Does this open up the possibility that an organization performs its 8.2 transfer to a wholly-owned subsidiary, and then sells that subsidiary to a third party, to bypass the limitation on applying for more IPv4 space? Do we need to change "was a subsidiary" to "was, and remains, a subsidiary" or similar?
-Scott On Fri, Dec 13, 2019 at 8:34 AM Kat Hunter <[email protected]> wrote: > Happy Friday Everyone; > Draft Policy ARIN-2019-1 is below and can be found at: > https://www.arin.net/participate/policy/drafts/2019_1/ > > During the Austin meeting there was concern for some of the wording of > 2019-1. It was suggested that the word "Repeated" was too vague and that > companies that performed M&A transfer that was a subsidiary, parent > company, or an organization under common ownership of the same parent > company as the applicant organization should not be removed or kept from > the waitlist because of a consolidation of resources. We've updated the > wording on 2019-1 and would appreciate discussion on the updates. Thanks so > much in advance. > ------- > 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: > > Multiple requests 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 through a specified transfer > under sections 8.3 or 8.4 or waitlist allocation less than three months > prior, or if the organization has transferred IPv4 address resources to > another party under Section 8 less than 36 months prior to its application > under this section. However, an organization may apply for IPv4 address > resources under this section if they have transferred IPv4 address > resources under section 8.2 during the previous 36 months if the recipient > organization was a subsidiary, parent company, or an organization under > common ownership of the same parent company as the applicant organization. > ARIN may at its sole discretion, 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. > > -Kat Hunter > > _______________________________________________ > ARIN-PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List ([email protected]). > Unsubscribe or manage your mailing list subscription at: > https://lists.arin.net/mailman/listinfo/arin-ppml > Please contact [email protected] if you experience any issues. >
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