[arin-ppml] Policy Proposal 117: Required Resource Reviews

[Member Services]

ARIN received the following policy proposal and is posting it to the
Public Policy Mailing List (PPML) in accordance with the Policy
Development Process.

This proposal is in the first stage of the Policy Development Process.
ARIN staff will perform the Clarity and Understanding step to make sure
that they understand the proposal and believe the community will as
well. Staff will report their results to the ARIN Advisory Council (AC)
within 10 days.

The AC will review the proposal at their next regularly scheduled
meeting (if the period before the next regularly scheduled meeting is
less than 10 days, then the period may be extended to the subsequent
regularly scheduled meeting). The AC will decide how to utilize the
proposal and announce the decision to the PPML.

In the meantime, the AC invites everyone to comment on the proposal on
the PPML, particularly their support or non-support and the reasoning
behind their opinion. Such participation contributes to a thorough
vetting and provides important guidance to the AC in their deliberations.

Draft Policies and Proposals under discussion can be found at:
https://www.arin.net/policy/proposals/index.html

The ARIN Policy Development Process can be found at:
https://www.arin.net/policy/pdp.html

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Regards,

Member Services
American Registry for Internet Numbers (ARIN)


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Policy Proposal 117: Required Resource Reviews

Proposal Originator: Owen DeLong

Proposal Version: 1

Date: 21 June 2010

Proposal type: new

Policy term: permanent

Policy statement:

Replace the text "under sections 4-6" in section 12, paragraph 7 with
"under paragraphs 12.4 through 12.6"

Add to section 12 the following text:

10. Except as provided below, resource reviews are conducted at the
discretion of the ARIN staff.  In any of the circumstances mentioned
below, a resource review must be initiated by ARIN staff:

a. Report or discovery of an acquisition, merger, transfer, trade or
sale in which the infrastructure and customer base of a network move
from one organization to another organization, but, the applicable IP
resources are not transferred. In this case, the organization retaining
the IP resources must be reviewed. The organization receiving the
customers may also be reviewed at the discretion of the ARIN staff.

b. Upon receipt by ARIN of one or more credible reports of fraud or
abuse of an IP address block. The credibility of a report shall be
determined by ARIN staff. If staff determines a report is not
sufficiently credible, the reporter may appeal the decision to the ARIN
CEO. In this case, the decision of the CEO shall be final.

c.Upon receipt by ARIN of five or more reports from separate individuals
representing at least three separate organizations of fraud or abuse for
the same organization or the same IP address block.

d. In the case where an organization wishes to act as recipient of
resources pursuant to a transfer under section 8.3, unless otherwise
prohibited by paragraph 12.2(c).

e. An organization which submits a request for additional resources when
more than 25% of their existing resources are obscured in SWIP or RWHOIS
pursuant to section 4.2.3.7.6 (residential customer privacy).

Rationale:

The first change is a minor correction which improves clarity and
consistency of the original policy without changing the meaning.

The addition of 12.10 (a) through (e) serves to create a set of
circumstances under which a resource review is required, rather than
optional and entirely at ARIN staff discretion.

The majority of early comments on this proposal focused on 12.10 (e).
Mostly it was confusion about the exact ramifications. This section will
cause ARIN to maintain greater scrutiny only in cases where a given ISP
issues more than 25% of their total space to residential customers who
wish to remain anonymous and receive network blocks of /29 or larger. To
the best of my knowledge, there are not currently any ISPs which meet
this criteria. Additionally, it would only apply that scrutiny to IPv4,
and will not carry forward into IPv6 residential assignments.

This should improve the compliance verification of ARIN policies and may
result in the improved reclamation of under-utilized IP address space.
It should also serve as a deterrent to certain address hoarding tactics
which have come to light in recent history.

Timetable for implementation: Immediately upon ratification by the Board