[ppml] Revised Policy Proposal Resource Reclamation

I would support this.  I would also support dropping the limitations  
on Point d, such that all allocations are subject to audit.  Frankly,  
I believe that if we invested the resources to audit all allocations,  
IPv4 exhaustion simply wouldn't occur for a much greater (4-6 year)  
period.  How much money is that worth?

On May 31, 2007, at 5:17 PM, Jason Schiller wrote:
> Kevin, how about a possible middle ground:
>
>              2.  ARIN may conduct such reviews:
>                      a. when any new resource is requested,
>                      b. whenever ARIN has cause to believe that the
>                         resources had originally been obtained
>                         fraudulently,
>                      c. whenever ARIN has cause to believe that the
>                         justification previously used is no longer
>                         valid, or
>                      d. if an orgization has not requested new  
> resources
>                         within one year of their last reques, ARIN may
>                         audit only the most recent allocation or
>                         assignment.
>
>
> Point c addresses Kevin's concern about the justification changing.
>
> Point d returns some of the origional flexibility of the policy to  
> allow
> ARIN to conduct an audit.  This can help limit abuse by allowing  
> followup
> for orgizations that will not likely need additional resources.  It  
> also
> minamizes the amount of pain placed on large orgizations by  
> limiting the
> audit to only the most recently allocated or assigned block.
>
> __Jason
>
> ====================================================================== 
> ====
> Jason Schiller                                               (703) 
> 886.6648
> Senior Internet Network Engineer                         fax:(703) 
> 886.0512
> Public IP Global Network Engineering                        
> schiller at uu.net
> UUNET / Verizon                          
> jason.schiller at verizonbusiness.com
>
> The good news about having an email address that is twice as long  
> is that
> it increases traffic on the Internet.
>
> On Mon, 30 Apr 2007, Kevin - Your.Org wrote:
>
>> Date: Mon, 30 Apr 2007 18:19:03 -0500
>> From: Kevin - Your.Org <kevin at your.org>
>> To: Public Policy Mailing List <ppml at arin.net>, policy at arin.net
>> Subject: Re: [ppml] Revised Policy Proposal Resource Reclamation
>>
>>
>> On Apr 30, 2007, at 3:26 PM, Owen DeLong wrote:
>>> 		2.  ARIN may conduct such reviews:
>>> 			a. when any new resource is requested,
>>> 			b. whenever ARIN has cause to believe that the resources had
>>> originally been obtained fraudulently, or
>>> 			c. at any other time without cause unless a prior review has
>>> been completed in the preceding 12 months.
>>
>>
>> I'm fine with A and B, but I can't say I support clause C in there as
>> it's written. While I don't think anyone at ARIN is malicious or
>> would conduct reviews unnecessarily, this strikes me as a blank check
>> to get an undefined "audit" every year that would require furnishing
>> arbitrary amounts of paperwork to comply.
>>
>> Getting paperwork and justification materials together when
>> requesting additional space is a predictable cost that can be planned
>> for in advance, and argued that it's necessary for business expansion
>> or whatever. More space = more revenue, so it's an investment. And,
>> the worst case that can happen there is you walk away no worse off
>> than you started, if the expenses/time required exceed what it's
>> worth to you. Especially for a small business where regular
>> allocation requests aren't made, these costs can be significant.
>>
>> A random inspection is at least as much effort, more risk (you risk
>> losing what you already have if you're unable to satisfy whatever
>> undocumented requirements there are for this) so you're probably
>> going to have to invest more time/money in making sure you get it
>> right, and a money hole in terms of what you get out of it.
>>
>> I can only see three reasons why an audit would need to take place.
>> You're asking for more space(you initiate this, you're planning for
>> it in advance, and you can walk away if you get in over your head),
>> you lied on your last application(all you would have to do is prove
>> you didn't lie), or whatever justification you used in a previous
>> application doesn't apply anymore(you've downsized and you really
>> should be giving space back.) Are there any other reasons why an
>> audit should take place, other than "because someone felt like it"?
>> If not, spell that out.
>>
>> I'd support:
>>
>> 		2.  ARIN may conduct such reviews:
>> 			a. when any new resource is requested,
>> 			b. whenever ARIN has cause to believe that the resources had
>> originally been obtained fraudulently, or
>> 			c. whenever ARIN has cause to believe the justification for the
>> resources no longer exists.
>>
>> Along with some kind of definition of exactly what a review entails,
>> how much time you have to respond to one, can it be appealed, etc. As
>> your proposal stands, it seems like ARIN can request arbitrary
>> amounts of paperwork
>>
>> While I understand that several people's interpretations of the
>> existing policy already gives ARIN the right to do this now, if we're
>> going to enumerate this policy specifically, don't turn it into the
>> ability to audit every organization every year without cause, with no
>> definition of what an audit even is, how the procedure is supposed to
>> work, or why you can get audited.
>>
>> -- Kevin
>>
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