I also support the updated language in this proposal and the issues it 
addresses.

Mike Arbrouet


------ Original message------
From: Rudolph Daniel
Date: Thu, Apr 18, 2019 6:23 AM
To: [email protected];
Cc:
Subject:Re: [arin-ppml] ARIN-PPML Draft 2019-1


I support this draft proposal..
RD

On Wed, Apr 17, 2019 at 12:00 PM 
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Today's Topics:

   1. Revised - Draft Policy ARIN-2019-1: Clarify Section 4 IPv4
      Request Requirements (ARIN)


----------------------------------------------------------------------

Message: 1
Date: Tue, 16 Apr 2019 14:26:07 -0400
From: ARIN <[email protected]<mailto:[email protected]>>
To: [email protected]<mailto:[email protected]>
Subject: [arin-ppml] Revised - Draft Policy ARIN-2019-1: Clarify
        Section 4 IPv4 Request Requirements
Message-ID: 
<[email protected]<mailto:[email protected]>>
Content-Type: text/plain; charset=utf-8; format=flowed

The following has been revised:

* Draft Policy ARIN-2019-1: Clarify Section 4 IPv4 Request Requirements

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 may only receive one allocation, assignment, or
transfer every 3 months, but 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.

Proposed new language:

Repeated requests, in a manner that would circumvent 4.1.6 are not
allowed: an organization may not apply for IPv4 address resources under
this section if they have received an allocation, assignment, or
transfer of IPv4 resources less than three months prior, or if the
organization has transferred space to another party under Section 8 less
than 36 months prior. ARIN, at its sole discretion, may waive this
restriction 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.

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
severalble, however, there was sufficient community support behind
keeping both.


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