribution. A timely review of the original request may be 
> conducted by ARIN staff. Requests will not be partially filled. Any 
> requests met through a transfer will be considered fulfilled and removed 
> from the waiting list.
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