[ppml] Revised Policy Proposal 2007-14
Owen DeLong
owen at delong.com
Thu Feb 21 18:52:49 EST 2008
Based on feedback from the ARIN AC and from the Albuquerque meeting, I'm
posting this revised proposal for 2007-14.
Changes include:
Rational expanded to clarify that 2c creates a limitation on how
often ARIN can do a
without-cause review.
Changed the without cause limitation to 24 months instead of 12.
Rewrote Paragraph 4 in an attempt at greater clarity of intent.
Added paragraph 9 to address concerns about timed policies that have
not completed.
I hope that these revisions create a proposal which is acceptable to
the community. I know
that the community put significant effort into the discussion of this
proposal and I believe
that such a review process will benefit the community greatly.
Thanks,
Owen
Policy statement:
Add the following to the NRPM:
Resource Review
1. ARIN may review the current usage of any resources issued by ARIN
to an organization. The organization shall furnish whatever records
are necessary to perform this review.
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 24 months.
3. ARIN shall communicate the results of the review to the organization.
4. Organizations shown to be substantially out of compliance with
current ARIN policy shall return resources as needed to bring them
into (or reasonably close to) compliance.
4a. The extent to which an organization may remain out of compliance
shall be based on the best judgment of the ARIN staff and shall
balance the organizations utilization rate, available address pool,
and other factors as appropriate so as to avoid forcing returns which
will result in near-term additional requests or unnecessary route de-
aggregation.
4b. To the extent possible, entire blocks should be returned. Partial
address blocks shall be returned in such a way that 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
in the previous paragraph.
6. Except in cases of fraud, an organization shall be given a minimum
of 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
or revocation is pending, except no new maintenance fees shall be
assessed 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
compliance.
9. In considering compliance with policies which allow a timeframe
(such as a requirement to assign some number of prefixes within 5
years) failure to comply cannot be measured until after the timeframe
specified in the applicable policy has elapsed. Blocks subject to such
a policy shall be assumed in compliance with that policy until such
time as the specified time since issuance has elapsed.
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 4.2.3.1.
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
documentation required and standards should be the same.
The intent of paragraph 2c is to prevent ARIN from doing more than one
without-cause review in a 24 month period.
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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