[ppml] Revision to 2007-17
Member Services
info at arin.net
Tue Apr 1 11:36:39 EDT 2008
Policy Proposal 2007-17
Title: Legacy Outreach and Partial Reclamation
Policy Revised: 28 March 2008
Date of Assessment: 1 April 2008
ARIN Staff Assessment (Revised)
The assessment of this proposal includes comments from ARIN staff and
the ARIN General Counsel. It contains analysis of procedural, legal, and
resource concerns regarding the implementation of this policy proposal
as it is currently stated. Any changes to the language of the proposal
may necessitate further analysis by staff and Counsel.
I. Proposal
Policy Proposal is available below and at:
http://www.arin.net/policy/proposals/2007_17.html
II. Understanding of the proposal
ARIN staff understands that this proposal would replace the existing
amnesty policy in NRPM Section 4.6.
III. Comments
A. ARIN Staff
There is currently an amnesty policy (NRPM 4.6) and an aggregation
policy (NRPM 4.7). Both policies contain clear and concise criteria and
have been used successfully by the ARIN community since implementation.
B. ARIN General Counsel
Pending.
IV. Resource Impact – Moderate
The resource impact of implementing this policy is viewed as moderate.
Barring any unforeseen resource requirements, this policy could be
implemented within 90 - 180 days from the date of the ratification of
the policy by the ARIN Board of Trustees. It will require the following:
• Updates to Registration Services Guidelines
• Staff training
• Tracking tools for the return of the space and for the yearly contact
requirement
• Creation of software that will flag records in WHOIS as "unreachable"
Respectfully submitted,
Member Services
American Registry for Internet Numbers (ARIN)
##*##
Owen DeLong wrote:
>
> The following revised version of 2007-17 is submitted for consideration.
> The amendments are being made to address concerns expressed by staff
> in the "staff assessment" of the policy proposal.
>
> I ran these changes by staff prior to submitting them here. The changes
> do address the concerns expressed by staff, but, staff may wish to revise
> their "impact" statement. Beyond this statement, I'll leave it to staff
> to comment further if they wish.
>
> Apologies for the late date on this amendment. Look forward to upcoming
> changes to the IRPEP to improve this situation.
>
> Owen
>
>
> Modifications:
>
> Extended 4.6.1 to allow ARIN to reject transactions of no benefit
> to the community. (Hopefully this closes most of the abuse loopholes)
>
> Renumbered 4.6.6 to 4.6.7 Annual contact required
>
> Renumbered 4.6.5 to 4.6.6 RSA Required if new addresses received
>
> Inserted new 4.6.5 to spell out requirement for ARIN to work with
> resource holders to specify a return timeframe in contract.
>
> Added text to rationale to clarify overriding intent and
>
> Policy Proposal 2007-17
> Legacy Outreach and Partial Reclamation
>
> Author: Owen DeLong
>
> Date: 21 February 2008
>
> Proposal type: modify
>
> Policy term: permanent
>
> Policy statement:
>
> Replace section 4.6 as follows:
>
> 4.6 Amnesty and Aggregation requests
>
> 4.6.1 Intent of this policy
>
> This policy is intended to allow the community and ARIN staff to work
> together with holders of address resources in the best interests of
> the community by facilitating the return of unused address space and
> the aggregation of existing space in a manner which is in the best
> interests of both parties.
>
> All transactions under this policy must either create greater
> aggregation (a reduction in the number of prefixes) or the return of
> address space. ARIN should reject any transaction which staff judges
> is not in the interests of the community.
>
> 4.6.2 No penalty for returning or aggregating
>
> ARIN shall seek to make the return of address space as convenient and
> risk-free to the returning organization as possible. An organization
> with several non-contiguous blocks seeking to aggregate and return
> space at the same time should be accommodated if possible. If it is
> possible to expand one block, for example, to facilitate the return of
> other blocks, ARIN should do th.6.3 Return should not force renumbering
>
> An organization shall be allowed to return a partial block of any size
> to ARIN. For any return greater than a /24, ARIN shall not require
> that the non-returned portion of the block be renumbered unless the
> returning organization wishes to do so.
>
> 4.6.4 Incentives
>
> The Board of Trustees should consider creating incentives for
> organizations to return addresses under this policy.
