[arin-ppml] ARIN Draft policy 2019-1 Clarify Section 4 IPv4 Request Requirements - Update Dec 2019

[Kat Hunter]

I've updated the language for 2019-1 to reflect this suggestion. Please see
the updated language here:

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

Updated text:
Multiple requests 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 through a specified transfer
under sections 8.3 or 8.4 or waitlist allocation less than three months
prior, or if the organization has transferred IPv4 address resources to
another party under Section 8 less than 36 months prior to its application
under this section. However, an organization may apply for IPv4 address
resources under this section if they have transferred IPv4 address
resources under section 8.2 during the previous 36 months if the recipient
organization was and remains a subsidiary, parent company, or an
organization under common ownership of the same parent company as the
applicant organization. ARIN may at its sole discretion, 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.

-Kat Hunter

On Fri, Dec 13, 2019 at 1:30 PM Kat Hunter <takokat81 at gmail.com> wrote:

> That's a great suggestion. Does anyone else have a similar
> opinion/suggestion on the same?
>
> Kat
>
> On Fri, Dec 13, 2019 at 12:20 PM Scott Leibrand <scottleibrand at gmail.com>
> wrote:
>
>> Does this open up the possibility that an organization performs its 8.2
>> transfer to a wholly-owned subsidiary, and then sells that subsidiary to a
>> third party, to bypass the limitation on applying for more IPv4 space?  Do
>> we need to change "was a subsidiary" to "was, and remains, a subsidiary" or
>> similar?
>>
>> -Scott
>>
>> On Fri, Dec 13, 2019 at 8:34 AM Kat Hunter <takokat81 at gmail.com> wrote:
>>
>>> Happy Friday Everyone;
>>> Draft Policy ARIN-2019-1 is below and can be found at:
>>> https://www.arin.net/participate/policy/drafts/2019_1/
>>>
>>> During the Austin meeting there was concern for some of the wording of
>>> 2019-1. It was suggested that the word "Repeated" was too vague and that
>>> companies that performed M&A transfer that was a subsidiary, parent
>>> company, or an organization under common ownership of the same parent
>>> company as the applicant organization should not be removed or kept from
>>> the waitlist because of a consolidation of resources. We've updated the
>>> wording on 2019-1 and would appreciate discussion on the updates. Thanks so
>>> much in advance.
>>> -------
>>> 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:
>>>
>>> Multiple requests 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 through a specified
>>> transfer under sections 8.3 or 8.4 or waitlist allocation less than three
>>> months prior, or if the organization has transferred IPv4 address resources
>>> to another party under Section 8 less than 36 months prior to its
>>> application under this section. However, an organization may apply for IPv4
>>> address resources under this section if they have transferred IPv4 address
>>> resources under section 8.2 during the previous 36 months if the recipient
>>> organization was a subsidiary, parent company, or an organization under
>>> common ownership of the same parent company as the applicant organization.
>>> ARIN may at its sole discretion, 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.
>>>
>>> -Kat Hunter
>>>
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>>
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