Proposal Originator: Andrew Dul
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.
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.
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.
Timetable for Implementation: Immediate