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

Rudolph Daniel rudi.daniel at gmail.com
Thu May 14 16:23:14 EDT 2020


I support the Policy Proposal and addition.

Rudi Daniel
*danielcharles consulting
<http://www.facebook.com/pages/Kingstown-Saint-Vincent-and-the-Grenadines/DanielCharles/153611257984774>*
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On Thu, May 14, 2020 at 11:50 AM <arin-ppml-request at arin.net> wrote:

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>    1. Re: Revised and Reverted to Draft Policy - Draft Policy
>       ARIN-2019-1: Clarify Section 4 IPv4 Request Requirements (Owen
> DeLong)
>
>
> ----------------------------------------------------------------------
>
> Message: 1
> Date: Thu, 14 May 2020 08:49:54 -0700
> From: Owen DeLong <owen at delong.com>
> To: Fernando Frediani <fhfrediani at gmail.com>
> Cc: 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
> Message-ID: <3BEB9C66-D91D-4B87-97B0-DD51A08A9192 at delong.com>
> Content-Type: text/plain; charset="utf-8"
>
> 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
> >>>>
> >>>> _______________________________________________
> >>>> ARIN-PPML
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> >>
> >>
> >> _______________________________________________
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