[ppml] Revised 2007-14
owen at delong.com
Sat Mar 22 18:34:08 EDT 2008
The following revisions to 2007-14 are being submitted in order
to address some concerns expressed to the authors by ARIN
counsel. The authors do not believe that these changes alter
the meaning or intent of the proposal.
This is the version that will be presented at the Denver meeting.
Add the following to the NRPM:
1. ARIN may review the current usage of any resources issued by ARIN
to an organization. The organization shall furnish whatever records
are believed to be necessary by ARIN to perform this review.
2. ARIN may conduct such reviews:
a. when any new resource is requested,
b. whenever ARIN has reason to believe that the resources
were originally obtained fraudulently, or
c. at any other time without having to establish 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 found by ARIN to be substantially out of compliance
current ARIN policy shall be requested or required to return resources
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 reasonable judgment of the ARIN staff and shall
balance all facts known, including 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
requested, 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, or intentional violations of policy, 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
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 any maintenance fees assessed
during that period shall be calculated as if the return or revocation
8. Legacy resources in active use, regardless of utilization, are not
subject to revocation by ARIN. pursuant to this subsection. 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 184.108.40.206.
The authors have been told that current policy does not clearly give
ARIN 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
Timetable for implementation: Immediate
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