[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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