This is great feedback. Thank you everyone. I agree with removing "summarily" is an easy correction and is probably an unnecessary word. Thanks all.
Kat On Thu, May 14, 2020 at 3:59 PM Martin Hannigan <[email protected]> wrote: > > Makes sense to me. +1 > > On Thu, May 14, 2020 at 1:50 PM Mike Burns <[email protected]> wrote: > >> I would support it with the removal of the pompous and meaningless word >> “summarily”. >> >> I like a clean NRPM. >> >> >> >> Regards, >> Mike >> >> >> >> >> >> *From:* ARIN-PPML <[email protected]> *On Behalf Of *Chris >> Woodfield >> *Sent:* Thursday, May 14, 2020 1:40 PM >> *To:* Owen DeLong <[email protected]>; ARIN-PPML List <[email protected]> >> *Subject:* Re: [arin-ppml] Revised and Reverted to Draft Policy - Draft >> Policy ARIN-2019-1: Clarify Section 4 IPv4 Request Requirements >> >> >> >> I support as written, but agree that the word can be removed from the >> proposal without changing its intent, so happy to see it removed. >> >> >> >> -Chris >> >> >> >> On May 14, 2020, at 9:49 AM, Owen DeLong <[email protected]> wrote: >> >> >> >> I don’t construe it that way, but I have no objection to either of >> Scott’s suggestions, either. >> >> >> >> My concern is for the end effect of the proposed policy which is the same >> with any of the proposed wordings. >> >> >> >> Owen >> >> >> >> >> >> On May 14, 2020, at 09:10 , Scott Leibrand <[email protected]> >> wrote: >> >> >> >> "Summarily" seems punitive, and doesn't seem necessary in this context. >> Perhaps just remove it and just leave "will be removed from the waitlist"? >> Or replace it with something like "immediately". >> >> >> >> -Scott >> >> >> >> On Thu, May 14, 2020 at 8:50 AM Owen DeLong <[email protected]> wrote: >> >> I support this addition and support the policy with the addition. >> >> >> >> Owen >> >> >> >> >> >> On May 14, 2020, at 08:37, Fernando Frediani <[email protected]> >> wrote: >> >> >> >> I support this proposal. >> It's fair to everybody and helps avoid fraud. >> >> Regards >> Fernando >> >> On 14/05/2020 11:56, Kat Hunter wrote: >> >> After making adjustments to the text, ARIN staff and legal conducted a >> new staff and legal review on 2019-1. You can view the updated review here: >> https://www.arin.net/participate/policy/drafts/2019_1/#staff-and-legal-review-30-april-2020 >> . >> It has been suggested that >> >> "It is worth noting that this Draft Policy does not include the removal >> of pending ARIN Waitlist requests for organizations that act as source >> organizations for 8.2, 8.3, or 8.4 transfers, which would allow them to >> conduct such transfers while waitlisted, and receive resources from the >> ARIN Waitlist immediately thereafter, as all organizations on the ARIN >> Waitlist have already applied, and are pending fulfillment. >> >> The text is clear and understandable, and can be implemented as written." >> >> After some discussion with some members of the AC, it was suggested that >> a new subsection is added to section 8 which would allow for additional >> clarity from this policy and some future cleanup via other future policy. >> >> "8.6 Waitlist Restrictions >> >> Any organization which is on the wait list and submits a request to be >> the source of a transfer under any provision in section 8 will be summarily >> removed from the wait list." >> >> I'd like to get the community's thoughts on the addition. With this >> addition, would you support the policy as written? >> >> -Kat Hunter >> >> >> >> On Tue, Mar 24, 2020 at 1:24 PM Kat Hunter <[email protected]> wrote: >> >> Owen, I think this is a good suggestion. I've updated the month >> designations in the other section to 90 days as, I agree, it is more >> precise when we are discussing shorter amounts of time. Additionally, I've >> taken your suggestion on wordsmithing that section and adjusted it just a >> little. >> >> >> >> " 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.". >> >> >> >> I wanted to make sure I specified that this was in reference to IPv4 and >> that the organization also remains a subsidiary, parent company, or under >> common ownership. Thank you for the input. Additionally I'd like to see if >> there is anyone else that still supports or no longer longer supports this >> policy as written. >> >> >> >> Kat Hunter >> >> >> >> On Wed, Mar 11, 2020 at 4:42 AM Owen DeLong <[email protected]> wrote: >> >> >> >> > On Mar 9, 2020, at 06:26 , ARIN <[email protected]> wrote: >> > >> > On 20 February 2020, the ARIN Advisory Council (AC) reverted the >> following Recommended Draft Policy to Draft Policy Status due to community >> feedback recommending significant substantive changes.: >> > >> > * Draft Policy ARIN-2019-1: Clarify Section 4 IPv4 Request Requirements >> > >> > The text has since been revised in response to that feedback. >> > >> > Revised text is below and can be found at: >> > >> > https://www.arin.net/participate/policy/drafts/2019_1/ >> > >> > You are encouraged to discuss all Draft Policies on PPML. The AC will >> evaluate the discussion in order to assess the conformance of this Draft >> Policy with ARIN's Principles of Internet number resource policy as stated >> in the Policy Development Process (PDP). Specifically, these principles are: >> > >> > * Enabling Fair and Impartial Number Resource Administration >> > * Technically Sound >> > * Supported by the Community >> > >> > The PDP can be found at: >> > https://www.arin.net/participate/policy/pdp/ >> > >> > Draft Policies and Proposals under discussion can be found at: >> > https://www.arin.net/participate/policy/drafts/ >> > >> > Regards, >> > >> > Sean Hopkins >> > Policy Analyst >> > American Registry for Internet Numbers (ARIN) >> > >> > >> > >> > >> > Draft Policy ARIN-2019-1: Clarify Section 4 IPv4 Request Requirements >> > >> > 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: >> > >> > After completion of an 8.2 transfer an organization may only apply for >> IPv4 address resources under Section 4.1.8. ARIN Waitlist if they have >> transferred IPv4 address resources under section 8.2 and the recipient >> organization is and remains a subsidiary, parent company, or an >> organization under common ownership of the same parent company as the >> organization that the IPv4 resources were transferred from. This >> restriction will last for 36 months and is applied to the organization that >> the IPv4 resources were transferred from and not the recipient. >> >> This paragraph cries out desperately for wordsmithing. It is very >> difficult to parse. >> >> Perhaps: >> >> An organization which serves as the source of an 8.2 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 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 3 months. >> >> This should read “90 days” instead of “3 months” to retain consistency >> with 4.1.8. >> >> > 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 3 months. >> >> This should read “90 days” instead of “3 months” to retain consistency >> with 4.1.8. >> >> > >> > 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. >> >> While I understand the desire to do this, I must point out that having >> the same rule specified in multiple places in the NRPM tends to lead to >> inconsistencies down the road. >> >> It is not at all unusual in this situation for a future policy proposal >> to miss one of these duplicate statements of the same rule and update only >> a subset of them. Even the above inconsistency in this proposal between 90 >> days in section 4 and 3 months for the same thing twice in section 8 serves >> as an example of the perils of duplicating the same rule in multiple >> locations. >> >> I suggest, therefore, that instead of duplicating the rules, we reference >> section 4.1.8 in each of those cases as follows: >> >> Recipients should be aware of the impact of transfers on their >> ability to apply and/or obtain space from the waitlist. These are spelled >> out in section 4.1.8. >> >> This provides clarity that there is an impact to be considered and clear >> guidance as to where to find that impact without abetting inconsistency. >> >> Owen >> >> _______________________________________________ >> ARIN-PPML >> You are receiving this message because you are subscribed to >> the ARIN Public Policy Mailing List ([email protected]). >> Unsubscribe or manage your mailing list subscription at: >> https://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact [email protected] if you experience any issues. >> >> >> >> _______________________________________________ >> >> ARIN-PPML >> >> You are receiving this message because you are subscribed to >> >> the ARIN Public Policy Mailing List ([email protected]). >> >> Unsubscribe or manage your mailing list subscription at: >> >> https://lists.arin.net/mailman/listinfo/arin-ppml >> >> Please contact [email protected] if you experience any issues. >> >> _______________________________________________ >> ARIN-PPML >> You are receiving this message because you are subscribed to >> the ARIN Public Policy Mailing List ([email protected]). >> Unsubscribe or manage your mailing list subscription at: >> https://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact [email protected] if you experience any issues. >> >> _______________________________________________ >> ARIN-PPML >> You are receiving this message because you are subscribed to >> the ARIN Public Policy Mailing List ([email protected]). >> Unsubscribe or manage your mailing list subscription at: >> https://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact [email protected] if you experience any issues. >> >> _______________________________________________ >> ARIN-PPML >> You are receiving this message because you are subscribed to >> the ARIN Public Policy Mailing List ([email protected]). >> Unsubscribe or manage your mailing list subscription at: >> https://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact [email protected] if you experience any issues. >> >> >> >> _______________________________________________ >> ARIN-PPML >> You are receiving this message because you are subscribed to >> the ARIN Public Policy Mailing List ([email protected]). >> Unsubscribe or manage your mailing list subscription at: >> https://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact [email protected] if you experience any issues. >> >> >> _______________________________________________ >> ARIN-PPML >> You are receiving this message because you are subscribed to >> the ARIN Public Policy Mailing List ([email protected]). >> Unsubscribe or manage your mailing list subscription at: >> https://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact [email protected] if you experience any issues. >> > _______________________________________________ > ARIN-PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List ([email protected]). > Unsubscribe or manage your mailing list subscription at: > https://lists.arin.net/mailman/listinfo/arin-ppml > Please contact [email protected] if you experience any issues. >
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