Draft Policy ARIN-2019-1

Clarify Section 4 IPv4 Request Requirements

Status: Under Discussion
Shepherds: Kat Hunter, Amy Potter

Current Text (25 March 2020)

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:

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.

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 90 days.

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 90 days.

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.

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
Reverted to Draft Policy 25 February 2020
Revised 9 March 2020
Revised 25 March 2020