[ppml] Policy Proposal 2007-14: Resource Review Process

Dave Mohler MOHLER at graceland.edu
Thu Jul 26 10:08:24 EDT 2007

I understand the goals of this policy. 

My concern is that the policy, as worded, obscures the nature of the
communication of "the results of the review to the organization"
(paragraph 3).  It seems to me that that communication actually
constitutes notice of a _requirement_ to return to ARIN a set of
resources which would bring the organization into compliance with a
deadline of no less than six months.

Specifically, the phrase "voluntarily return" in paragraph 5 implies to
me a decision solely on the part of the organization to bring themselves
into compliance.  The policy actually _requires_ the return of these
resources; the organization simply has up until this deadline to return
(or demonstrate to ARIN that they are "working in good faith" to return)
the required amount resources according to a plan the organization
devises before ARIN revokes the resources.

Is there some way to word paragraph 3 to clearly communicate this
expectation to those reading the policy and to remove the ambiguity that
I see caused by the inclusion of the phrase "voluntarily return" in
paragraph 5?

David A. Mohler
Senior Network Specialist
Graceland University

> Policy Proposal 2007-14
> Resource Review Process
> Author: Owen DeLong, Stephen Sprunk
> 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
> 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
> the previous paragraph.
> 6. Except in cases of fraud, an organization shall be given a minimum
> 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
> revocation is pending, except no new maintenance fees shall be
> 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
> 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
> Policy Rationale
> 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
> 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
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