Recommended Draft Policy ARIN-2019-1

Clarify Section 4 IPv4 Request Requirements

Status: Recommended for Adoption
Shepherds: Kat Hunter, Amy Potter

Current Text (11 January 2020)

AC Assessment of Conformance with the Principles of Internet Number Resource Policy:

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:

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 and remains 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.

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 orginal proposed language would excude those companies from being able to apply to the waitlist.

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.

Proposal/Draft Policy Text Assessed: 16 April 2019 Version

History and Earlier Versions

History
Action Date
Proposal 30 January 2019
Draft Policy 26 February 2019
Revised 16 April 2019
Recommended Draft Policy 23 July 2019
Revised 25 July 2019
Revised 13 December 2019
Revised 11 January 2020