[ppml] Policy Proposal 2007-17 - Staff Assessment

[Owen DeLong]

This appears to be an evaluation of the original 2007-17 proposal  
without
regard to the updated version which was submitted.

The revised proposal addresses most of the concerns expressed by staff
and counsel.  Below is the message I sent on September 15 which
contains the revised policy:

> Specific ideas incorporated into this proposal:
> 	1.	Specific fee statements removed.  Fees are not the realm
> 		of IRPEP, so, it is replaced with a requirement for the BoT
> 		to develop appropriate incentives.
>
> 	2.	An oversight in the original version did not provide a
> 		timeframe in which addresses were to be returned.
> 		This version adopts a 12 month timeframe with staff
> 		discretion for up to 2 extensions of 6 months each.
>
> 	3.	This proposal differs from the existing section 4.6 in
> 		that it places discretion over whether a subnet of
> 		a returned block may be retained or not in the hands
> 		of the address holder.  There was some suggestion
> 		from some AC members that this discretion should
> 		only be given to legacy holders while ARIN staff should
> 		retain discretion over non-legacy resources.  I do not
> 		have a strong opposition to such a change, but, I do
> 		feel that the policy is actually better as is, so, I have
> 		chosen not to add this revision.  I would like to see
> 		discussion on this area, and, if it is possible, I would
> 		like this version to allow the AC discretion to gauge
> 		consensus on whether this edit should be added
> 		prior to last call.
>
>
> Revised proposal is as follows:
>
>
> Policy Proposal 2007-17
> Legacy Outreach and Partial Reclamation
>
> Author: Owen DeLong
>
> Proposal Version: 1.0
> Submission Date: 2007 September 15
>
> Proposal type: modify
>
> Policy term: permanent
>
> Policy statement:
>
> Modify section 4.6 as follows:
>
> 4.6 Amnesty Requests:
>
> ARIN will accept the return or relinquishment of
> any address space from any existing address holder. If the address
> holder wishes to aggregate into a single block, ARIN may work with the
> address holder to arrive at an allocation or assignment which is equal
> to or smaller than the sum of their existing blocks and which best  
> meets
> the needs of the existing holder and the community. The organization
> returning the addresses shall have 12 months from the date they  
> receive
> their new addresses to return the addresses under this policy.  
> Organizations
> may request no more than 2 six month extensions to this time, which,
> may be granted at ARIN the discretion of ARIN staff. There shall be no
> fee for returning addresses under this policy. Further, organizations
> returning addresses under this policy shall receive the following  
> benefits:
>
> 1. If the organization does not currently pay ARIN fees, they shall
> remain fee exempt.
>
> 2. The BoT shall develop an incentive program to encourage such
> returns.  Such incentives may include fee reductions and/or other
> such mechanisms as the BoT deems appropriate.
>
> 3. Any organization returning address space under this policy shall
> continue under their existing RSA or they may choose to sign the  
> current
> RSA. For organizations which currently do not have an RSA, they may  
> sign
> the current RSA, or, they may choose to remain without an RSA.
>
> 4. All organizations returning space under this policy shall, if they
> meet other eligibility requirements and so request, obtain an
> appropriate IPv6 end-user assignment or ISP allocation as applicable,
> with no fees for the first 5 years. Organizations electing to receive
> IPv6 allocation/assignment under this provision must sign a current  
> RSA
> and must agree that all of their IPv4 and ASN resources are  
> henceforth subject
> to the RSA. Organizations taking this election shall be subject to
> end-user fees for their IPv4 resources not previously under an ARIN  
> RSA.
> If they are already an ARIN subscriber, then IPv4 resources  
> affected by
> this process may, instead, be added to their existing subscriber
> agreement at the address holder's discretion.
>
> Rationale:
>
> The current amnesty policy does a nice job of facilitating  
> aggregation,
> which was the intent when it was drafted. However, as we approach IPv4
> free-space exhaustion, the community now has an additional need to
> facilitate address reclamation.
>
> A very high percentage of underutilized space is in the hands of  
> legacy
> holders who currently have no benefit to joining the ARIN process.
> Further, there is an unfortunate perception that doing so will require
> force the legacy holder into certain future disadvantages. This  
> proposal
> attempts to resolve both of those issues while also providing some
> incentive to legacy organizations to start using IPv6 resources and
> bring their IPv4 resources into the ARIN process.
>
> This policy attempts to provide some benefit and remove most of the
> costs of making partial IPv4 returns. It also attempts to provide an
> incentive for these IPv4 holders to join the ARIN process.
>
> It is suggested that the BoT adopt fee incentives such as the
> elimination of 2 years of ARIN fees for each /20 returned.
>
>
> Timetable for implementation: Immediate
>
>


Sorry for any confusion.

Owen