[ppml] Policy Proposal: Resource Review Process

[Stephen Sprunk]

This proposal was originally titled "Reclamation of Number Resources"; Owen 
and I have reviewed comments on the second revision, have worked with the AC 
shepherds to revise it again, and felt a change in title was prudent to 
avoid potential confusion with the more recent, but unrelated, proposal 
titled "Resource Reclamation Incentives".


Policy Proposal Name: Resource Review Process
Author: Owen DeLong, Stephen Sprunk
Proposal Version: 3
Submission Date: 07/17/07
Proposal type: modify
Policy term: permanent
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 
necessary to perform this review.

   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.

   3.  ARIN shall communicate the results of the review to the organization.

   4.  If the review shows that existing usage is substantially not in 
compliance with current allocation and/or assignment policies, the 
organization shall return resources as needed to bring them substantially 
into compliance.  If possible, only whole resources shall 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 
required, 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, 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 new maintenance fees shall be assessed for 
the resource(s).

   8.  Legacy resources in active use, regardless of utilization, are not 
subject to revocation by ARIN.  However, the utilization of legacy resources 
shall be considered during a review to assess overall compliance.


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:

ARIN feels that current policy does not give them 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 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




Stephen Sprunk      "Those people who think they know everything
CCIE #3723         are a great annoyance to those of us who do."
K5SSS                                             --Isaac Asimov