Re: [arin-ppml] Draft Policy ARIN-2019-14: No Specified Transfers for 4.1.8.2 Blocks

2019-07-08 Thread Fernando Frediani
I like the 60 month restriction and finds it adequate as a mechanism to 
discourage fraud.


I don't think a complete prohibition on transfers is necessary, just a 
significant delay so those who are really committed in using the 
resources as they should and not to especulate or stockpiling can do 
things in an appropriate manner when the time comes for them.


Regards
Fernando Frediani

On 08/07/2019 14:56, Andrew Dul wrote:

Hello,

With the ARIN board recently adopting the AC's recommendation to 
re-instate the wait-list policy, we should now reconsider this draft 
policy to the wait-list policy in light of those changes. In the AC's 
recommendation, a 60 month transfer restriction was placed on any 
block received from the wait-list starting with the re-implementation 
of the policy.


Do you feel this 60 month restriction is sufficient?


This draft policy calls for prohibition on non M transfers and 
restricts M transfers to the same purpose as requested under the 
wait-list policy.


Would you prefer a complete prohibition on transfer of these blocks?  
Should an exception & restrictions be allowed for M transfers?



Your input here is helpful to help the AC determine if this draft 
policy should be updated to reflect the recently adopted re-instated 
wait-list policy text or if this draft policy should now be abandoned 
given the 60 month restriction in the current wait-list policy.



Thanks,

Andrew


On 5/21/2019 11:06 AM, ARIN wrote:
On 16 May 2019, the ARIN Advisory Council (AC) accepted 
"ARIN-prop-274: No Specified Transfers for 4.1.8.2 Blocks" as a Draft 
Policy.


Draft Policy ARIN-2019-14 is below and can be found at:
https://www.arin.net/participate/policy/drafts/2019_14/


Draft Policy ARIN-2019-14: No Specified Transfers for 4.1.8.2 Blocks

Problem Statement:

The ARIN “Unfulfilled Requests” policy creates an opportunity for an 
ARIN member to claim need for number resources, wait for those 
resources to become available via returns or reclamations, acquire 
them (per 4.1.8.2 of the NRPM), wait a day after the mandatory “hold 
time”, and then profit from them via a specified transfer transaction.


This waiting list policy freely provides number resources, creating 
an incentive for profit-taking through fraudulent applications or 
making misrepresentations to registration services.


ARIN can avoid this problem by prohibiting non-8.2 transfers for 
blocks distributed under 4.1.8.2 using language very similar to 
policy elsewhere in the NRPM.


Policy Statement:

Add a second paragraph to 4.1.8.2:

IP allocations issued through 4.1.8.2 are non-transferable via 
section 8.3 and section 8.4. In the case of a section 8.2, transfer 
of the IP assignment must be utilized for the same purpose or needs 
justified used for the original 4.1.8 application.


Comments:

Timetable for implementation: Immediate
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Re: [arin-ppml] ARIN-PPML Draft 2019-1

2019-07-08 Thread Kat Hunter
Good afternoon,

With the ARIN board recently adopting the AC's recommendation to re-instate
the wait-list policy, we should now reconsider Draft Policy ARIN-2019-1:
Clarify Section 4 IPv4 Request Requirements draft policy in light of those
changes. In the AC's recommendation, the specific part of this section
remains unchanged. Would everyone like to proceed with the following
changes:

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 36 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.


Would you like this to proceed to recommended draft as proposed? Feedback
before the reinstatement of the wait list was very positive for this and we
would appreciate any additional comments or verification on moving this to
recommended draft.

-Thanks
Kat Hunter

On Thu, Apr 18, 2019 at 8:27 AM Brian Jones  wrote:

> I support Draft Policy 2019-1 with the new proposed language.
>
> --
> Brian E Jones, CSP-SM, CSP-PO
> NI Virginia Tech
> bjo...@vt.edu
>
> On Apr 18, 2019, at 7:20 AM, Rudolph Daniel  wrote:
>
>
> I support this draft proposal..
> RD
>
> On Wed, Apr 17, 2019 at 12:00 PM  wrote:
>
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>>
>>1. Revised - Draft Policy ARIN-2019-1: Clarify Section 4 IPv4
>>   Request Requirements (ARIN)
>>
>>
>> --
>>
>> Message: 1
>> Date: Tue, 16 Apr 2019 14:26:07 -0400
>> From: ARIN 
>> To: arin-ppml@arin.net
>> Subject: [arin-ppml] Revised - Draft Policy ARIN-2019-1: Clarify
>> Section 4 IPv4 Request Requirements
>> Message-ID: <6a411169-0e13-2087-d6f2-5176a56bf...@arin.net>
>> Content-Type: text/plain; charset=utf-8; format=flowed
>>
>> The following has been revised:
>>
>> * Draft Policy ARIN-2019-1: Clarify Section 4 IPv4 Request Requirements
>>
>> 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 

