ARIN-PPML Message

[ppml] Revised 2007-14

Policy Proposal 2007-14: Resource Review Process has been revised. This
proposal is open for discussion on this mailing list and will be on the
agenda at the upcoming ARIN Public Policy Meeting.

The current policy proposal text is provided below and is also available
at: http://www.arin.net/policy/proposals/2007_14.html

Regards,

Member Services
American Registry for Internet Numbers (ARIN)



Owen DeLong wrote:
> The following revisions to 2007-14 are being submitted in order
> to address some concerns expressed to the authors by ARIN
> counsel.  The authors do not believe that these changes alter
> the meaning or intent of the proposal.
> 
> This is the version that will be presented at the Denver meeting.
> 
> Version: 2.1
> Policy statement:
> 
> Add the following to the NRPM:
> 
> Resource Review
> 
> 1. ARIN may review the current usage of any resources issued by ARIN
> to an organization. The organization shall furnish whatever records
> are believed to be necessary by ARIN to perform this review.
> 
> 2. ARIN may conduct such reviews:
> 
> a. when any new resource is requested,
> b. whenever ARIN has reason to believe that the resources
> were originally obtained fraudulently, or
> c. at any other time without having to establish cause unless a
> prior review has been completed in the preceding 24 months.
> 
> 3. ARIN shall communicate the results of the review to the organization.
> 
> 4. Organizations found by ARIN to be substantially out of compliance
> with
> current ARIN policy shall be requested or required to return resources
> as
> needed to bring them into (or reasonably close to) compliance.
> 
> 4a. The extent to which an organization may remain out of compliance
> shall be based on the reasonable judgment of the ARIN staff and shall
> balance all facts known, including the organizations utilization rate,
> available address pool,  and other factors as appropriate so as to avoid
> forcing returns which  will result in near-term additional requests or
> unnecessary route de-aggregation.
> 
> 4b. To the extent possible, entire blocks should be returned. Partial
> address blocks shall be returned in such a way that the portion
> retained will comprise a single aggregate block.
> 
> 5. If the organization does not voluntarily return resources as
> requested, ARIN may revoke any resources issued by ARIN as required to
> bring the organization into overall compliance. ARIN shall follow the
> same guidelines for revocation that are required for voluntary return
> in the previous paragraph.
> 
> 6. Except in cases of fraud, or intentional violations of policy, an
> organization shall be given a minimum  of six months to effect a
> return. ARIN shall negotiate a longer term with the organization
> if ARIN believes the organization is working in good faith to
> substantially
> restore compliance and has a valid need for additional time to
> renumber out of the affected blocks.
> 
> 7. ARIN shall continue to maintain the resource(s) while their return
> or revocation is pending, except no any maintenance fees assessed
> during that period shall be calculated as if the return or revocation
> was complete.
> 
> 8. Legacy resources in active use, regardless of utilization, are not
> subject to revocation by ARIN. pursuant to this subsection. However,
> the utilization of legacy resources shall be considered during a
> review to assess overall compliance.
> 
> 9. In considering compliance with policies which allow a timeframe
> (such as a requirement to assign some number of prefixes within 5
> years) failure to comply cannot be measured until after the timeframe
> specified in the applicable policy has elapsed. Blocks subject to such
> a policy shall be assumed in compliance with that policy until such
> time as the specified time since issuance has elapsed.
> 
> 
> 
> Delete NRPM sections 4.1.2, 4.1.3, 4.1.4
> 
> Remove the sentence "In extreme cases, existing allocations may be
> affected." from NRPM section 4.2.3.1.
> 
> Rationale:
> 
> The authors have been told that current policy does not clearly give
> ARIN the power to review or reclaim resources except in cases of
> fraud, despite this being mentioned in the Registration Services
> Agreement. This policy proposal provides clear policy authority to
> do so, guidelines for how and under what conditions it shall be
> done, and a guarantee of a (minimum) six- month grace period
> so that the current user shall have time to renumber out of any
> resources to be reclaimed.
> 
> The nature of the "review" is to be of the same form as is currently
> done when an organization requests new resources, i.e. the
> documentation required and standards should be the same.
> 
> The intent of paragraph 2c is to prevent ARIN from doing more than one
> without-cause review in a 24 month period.
> 
> The renumbering period does not affect any "hold" period that ARIN may
> apply after return or revocation of resources is complete.
> 
> The deleted sections/text would be redundant with the adoption of this
> proposal.
> 
> Timetable for implementation: Immediate
> 
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