[arin-ppml] ARIN-prop-131: Section 5.0 Legacy Addresses - revised
First Section 5 of the NRPM currently is labeled for dealing with AS
Number Policies. I assume you are intending to re-purpose the current
Section 5 for policies dealing with Legacy IPv4 addresses. I think I
would prefer to keep section 5 for any future AS Number related
policies. I think it would be more appropriate for this to be a new
sub-section under section 4, since really this is about Legacy IPv4
addresses. I don't think anyone is all that worried about Legacy AS
Numbers, and there are no Legacy IPv6 addresses, therefore it seems most
appropriate for this to be under section 4 where we deal with IPv4
resources. Other options might be a new sub-section of section 3.
Directory Services, or a whole new section.
As a number of others have commented, I don't understand why we want to
restrict this policy to Legacy Addresses. I am concerned that we could
have different hold periods between legacy IPv4 addresses and ARIN
allocated IPv4 addresses. This doesn't seem like a good idea to me.
It also seems important to more precisely define "IPv4 addresses
returned to or recovered by ARIN", ARIN staff has used revoked,
returned, reclaimed, all with slightly different meanings I believe. Do
you intend to include resources recovered for non-payment in a 30 day
hold time, that seems a little short to me, and would be in violation of
the LRSA for anyone who has taken up ARIN on the LRSA. (See Section 6b
of the LRSA, https://www.arin.net/resources/agreements/legacy_rsa.pdf)
Also, Draft Policy ARIN-2011-2 is directing ARIN to proactively recover
abandoned resources, if this gains consensus do you intend for these
resources to be included in the 30 day hold time too?
I'm OK with 30 days or less for voluntarily returned resources and maybe
even for resource revoked for fraud or other acts of commission. But,
30 days seems short for resource revoked for acts of omission, like
failing to pay a bill or update records. I'm not saying you intend to
include the later, but it is not entirely clear you didn't and I think
the policy needs to be clear about this one way or the other. And, I
prefer that these kind of things got more time. But, this additional
time needs to be weighed against the fact we will be out of IPv4
resources soon. So I think something like 60 or 90 days seems to strike
the right balance between these two issues.
By my interpretation, you seem to clearly be including resource revoked
for fraud or other acts of commission. I'm probably OK with that.
However, those are the kinds of situations that are likely to lead to
law suits and probably someone seeking injunctive relief from the courts
anyway. So maybe it is best to not to try to be in to much of a hurry
to distribute those resources out again, only to have a court order pull
them back again.
Finally, it seems to me that if someone voluntarily returns resources
they intend for the rest of the community to use them. Therefore, we
should honor their wishes and get these freed up resources into active
use with someone else as soon a reasonably possible. Since we are
approaching IPv4 resource exhaustion both regionally and globally, I
think a maximum of 30 day hold time for such voluntarily returned
resources is more than sufficiently prudent. Further, I think maybe we
should allow 60 or 90 days for all the other situations, expect when
otherwise dictated in the RSA or the LRSA, and we should leave the
agreements as they are. Additionally, I think the policy should
explicitly include, but not be limited to, Legacy IPv4 resources.
So, I suggest something like the following;
X. Recovered IPv4 Resources
X.1 Voluntarily Returned IPv4 Resources
All IPv4 resources voluntarily returned to ARIN, including any Legacy
IPv4 resources, will be made available for registration and distribution
within the ARIN region no more than thirty (30) days following receipt
of the resources.
X.2 Other Recovered IPv4 Resources
All other IPv4 resources recovered by ARIN, including any Legacy IPv4
resources, will be made available for registration and distribution
within the ARIN region ninety (90) days following their removal from the
registry database (Whois), unless terms of a valid Registry Services
Agreement otherwise apply.
On 2/10/11 09:03 CST, ARIN wrote:
> Policy statement:
> Section 5.0 Legacy Addresses
> 5.1 Returned Legacy Addresses
> Legacy IPv4 addresses returned to or recovered by ARIN will be made
> available for registration and distribution in the ARIN region within
> thirty days of their receipt.
> Adopting this proposal will result in the clarification of the status
> of returned legacy addresses. IPv4 address resources should not sit
> idle due to lack of policy clarity.
> Timetable for implementation: Immediately
David Farmer Email:farmer at umn.edu
Networking & Telecommunication Services
Office of Information Technology
University of Minnesota
2218 University Ave SE Phone: 612-626-0815
Minneapolis, MN 55414-3029 Cell: 612-812-9952