Re: [arin-ppml] Draft Policy ARIN-2019-14: No Specified Transfers for 4.1.8.2 Blocks

2019-07-08 Thread Andrew Dul

Hello,

With the ARIN board recently adopting the AC's recommendation to 
re-instate the wait-list policy, we should now reconsider this draft 
policy to the wait-list policy in light of those changes. In the AC's 
recommendation, a 60 month transfer restriction was placed on any block 
received from the wait-list starting with the re-implementation of the 
policy.


Do you feel this 60 month restriction is sufficient?


This draft policy calls for prohibition on non M transfers and 
restricts M transfers to the same purpose as requested under the 
wait-list policy.


Would you prefer a complete prohibition on transfer of these blocks?  
Should an exception & restrictions be allowed for M transfers?



Your input here is helpful to help the AC determine if this draft policy 
should be updated to reflect the recently adopted re-instated wait-list 
policy text or if this draft policy should now be abandoned given the 60 
month restriction in the current wait-list policy.



Thanks,

Andrew


On 5/21/2019 11:06 AM, ARIN wrote:
On 16 May 2019, the ARIN Advisory Council (AC) accepted 
"ARIN-prop-274: No Specified Transfers for 4.1.8.2 Blocks" as a Draft 
Policy.


Draft Policy ARIN-2019-14 is below and can be found at:
https://www.arin.net/participate/policy/drafts/2019_14/


Draft Policy ARIN-2019-14: No Specified Transfers for 4.1.8.2 Blocks

Problem Statement:

The ARIN “Unfulfilled Requests” policy creates an opportunity for an 
ARIN member to claim need for number resources, wait for those 
resources to become available via returns or reclamations, acquire 
them (per 4.1.8.2 of the NRPM), wait a day after the mandatory “hold 
time”, and then profit from them via a specified transfer transaction.


This waiting list policy freely provides number resources, creating an 
incentive for profit-taking through fraudulent applications or making 
misrepresentations to registration services.


ARIN can avoid this problem by prohibiting non-8.2 transfers for 
blocks distributed under 4.1.8.2 using language very similar to policy 
elsewhere in the NRPM.


Policy Statement:

Add a second paragraph to 4.1.8.2:

IP allocations issued through 4.1.8.2 are non-transferable via section 
8.3 and section 8.4. In the case of a section 8.2, transfer of the IP 
assignment must be utilized for the same purpose or needs justified 
used for the original 4.1.8 application.


Comments:

Timetable for implementation: Immediate
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[arin-ppml] Board Adopts New Policies

2019-07-08 Thread ARIN

On 20 June 2019, the Board of Trustees adopted the following:

* ARIN-2017-12: POC Notification and Validation Upon Reassignment or 
Reallocation


* ARIN-2018-2: Clarification to ISP Initial Allocation

* ARIN-2018-5: Disallow Third-party Organization Record Creation

* ARIN-edit-2019-1: Remove IPv4 Reference in NRPM Section 6.10.1

* Recommended Draft Policy ARIN-2019-16: Advisory Council Recommendation 
Regarding NRPM 4.1.8. Unmet Requests


In order to reduce the overall engineering effort involved between 
ARIN-2017-12 and ARIN-2018-5, these two policies will be implemented in 
conjunction by Q1 2020.


The remaining policies will be implemented within the next week in 
accordance with their Staff and Legal Reviews, which rated their 
resource impacts as minimal.


Board of Trustees Meeting Minutes are available at:
https://www.arin.net/about/welcome/board/meetings/

Draft Policy and Policy Proposal texts are available at:
https://www.arin.net/participate/policy/drafts/

The ARIN Policy Development Process (PDP) can be found at:
https://www.arin.net/participate/policy/pdp/

Regards,

Sean Hopkins
Policy Analyst
American Registry for Internet Numbers (ARIN)
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