[ppml] Policy Proposal 2007-17 - Staff Assessment

[Member Services]

Policy Proposal 2007-17	
Title:  Legacy Outreach and Partial Reclamation
Date Submitted: Feb. 21, 2008
Date of Assessment: Mar 21, 2008

ARIN Staff Assessment

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 as Annex A below and at:
http://www.arin.net/policy/proposals/2007_17.html

The proposal was revised, current version dated 21 February 2008.

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
1.	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.
2.	This proposal seems to be combining both of these policies into one
policy.  If that is the case, it needs to explicitly state that.
3.	The proposed policy text implies that ARIN will issue new addresses
to organizations in exchange for returned addresses, but does not
explicitly state that.
4.	The proposed policy text removes the 12 month renumbering timeframe,
creating significant abuse potential.   Since there's no renumbering
timeframe, nothing prevents the requestor from keeping both the smaller
aggregates and the large aggregate indefinitely.
5.	The proposed policy text requires ARIN to accept all amnesty or
aggregation returns without prejudice, creating more avenues for abuse.
  For example, a spammer would be able to use this policy to repeatedly
exchange blacklisted space for clean space.
6.	If anyone is allowed to exchange their space without limitation, this
could affect the remaining supply of IPv4 address space.

B.	ARIN General Counsel

The policy creates no significant legal or litigation concerns.

Comment for author or AC to consider, but not in a binding way: if ARIN
label's some set of resources as in the control of someone 'unreachable'
in whois, do we inadvertently encourage hijacking and spamming during
the waiting period before revocation?

The prior expressed concerns about binding board or inappropriately
getting into fee setting of board have been addressed by changes.


IV. Resource Impact – Minimal

The resource impact of implementing this policy is viewed as minimum.
Barring any unforeseen resource requirements, this policy could be
implemented within 30 - 90 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 will be required
• Staff training will be required
• Tracking tools for the return of the space and for the yearly contact
requirement

Respectfully submitted,

Member Services
American Registry for Internet Numbers (ARIN)


##*##


Annex A

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.

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 that where possible.

4.6.3 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 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.

4.6.6 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.

Timetable for implementation: Immediate