[arin-ppml] New Version of ARIN-prop-126: Compliance Requirement

[Chris Grundemann]

Hail PPML!

I am the primary AC shepherd for ARIN-prop-126: Compliance Requirement
and I would like to hear your comments and feedback on this new
version of the proposal (included below). If the community is happy
with this text; I will take the necessary steps as shepherd to advance
it to the next stage of the process, which would be getting the AC to
promote it to a draft policy (https://www.arin.net/policy/pdp.html).

One thing to note: This proposal updates existing policy and as such
not all of the text is new or a change. Please review the current
policy language when evaluating this proposal:
https://www.arin.net/policy/nrpm.html#twelve.

Thanks in advance for your input!

Cheers,
~Chris

####

ARIN-prop-126: Compliance Requirement

Proposal Originator: Marla Azinger

Proposal Version: 2

Date: 16 February 2011

Proposal type: new

Policy term: permanent

Policy statement:

Resource Review
Update the following NRPM Sections:

12.4 - Update to: Organizations found by ARIN to be out of compliance
with current ARIN policy shall be required to update reassignment
information or return resources as needed to bring them into (or
reasonably close to) compliance.

1. The degree 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 organization's 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.
2. 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.

(leave 12.5 as is)

12.6 - Update to: Except in cases of fraud, an organization shall be
given a minimum of thirty (30) days to respond. If an organization
does not respond within those thirty (30) days, ARIN may cease
providing reverse DNS services to that organization. If progress of
resource returns or record corrections is not visible within sixty
(60) days after correspondence with ARIN began, ARIN will cease
providing reverse DNS services for the resources in question. At any
time after ninety (90) days have passed, ARIN may initiate resource
revocation as allowed in paragraph 12.5. 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.

Rationale:

Version 2 addresses several staff and legal concerns with the original
text of this policy by clarifying the language and making it more
concrete.

To date the community has not documented or firmly established use of
an effective enforcement mechanism. This policy will support current
policy and compel those who are allocated ARIN resources to maintain
the proper WHOIS records in accordance with ARIN NRPM. While it is
recognized this is not an absolute solution to ensure compliance, it
is the best method under current ARIN policies.

Timetable for implementation: Immediate