I generally support the goal of this proposal, but I wonder if a
one-time exception should be carved out for and organization which is
switching to IPv6, no longer needs a large IPv4 allocation or
assignment, and wishes to replace it with a new, much smaller
distribution? Would they be able to apply for and receive a new IPv4
/24 from the wait list, transfer market or the special IPv6 pool, and
then sell their existing space under 8.2? Or would they run afoul of
the timing requirements of the proposed wording? If they were permitted
to do this, then I support. (They could obviously carve out a /24 from
their existing space and sell the rest, but that would greatly increase
fragmentation.)
On 7/29/2019 11:18 AM, Fernando Frediani wrote:
Totally support this draft policy. It makes sense and is fair and
logic to the IP assignment process.
Fernando
On 25/07/2019 13:26, ARIN wrote:
On 18 July 2019 the ARIN Advisory Council (AC) advanced the following
Draft Policy to Recommended Draft Policy status:
Recommended Draft Policy 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 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:
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. 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.
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.
_______________________________________________
ARIN-PPML
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_______________________________________________
ARIN-PPML
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--
John Santos
Evans Griffiths & Hart, Inc.
781-861-0670 ext 539
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ARIN-PPML
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