>
> 4.6.5 Timeframe for return
>
> Any organization which is returning addresses under this policy shall
> negotiate with ARIN an appropriate timeframe in which to return the
> addresses after any new resources are received under this policy. In
> the case of a simple return, the timeframe shall be immediate. In the
> case where renumbering into new addresses out of existing addresses to
> be returned is required, the returning organization shall sign a
> contract with ARIN which stipulates a final return date not less than
> 6 months nor more than 18 months after the receipt of new addresses.
> If an organization misses this return date, but, ARIN believes the
> organization is working in good faith to complete the renumbering,
> ARIN may grant a single extension of 6-12 months as staff deems
> appropriate to the situation. Such an extension must be requested in
> writing (email to hostmaster at arin.net <mailto:hostmaster at arin.net>) by
> the organization at least 15
> days prior to the original expiration date.
>
> 4.6.6 RSA Required if new addresses received
>
> Any organization which receives any additional addresses under this
> policy shall be required to sign an ARIN RSA which will apply to all
> new addresses issued and to any retained blocks which are expanded
> under this policy.
>
> 4.6.7 Annual contact required
>
> Any organization which participates in this policy shall be required
> to sign an agreement stipulating that ARIN will attempt contact at
> least once per year via the contact mechanisms registered for the
> organization in whois. Should ARIN fail to make contact, after
> reasonable effort the organization shall be flagged as "unreachable"
> in whois. After six months in "unreachable" status, the organization
> agrees that ARIN may consider all resources held by the organization
> to be abandoned and reclaim such resources. Should the organization
> make contact with ARIN prior to the end of the aforementioned six
> month period and update their contact information appropriately, ARIN
> shall remove the "unreachable" status and the annual contact cycle
> shall continue as normal. If the organization pays annual fees to
> ARIN, the payment of annual fees shall be considered sufficient contact.
>
> Rationale:
>
> Existing policy supports aggregation (4.7) and provides some amnesty
> (existing 4.6) for returning blocks. However, a number of resource
> holders have expressed discomfort with the current section 4.6
> believing that they will be forced to return their entire address
> space and renumber rather than being able to make partial returns and
> retain some of their existing space.
>
> This policy seeks to eliminate those concerns and make the return of
> unused address space more desirable to the resource holders.
>
> A very high percentage of underutilized space is in the hands of
> legacy holders who currently have no benefit to joining the ARIN
> process and no way to return any portion of their address space
> without incurring significant disadvantage as a result.
>
> A suggestion to the board would be to adopt benefits along the
> following lines for people returning space. These benefits would
> provide additional incentive for resource holders to make appropriate
> returns and for legacy holders to join the ARIN process:
>
> 1. If the organization does not currently pay ARIN fees, they shall
> remain fee exempt.
>
> 2. If the organization currently pays ARIN fees, their fees shall be
> waived for two years for each /20 returned, with any fractional /20
> resulting in a one-time single year waiver.
>
> 3. Any organization returning address space under this policy shall
> continue under their existing RSA or they may choose to sign the
> current RSA. For organizations which currently do not have an RSA,
> they may sign the current RSA, or, they may choose to remain without
> an RSA.
>
> 4. All organizations returning space under this policy shall, if they
> meet other eligibility requirements and so request, obtain an
> appropriate IPv6 end-user assignment or ISP allocation as applicable,
> with no fees for the first 5 years. Organizations electing to receive
> IPv6 allocation/assignment under this provision must sign a current
> RSA and must agree that their IPv4 resources are henceforth subject to
> the RSA.
>
> The overriding intent of this policy proposal is to make it as easy as
> possible for both ARIN and resource holders to "do the right thing"
> with regard to excess resources or dis-aggregated (fragmented) address
> blocks. It is the desire of the author that staff make any judgment
> calls necessary under this policy with that ideal clearly in mind.
> While the author has made a concerted effort to make the policy as
> clear as possible and
> as concrete as can be, the reality is that these types of transactions
> must rely heavily on the judgment and expertise of the ARIN staff in
> determining what is in the best interests of the community.
>
>
> Timetable for implementation: Immediate
>
>
> ------------------------------------------------------------------------
>
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