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

[Owen DeLong]

On Feb 21, 2008, at 2:01 PM, Michael K. Smith - Adhost wrote:

> 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.
>
As I understand it, you object because you believe the policy by
itself would not be effective.  Would you agree it could be effective
if the BoT were to adopt additional incentives as recommended
in the Rationale section?  Those incentives were removed from the
policy text to address the technicality that fees, fee waivers and the
like are not policy matters and cannot be addressed in the policy
process.

>>> 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?
>
It means that any resource holder seeking to return resources to ARIN
should be able to do so without fear that ARIN will seek to do some
harm to the organization returning the address space.  For example,
returning address space will not force you to renumber (other than
to stop using the addresses you are returning).  It should not trigger
an additional audit of your retained resources.  Etcetera.  In general,
this is intended as a guideline statement to staff that the public
interest is best served if people have no reason to be afraid of  
returning
unused address space.

>>> 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?
>
This is intended to cover a situation where, for example, someone has  
a /16
and needs a /18 of that space.  Instead of returning the /16 and  
getting a
completely different /18, this policy would require ARIN staff to  
allow the
holder to return any /18 and /17 from the /16 while still keeping the / 
18 of
the holder's choosing.  Under current policy, theoretically, the  
holder could
be required to return the entire /16.  Although that is not current  
staff practice
in most such cases, it is how current policy is written.

>>>
>>> 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.
>
Again, because of the limitations of the policy process, should is the
strongest language that can be applied in this context.  I have a high
degree of confidence that if this policy is adopted, the board will
consider creating incentives.  Even if they do not, I don't see any
way in which this policy is harmful, and, the membership certainly
can through the member meeting process create a forcing function
for the board to consider incentives if this policy is adopted.
Fee issues are outside the purview of the policy process, so, this
was the best compromise I could strike.

>>>
>>> 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.
>
Not exactly.  You need to sign an RSA for new space anyway.
If you retain a block that is not expanded (i.e. you have a /16 and
you return all but a /18), you would not be required to sign an RSA.
If, on the other hand, you have 7 /24s that are non-contiguous and
you return 6 of them, retain 1 of them, and, are assigned the  
appropriate
other /24s to make it a /22 (effectively returning a net of 3 /24s),
you would be required to sign an RSA that covers the /22.
The RSA still wouldn't apply to any other blocks you retain.

>>> 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.
>
In order to be subject to this, you would have to participate in this
policy at least once.  Existing stale legacy contacts would not be
subject to this issue since they would have to contact ARIN and
update their contact information in order to participate in this
policy.  Once you've participated in this policy, you've agreed
to make contact with ARIN once a year and keep your contact
up to date.  All you need to do to avoid being labelled is make
a phone call once every 12 months, and, you can avoid your
resources being reclaimed by calling once every 18 months.

(An email works, too).  Also, note that in the next paragraph, if you
are paying fees every year, by paying your fee, you have met the
requirement to make contact.

>>> 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?
>
The bullets below can't be policy.  That is why they were removed from  
the
policy in this rewrite.  Fees are set by the BoT and are not part of  
the public
policy process.

>>>
>>> 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.
>
Nope.  Many legacy holders pay no fees.

>>> 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
>
Nope.  That's why it says "one-time single year waiver".  You only
get a free year the first time you return a /28.  After that, you'd have
to return at least a /20 to get additional fees waived.

I'm not necessarily opposed to your graduated structure either.
However, this discussion of fee waivers really would be more
appropriate on arin-discuss or as a suggestion sent to the BoT.
The text in the rationale section of the proposal is intended just
as a straw-man for what the BoT might consider.  It is really outside
of the purview of the policy process.
>
>>> 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.
>
That's possible now.  However, if they want to get it for a reduced  
fee or
for free, they face the tradeoff of bringing their legacy IPv4 under  
RSA.


Owen