[arin-ppml] Recommended Draft Policy ARIN-2019-1: Clarify Section 4 IPv4 Request Requirements
ARIN
info at arin.net
Wed May 27 11:59:09 EDT 2020
On 21 May 2020 the ARIN Advisory Council (AC) advanced the following
Draft Policy to Recommended Draft Policy status:
ARIN-2019-1: Clarify Section 4 IPv4 Request Requirements
The text of the Recommended Draft Policy is below, and may also be found at:
https://www.arin.net/participate/policy/drafts/2019_1/
You are encouraged to discuss all Recommended Draft Policies on PPML
prior to their presentation at the next ARIN Public Policy Consultation
(PPC). PPML and PPC discussions are invaluable to the AC when
determining community consensus.
The Policy Development Process (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
Recommended Draft Policy ARIN-2019-1: Clarify Section 4 IPv4 Request
Requirements
AC Assessment of Conformance With the Principles of Internet Number
Resource Policy:
This Draft Policy is is fair, impartial, and technically sound. This
draft policy is an attempt to clarify the waiting period to only
prohibit requests for IPv4 allocations under Section 4 of the NRPM.
Additionally, it disallows organizations that have transferred space to
other parties within the past 36 months from applying for additional
IPv4 space under NRPM Section 4.
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:
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.
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 90 days.
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 90 days.
Add:
8.6 Wait List 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
removed from the wait list.
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.
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