That's a great suggestion. Does anyone else have a similar opinion/suggestion on the same?
Kat On Fri, Dec 13, 2019 at 12:20 PM Scott Leibrand <[email protected]> wrote: > 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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