Recommended Draft Policy ARIN-2019-1

Clarify Section 4 IPv4 Request Requirements

Status: Recommended for Adoption

Staff and Legal Review: 16 May 2019

Advisory Council Shepherds: Amy Potter, Kat Hunter

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History:

Revisions:

ARIN Advisory Council Meetings:

Presented at:

Latest Version: 25 July 2019

AC Statement of Conformance:

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.

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Earlier Version

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Version Date: 16 April 2019

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 may only receive one allocation, assignment, or transfer every 3 months, but 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.

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.

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 severalble, however, there was sufficient community support behind keeping both.

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ARIN STAFF & LEGAL ASSESSMENT

Summary (Staff Understanding)

Draft Policy 2019-1: Clarify Section 4 IPv4 Request Requirements It is staff understanding that this policy changes section 4.1.8 and effectively outlines a clear intent that an organization may only apply for IPv4 addresses if they have not received IPv4 addresses within three months prior to submitting an application. The new text also introduces a clear statement to staff that any organization applying for IPv4 addresses cannot have transferred IPv4 addresses to another party under Section 8 within 36-months prior to the application.

Comments

ARIN Staff Comments

The new text is clear and easily understood.

This policy will have the following impact: Staff training Updated guidelines and internal procedures Updated documentation on website This policy can be implemented as written

ARIN General Counsel – Legal Assessment

ARIN Counsel sees no material legal issue in the draft policy, and believes the policy will assist ARIN achieve anti-fraud objectives.


Resource Impact

Proposal/Draft Policy Text Assessed

Latest Version: 16 April 2019

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 may only receive one allocation, assignment, or transfer every 3 months, but 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.

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.

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 severalble, however, there was sufficient community support behind keeping both.

##########

Earlier version

##########

Version Date: 26 February 2019

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 12 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 may only receive one allocation, assignment, or transfer every 3 months, but 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.

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 12 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.

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. These policy goals are severable if the community prefers to address them independently.