I support this addition and support the policy with the addition. Owen
> On May 14, 2020, at 08:37, Fernando Frediani <[email protected]> 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 <[email protected]> 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 <[email protected]> wrote: >>>> >>>> >>>> > On Mar 9, 2020, at 06:26 , ARIN <[email protected]> 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 >>>> 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. >> >> >> _______________________________________________ >> 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. > _______________________________________________ > 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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