[arin-ppml] Revised and Reverted to Draft Policy - Draft Policy ARIN-2019-1: Clarify Section 4 IPv4 Request Requirements
Fernando Frediani
fhfrediani at gmail.com
Thu May 14 11:37:21 EDT 2020
I support this proposal.
It's fair to everybody and helps avoid fraud.
Regards
Fernando
On 14/05/2020 11:56, Kat Hunter wrote:
> After making adjustments to the text, ARIN staff and legal conducted a
> new staff and legal review on 2019-1. You can view the updated review
> here:
> https://www.arin.net/participate/policy/drafts/2019_1/#staff-and-legal-review-30-april-2020 .
> It has been suggested that
> "It is worth noting that this Draft Policy does not include the
> removal of pending ARIN Waitlist requests for organizations that act
> as source organizations for 8.2, 8.3, or 8.4 transfers, which would
> allow them to conduct such transfers while waitlisted, and receive
> resources from the ARIN Waitlist immediately thereafter, as all
> organizations on the ARIN Waitlist have already applied, and are
> pending fulfillment.
>
> The text is clear and understandable, and can be implemented as written."
>
> After some discussion with some members of the AC, it was suggested
> that a new subsection is added to section 8 which would allow for
> additional clarity from this policy and some future cleanup via other
> future policy.
>
> "8.6 Waitlist Restrictions
>
> Any organization which is on the wait list and submits a request to be
> the source of a transfer under any provision in section 8 will be
> summarily removed from the wait list."
>
> I'd like to get the community's thoughts on the addition. With this
> addition, would you support the policy as written?
>
> -Kat Hunter
>
>
> On Tue, Mar 24, 2020 at 1:24 PM Kat Hunter <takokat81 at gmail.com
> <mailto:takokat81 at gmail.com>> wrote:
>
> Owen, I think this is a good suggestion. I've updated the month
> designations in the other section to 90 days as, I agree, it is
> more precise when we are discussing shorter amounts of time.
> Additionally, I've taken your suggestion on wordsmithing that
> section and adjusted it just a little.
>
> " An organization which serves as the source of an 8.2 IPv4
> transfer will not be allowed to apply for IPv4 address space under
> section 4.1.8 ARIN Waitlist for a period of 36 months following
> said transfer unless the recipient organization remains a
> subsidiary, parent company, or under common ownership with the
> source organization.".
>
> I wanted to make sure I specified that this was in reference to
> IPv4 and that the organization also remains a subsidiary, parent
> company, or under common ownership. Thank you for the input.
> Additionally I'd like to see if there is anyone else that still
> supports or no longer longer supports this policy as written.
>
> Kat Hunter
>
> On Wed, Mar 11, 2020 at 4:42 AM Owen DeLong <owen at delong.com
> <mailto:owen at delong.com>> wrote:
>
>
>
> > On Mar 9, 2020, at 06:26 , ARIN <info at arin.net
> <mailto:info at arin.net>> wrote:
> >
> > On 20 February 2020, the ARIN Advisory Council (AC) reverted
> the following Recommended Draft Policy to Draft Policy Status
> due to community feedback recommending significant substantive
> changes.:
> >
> > * Draft Policy ARIN-2019-1: Clarify Section 4 IPv4 Request
> Requirements
> >
> > The text has since been revised in response to that feedback.
> >
> > Revised text is below and can be found at:
> >
> > https://www.arin.net/participate/policy/drafts/2019_1/
> >
> > 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/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 (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 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 4.1.8:
> >
> > Multiple requests are not allowed: an organization currently
> on the waitlist must wait 90 days after receiving a
> distribution from the waitlist or IPv4 number resources as a
> recipient of any transfer 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.
> >
> > Restrictions apply for entities who have conducted recent
> resource transfers. These restrictions are specified in
> Section 8 for each relevant transfer category.
> >
> > Add the following under 8.2. Mergers, Acquisitions, and
> Reorganizations:
> >
> > After completion of an 8.2 transfer an organization may only
> apply for IPv4 address resources under Section 4.1.8. ARIN
> Waitlist if they have transferred IPv4 address resources under
> section 8.2 and the recipient organization is and remains a
> subsidiary, parent company, or an organization under common
> ownership of the same parent company as the organization that
> the IPv4 resources were transferred from. This restriction
> will last for 36 months and is applied to the organization
> that the IPv4 resources were transferred from and not the
> recipient.
>
> This paragraph cries out desperately for wordsmithing. It is
> very difficult to parse.
>
> Perhaps:
>
> An organization which serves as the source of an 8.2 transfer
> will not be allowed to apply for IPv4 address space under
> section 4.1.8 ARIN Waitlist for a period of 36 months
> following said transfer unless the recipient organization
> remains under common ownership with the source organization.
>
> > Add the following under 8.3. Transfers Between Specified
> Recipients Within the ARIN Region and under the Conditions on
> the source of the transfer:
> >
> > The source entity will not be allowed to apply for IPv4
> address space under Section 4.1.8. ARIN Waitlist for a period
> of 36 months following the transfer of IPv4 address resources
> to another party.
> >
> > Under conditions on the recipient:
> >
> > If applicable the recipient will be removed from the ARIN
> Waitlist and will not be allowed to reapply under section
> 4.1.8. ARIN Waitlist for a period of 3 months.
>
> This should read “90 days” instead of “3 months” to retain
> consistency with 4.1.8.
>
> > Add the following under 8.4. Transfers Between Specified
> Recipients Within the ARIN Region and under the Conditions on
> the source of the transfer:
> >
> > The source entity will not be allowed to apply for IPv4
> address space under Section 4.1.8. ARIN Waitlist for a period
> of 36 months following the transfer of IPv4 address resources
> to another party.
> >
> > Under conditions on the recipient:
> >
> > If applicable the recipient will be removed from the ARIN
> Waitlist and will not be allowed to reapply under section
> 4.1.8. ARIN Waitlist for a period of 3 months.
>
> This should read “90 days” instead of “3 months” to retain
> consistency with 4.1.8.
>
> >
> > 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.
> >
> > There was significant community support to change the word
> “repeated” as it was vague. Additionally, there was concerned
> that a company may perform an M&A transfer to itself/parent
> company and the original proposed language would exclude those
> companies from being able to apply to the waitlist. After the
> addition of the new merger and acquisition language, staff and
> legal recommended that the restrictions for applying to the
> waitlist for participants of the transfer market be added to
> the appropriate section in the Section 8 of the NRPM.
> Organizations should be informed of how their activities in
> the transfer market will impact them in reference to applying
> to the waitlist. These changes were to make it easier for
> staff and the community to understand these requirements.
>
> While I understand the desire to do this, I must point out
> that having the same rule specified in multiple places in the
> NRPM tends to lead to inconsistencies down the road.
>
> It is not at all unusual in this situation for a future policy
> proposal to miss one of these duplicate statements of the same
> rule and update only a subset of them. Even the above
> inconsistency in this proposal between 90 days in section 4
> and 3 months for the same thing twice in section 8 serves as
> an example of the perils of duplicating the same rule in
> multiple locations.
>
> I suggest, therefore, that instead of duplicating the rules,
> we reference section 4.1.8 in each of those cases as follows:
>
> Recipients should be aware of the impact of transfers
> on their ability to apply and/or obtain space from the
> waitlist. These are spelled out in section 4.1.8.
>
> This provides clarity that there is an impact to be considered
> and clear guidance as to where to find that impact without
> abetting inconsistency.
>
> Owen
>
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