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

Thu May 14 16:01:55 EDT 2020

This is great feedback. Thank you everyone. I agree with removing
"summarily" is an easy correction and is probably an unnecessary word.
Thanks all.

Kat

On Thu, May 14, 2020 at 3:59 PM Martin Hannigan <hannigan at gmail.com> wrote:

>
> Makes sense to me. +1
>
> On Thu, May 14, 2020 at 1:50 PM Mike Burns <mike at iptrading.com> wrote:
>
>> I would support it with the removal of the pompous and meaningless word
>> “summarily”.
>>
>> I like a clean NRPM.
>>
>>
>>
>> Regards,
>> Mike
>>
>>
>>
>>
>>
>> *From:* ARIN-PPML <arin-ppml-bounces at arin.net> *On Behalf Of *Chris
>> Woodfield
>> *Sent:* Thursday, May 14, 2020 1:40 PM
>> *To:* Owen DeLong <owen at delong.com>; ARIN-PPML List <arin-ppml at arin.net>
>> *Subject:* Re: [arin-ppml] Revised and Reverted to Draft Policy - Draft
>> Policy ARIN-2019-1: Clarify Section 4 IPv4 Request Requirements
>>
>>
>>
>> I support as written, but agree that the word can be removed from the
>> proposal without changing its intent, so happy to see it removed.
>>
>>
>>
>> -Chris
>>
>>
>>
>> On May 14, 2020, at 9:49 AM, Owen DeLong <owen at delong.com> wrote:
>>
>>
>>
>> I don’t construe it that way, but I have no objection to either of
>> Scott’s suggestions, either.
>>
>>
>>
>> My concern is for the end effect of the proposed policy which is the same
>> with any of the proposed wordings.
>>
>>
>>
>> Owen
>>
>>
>>
>>
>>
>> On May 14, 2020, at 09:10 , Scott Leibrand <scottleibrand at gmail.com>
>> wrote:
>>
>>
>>
>> "Summarily" seems punitive, and doesn't seem necessary in this context.
>> Perhaps just remove it and just leave "will be removed from the waitlist"?
>> Or replace it with something like "immediately".
>>
>>
>>
>> -Scott
>>
>>
>>
>> On Thu, May 14, 2020 at 8:50 AM Owen DeLong <owen at delong.com> wrote:
>>
>> I support this addition and support the policy with the addition.
>>
>>
>>
>> Owen
>>
>>
>>
>>
>>
>> On May 14, 2020, at 08:37, Fernando Frediani <fhfrediani at gmail.com>
>> wrote:
>>
>> 
>>
>> 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> 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> wrote:
>>
>>
>>
>> > On Mar 9, 2020, at 06:26 , ARIN <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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>>
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