I support this proposal as written. — Brian On Thu, May 14, 2020 at 10:56 AM Kat Hunter <takoka...@gmail.com> 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 <takoka...@gmail.com> 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 <o...@delong.com> wrote: >> >>> >>> >>> > On Mar 9, 2020, at 06:26 , ARIN <i...@arin.net> 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 (ARIN-PPML@arin.net). >>> Unsubscribe or manage your mailing list subscription at: >>> https://lists.arin.net/mailman/listinfo/arin-ppml >>> Please contact i...@arin.net if you experience any issues. >>> >> _______________________________________________ > ARIN-PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). > Unsubscribe or manage your mailing list subscription at: > https://lists.arin.net/mailman/listinfo/arin-ppml > Please contact i...@arin.net if you experience any issues. >
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