[ppml] Revised Policy Proposal Resource Reclamation

[Jason Schiller]

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                        justification previously used is no longer
                        valid, or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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