I support the Policy Proposal and addition. Rudi Daniel *danielcharles consulting <http://www.facebook.com/pages/Kingstown-Saint-Vincent-and-the-Grenadines/DanielCharles/153611257984774>* 1 784 430 9235 ........ict4d........
On Thu, May 14, 2020 at 11:50 AM <[email protected]> wrote: > Send ARIN-PPML mailing list submissions to > [email protected] > > To subscribe or unsubscribe via the World Wide Web, visit > https://lists.arin.net/mailman/listinfo/arin-ppml > or, via email, send a message with subject or body 'help' to > [email protected] > > You can reach the person managing the list at > [email protected] > > When replying, please edit your Subject line so it is more specific > than "Re: Contents of ARIN-PPML digest..." > > > Today's Topics: > > 1. Re: Revised and Reverted to Draft Policy - Draft Policy > ARIN-2019-1: Clarify Section 4 IPv4 Request Requirements (Owen > DeLong) > > > ---------------------------------------------------------------------- > > Message: 1 > Date: Thu, 14 May 2020 08:49:54 -0700 > From: Owen DeLong <[email protected]> > To: Fernando Frediani <[email protected]> > Cc: [email protected] > Subject: Re: [arin-ppml] Revised and Reverted to Draft Policy - Draft > Policy ARIN-2019-1: Clarify Section 4 IPv4 Request Requirements > Message-ID: <[email protected]> > Content-Type: text/plain; charset="utf-8" > > 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. > -------------- next part -------------- > An HTML attachment was scrubbed... > URL: < > https://lists.arin.net/pipermail/arin-ppml/attachments/20200514/40edceaf/attachment.htm > > > > ------------------------------ > > Subject: Digest Footer > > _______________________________________________ > ARIN-PPML mailing list > [email protected] > https://lists.arin.net/mailman/listinfo/arin-ppml > > > ------------------------------ > > End of ARIN-PPML Digest, Vol 179, Issue 6 > ***************************************** > <https://www.avast.com/sig-email?utm_medium=email&utm_source=link&utm_campaign=sig-email&utm_content=webmail&utm_term=icon> Virus-free. www.avast.com <https://www.avast.com/sig-email?utm_medium=email&utm_source=link&utm_campaign=sig-email&utm_content=webmail&utm_term=link> <#DAB4FAD8-2DD7-40BB-A1B8-4E2AA1F9FDF2>
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