[ppml] Revised 2007-17 Legacy outreach and partial reclamation

[Michael K. Smith - Adhost]

Hello All:

I oppose this policy as written.  I have put comments in line below, but in summary, the incentives to Legacy holders seem largely ephemeral in comparison to the disincentives and, as such, I don't think this policy will be well received by the Legacy community.  It should be noted that I am not a Legacy address holder.

> > Replace section 4.6 as follows:
> >
> > 4.6 Amnesty and Aggregation requests
> > 4.6.1 Intent of this policy
> > This policy is intended to allow the community and ARIN staff
> > to work together with holders of address resources in the
> > best interests of the community by facilitating the return of
> > unused address space and the aggregation of existing space
> > in a manner which is in the best interests of both parties.
> >
This certainly sounds hopeful.

> > 4.6.2 No penalty for returning or aggregating
> > ARIN shall seek to make the return of address space as convenient
> > and risk-free to the returning organization as possible. An
> > organization with several non-contiguous blocks seeking to
> > aggregate and return space at the same time should be accommodated
> > if possible. If it is possible to expand one block, for example,
> > to facilitate the return of other blocks, ARIN should do that
> > where possible.
> >
Here's where we get ephemeral.  What does "as convenient and risk-free...as possible" actually mean?

> > 4.6.3 Return should not force renumbering
> > An organization shall be allowed to return a partial block of
> > any size to ARIN. For any return greater than a /24, ARIN shall
> > not require that the non-returned portion of the block be renumbered
> > unless the returning organization wishes to do so.

I'm not sure I understand the intent of this one.  Is this to say ARIN will not require the owner to renumber within the remaining block, or renumber out of the block into a new, non-Legacy block at some future date?

> >
> > 4.6.4 Incentives
> > The Board of Trustees should consider creating incentives for
> > organizations to return addresses under this policy.

Should?  That doesn't really say much to my mind.  I think a "must" or "will" would be in order to make this palatable.

> >
> > 4.6.5 RSA Required if new addresses received
> > Any organization which receives any additional addresses under
> > this policy shall be required to sign an ARIN RSA which will
> > apply to all new addresses issued and to any retained blocks
> > which are expanded under this policy.
> >

So this seems like a clearly defined "stick."  As I read this, I need to sign an RSA for new space and for the space left over after any reclamation.

> > 4.6.6 Annual contact required
> > Any organization which participates in this policy shall be
> > required to sign an agreement stipulating that ARIN will attempt
> > contact at least once per year via the contact mechanisms
> > registered for the organization in whois. Should ARIN fail
> > to make contact, after reasonable effort the organization
> > shall be flagged as "unreachable" in whois. After six months
> > in "unreachable" status, the organization agrees that ARIN
> > may consider all resources held by the organization to be
> > abandoned and reclaim such resources. Should the organization
> > make contact with ARIN prior to the end of the aforementioned
> > six month period and update their contact information
> > appropriately, ARIN shall remove the "unreachable" status
> > and the annual contact cycle shall continue as normal.
> >

I like the intent of this, but given the gravity of the outcome of being labeled "unreachable" I think a single, annual contact attempt and a "reasonable effort" are not sufficient for de-allocating the resource.  I would like to know what a reasonable effort is.  My guess is a lot of the Legacy contact information for an entity is stale, but the entity itself is not.

> > If the organization pays annual fees to ARIN, the payment
> > of annual fees shall be considered sufficient contact.
> >
> > Rationale:
> >
> > Existing policy supports aggregation (4.7) and provides some
> > amnesty (existing 4.6) for returning blocks.  However, a number
> > of resource holders have expressed discomfort with the current
> > section 4.6 believing that they will be forced to return their
> > entire address space and renumber rather than being able to
> > make partial returns and retain some of their existing space.
> >
> > This policy seeks to eliminate those concerns and make the return
> > of unused address space more desirable to the resource holders.
> >
> > A very high percentage of underutilized space is in the hands of
> > legacy holders who currently have no benefit to joining the ARIN
> > process and no way to return any portion of their address space
> > without incurring significant disadvantage as a result.
> >
> > A suggestion to the board would be to adopt benefits along the
> > following lines for people returning space. These benefits would
> > provide additional incentive for resource holders to make appropriate
> > returns and for legacy holders to join the ARIN process:
> >

I'm assuming one or more of the bullets below would be rolled up under 4.6.4?

> >
> > 1. If the organization does not currently pay ARIN
> > fees, they shall remain fee exempt.
> >
Don't the vast majority pay some sort of fees already?  I thought even the Legacy holders paid at least a nominal fee to ARIN.

> > 2. If the organization currently pays ARIN fees,
> > their fees shall be waived for two years for
> > each /20 returned, with any fractional /20
> > resulting in a one-time single year waiver.
> >
So, if I return a /28 a year I get a single year waiver for each /28?  Hrmm.  How about:

/24 - /23 -> 6 month waiver
/22 - /21 -> 1 year waiver
/20 - /17 -> 2 year waiver
/16 - /8 -> 5 year waiver


> > 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.
> >


This would probably meet with the least resistance.

> > 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 their IPv4 resources are
> > henceforth subject to the RSA.
> > 

This seems to be a disincentive to getting IPv6 space.  I want everyone to get IPv6 *now* so I don't want ARIN to put stipulations on any IPv4-holder to acquiring IPv6 space.  I would rather see something along the lines of "IPv6 assignments will be made separate and distinct from any previous IPv4 assignments and will be entered into under a separate RSA from any other agreements that may exist."  IANAL so that last sentence was off-the-cuff.  Basically, let them get the /32 under the same arrangements as me and don't put any restrictions based upon their legacy allocations or contracts.

Regards,

Michael Smith
Adhost Internet LLC.
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