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Advisory Council Recommendation Regarding NRPM 4.1.8. Unmet Requests

Status: Implemented

Staff and Legal Review: 1 May 2019

History:

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Latest Version: 24 May 2019

This is an updated version which incorporates feedback from the ARIN staff and was approved for further community consultation at the ARIN AC meeting on May 16, 2019.

In accordance with section 10.2 of the ARIN Policy Development Process, the ARIN Advisory Council recommends the following actions to the Board of Trustees in response to the Board’s suspension of part of the operation of sections 4.1.8, 4.1.8.1 and 4.1.8.2 of the Numbering Resource Policy Manual:

Replace section 4.1.8 et. seq. as follows, then reinstate the full operation of sections 4.1.8, 4.1.8.1 and 4.1.8.2 immediately.

4.1.8 ARIN Waitlist

ARIN will only issue future IPv4 assignments/allocations (excluding 4.4 and 4.10 space) from the ARIN Waitlist. The maximum size aggregate that an organization may qualify for at any one time is a /22. Organizations will be able to elect a smaller block size than they qualify for down to a /24. Only organizations holding a /20 or less of IPv4 address space may apply and be approved. Address space distributed from the waitlist will not be eligible for transfer for a period of 60 months. This policy will be applied to all future distributions from the waitlist to include those currently listed.

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 whose request will also be advised of the availability of the transfer mechanism in section 8.3 as an alternative mechanism to obtain IPv4 addresses.

4.1.8.1 Sequencing

The position of each qualified request on the waiting list will be determined by the date it was approved. Each organization may have one approved request on the waiting list at a time.

4.1.8.2 Fulfillment

ARIN will fulfill requests on a first-approved basis, subject to the size of each available address block as address blocks become available for distribution. A timely review of the original request may be conducted by ARIN staff. Requests will not be partially filled. Any requests met through a transfer will be considered fulfilled and removed from the waiting list.

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ARIN STAFF & LEGAL ASSESSMENT

STAFF COMMENTS:

4.1.8 ARIN Waitlist

ARIN will only issue future IPv4 assignments/allocations (excluding 4.4 and 4.10 space) from the ARIN Waitlist. The maximum size aggregate that an organization may qualify for at any one time is a /22. Organizations will be able to elect a smaller block size than they qualify for down to a /24. Only organizations holding a /20 or less of IPv4 address space may apply and be approved. Address space distributed from the waitlist will not be eligible for transfer for a period of 60 months. This policy will be applied to all future distributions from the waitlist to include those currently listed.

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 whose request will also be advised of the availability of the transfer mechanism in section 8.3 as an alternative mechanism to obtain IPv4 addresses.

4.1.8.1 Priority

The position of each qualified request on the waiting list will be determined by the date it was approved. Each organization may have one approved request on the waiting list at a time.

4.1.8.2

ARIN will fulfill requests on a first-approved basis, subject to the size of each available address block as address blocks become available for distribution. A timely review of the original request may be conducted by ARIN staff. Requests will not be partially filled. Any requests met through a transfer will be considered fulfilled and removed from the waiting list.

LEGAL COMMENTS:

The proposal requires legal analysis. Counsel strongly supports the revised policy’s central feature of a limit on the size of the block that can be issued from the waiting list. The new AC proposal will help reduce fraudulent applications, such as those that were being made under the pre–suspension policy, which allowed for allocation of larger number resource blocks. However, the proposal as drafted has language that is potentially confusing (as does policy proposal 2019-2). The excess language could create the mistaken impression that larger blocks must still be issued. Policy language that simply states that no applicant can obtain a direct distribution from ARIN larger than a set prefix size chosen by the AC [/22] is strongly preferred.

It is also clear the AC draft intends to have a the effect of reducing the size of the block to those who were on the list before suspension occurred. The clearest possible language should be used to provide notice that ARIN may interpret the proposed policy will limit the previously approved requests for size. It would be best to have the AC clearly articulate its intention in this regard.

TEXT ASSESSED:

In accordance with section 10.2 of the ARIN Policy Development Process, the ARIN Advisory Council recommends the following actions to the Board of Trustees in response to the Board’s suspension of part of the operation of sections 4.1.8, 4.1.8.1 and 4.1.8.2 of the Numbering Resource Policy Manual:

Replace section 4.1.8 as follows, then reinstate the full operation of sections 4.1.8, 4.1.8.1 and 4.1.8.2 immediately.

4.1.8. Unmet Requests

In the event that ARIN does not have a contiguous block of addresses of sufficient size to fulfill a qualified request, ARIN will provide the requesting organization with the option to specify the smallest block size they’d be willing to accept, equal to or larger than the applicable minimum size specified elsewhere in ARIN policy. If such a smaller block is available, ARIN will fulfill the request with the largest single block available that fulfills the request.

If no such block is available, the organization will be provided the option to be placed on a waiting list of pre-qualified recipients, listing both the block size, for which the organization is qualified, which in the case of the waiting list shall not be larger than a /22, and the smallest block size acceptable to the organization. An organization may not be added to the waiting list if it already holds IPv4 resources amounting in aggregate to more than a /20 of address space. Resources received via section 4.1.8 may not be transferred within 60 months of the issuance date.

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. Qualified requesters whose request cannot be immediately met will also be advised of the availability of the transfer mechanism in section 8.3 as an alternative mechanism to obtain IPv4 addresses.

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Earlier Version

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Version Date: 29 April 2019

In accordance with section 10.2 of the ARIN Policy Development Process, the ARIN Advisory Council recommends the following actions to the Board of Trustees in response to the Board’s suspension of part of the operation of sections 4.1.8, 4.1.8.1 and 4.1.8.2 of the Numbering Resource Policy Manual:

Replace section 4.1.8 as follows, then reinstate the full operation of sections 4.1.8, 4.1.8.1 and 4.1.8.2 immediately.

4.1.8. Unmet Requests

In the event that ARIN does not have a contiguous block of addresses of sufficient size to fulfill a qualified request, ARIN will provide the requesting organization with the option to specify the smallest block size they’d be willing to accept, equal to or larger than the applicable minimum size specified elsewhere in ARIN policy. If such a smaller block is available, ARIN will fulfill the request with the largest single block available that fulfills the request.

If no such block is available, the organization will be provided the option to be placed on a waiting list of pre-qualified recipients, listing both the block size, for which the organization is qualified, which in the case of the waiting list shall not be larger than a /22, and the smallest block size acceptable to the organization. An organization may not be added to the waiting list if it already holds IPv4 resources amounting in aggregate to more than a /20 of address space. Resources received via section 4.1.8 may not be transferred within 60 months of the issuance date.

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. Qualified requesters whose request cannot be immediately met will also be advised of the availability of the transfer mechanism in section 8.3 as an alternative mechanism to obtain IPv4 addresses.