[arin-ppml] ARIN-prop-131: Section 5.0 Legacy Addresses - revised

David Farmer farmer at umn.edu
Fri Feb 11 11:46:38 EST 2011

First Section 5 of the NRPM currently is labeled for dealing with AS 
Number Policies.  I assume you are intending to re-purpose the current 
Section 5 for policies dealing with Legacy IPv4 addresses.  I think I 
would prefer to keep section 5 for any future AS Number related 
policies.  I think it would be more appropriate for this to be a new 
sub-section under section 4, since really this is about Legacy IPv4 
addresses.  I don't think anyone is all that worried about Legacy AS 
Numbers, and there are no Legacy IPv6 addresses, therefore it seems most 
appropriate for this to be under section 4 where we deal with IPv4 
resources.  Other options might be a new sub-section of section 3. 
Directory Services, or a whole new section.

As a number of others have commented, I don't understand why we want to 
restrict this policy to Legacy Addresses.  I am concerned that we could 
have different hold periods between legacy IPv4 addresses and ARIN 
allocated IPv4 addresses.  This doesn't seem like a good idea to me.

It also seems important to more precisely define "IPv4 addresses 
returned to or recovered by ARIN", ARIN staff has used revoked, 
returned, reclaimed, all with slightly different meanings I believe. Do 
you intend to include resources recovered for non-payment in a 30 day 
hold time, that seems a little short to me, and would be in violation of 
the LRSA for anyone who has taken up ARIN on the LRSA. (See Section 6b 
of the LRSA, https://www.arin.net/resources/agreements/legacy_rsa.pdf) 
Also, Draft Policy ARIN-2011-2 is directing ARIN to proactively recover 
abandoned resources, if this gains consensus do you intend for these 
resources to be included in the 30 day hold time too?

I'm OK with 30 days or less for voluntarily returned resources and maybe 
even for resource revoked for fraud or other acts of commission.  But, 
30 days seems short for resource revoked for acts of omission, like 
failing to pay a bill or update records.  I'm not saying you intend to 
include the later, but it is not entirely clear you didn't and I think 
the policy needs to be clear about this one way or the other.  And, I 
prefer that these kind of things got more time.  But, this additional 
time needs to be weighed against the fact we will be out of IPv4 
resources soon. So I think something like 60 or 90 days seems to strike 
the right balance between these two issues.

By my interpretation, you seem to clearly be including resource revoked 
for fraud or other acts of commission.  I'm probably OK with that. 
However, those are the kinds of situations that are likely to lead to 
law suits and probably someone seeking injunctive relief from the courts 
anyway.  So maybe it is best to not to try to be in to much of a hurry 
to distribute those resources out again, only to have a court order pull 
them back again.

Finally, it seems to me that if someone voluntarily returns resources 
they intend for the rest of the community to use them.  Therefore, we 
should honor their wishes and get these freed up resources into active 
use with someone else as soon a reasonably possible.  Since we are 
approaching IPv4 resource exhaustion both regionally and globally, I 
think a maximum of 30 day hold time for such voluntarily returned 
resources is more than sufficiently prudent.  Further, I think maybe we 
should allow 60 or 90 days for all the other situations, expect when 
otherwise dictated in the RSA or the LRSA, and we should leave the 
agreements as they are.  Additionally, I think the policy should 
explicitly include, but not be limited to, Legacy IPv4 resources.

So, I suggest something like the following;

X. Recovered IPv4 Resources

X.1 Voluntarily Returned IPv4 Resources

All IPv4 resources voluntarily returned to ARIN, including any Legacy 
IPv4 resources, will be made available for registration and distribution 
within the ARIN region no more than thirty (30) days following receipt 
of the resources.

X.2 Other Recovered IPv4 Resources

All other IPv4 resources recovered by ARIN, including any Legacy IPv4 
resources, will be made available for registration and distribution 
within the ARIN region ninety (90) days following their removal from the 
registry database (Whois), unless terms of a valid Registry Services 
Agreement otherwise apply.

On 2/10/11 09:03 CST, ARIN wrote:

> Policy statement:
> Section 5.0 Legacy Addresses
> 5.1 Returned Legacy Addresses
> Legacy IPv4 addresses returned to or recovered by ARIN will be made
> available for registration and distribution in the ARIN region within
> thirty days of their receipt.
> Rationale:
> Adopting this proposal will result in the clarification of the status
> of returned legacy addresses. IPv4 address resources should not sit
> idle due to lack of policy clarity.
> Timetable for implementation: Immediately

David Farmer               Email:farmer at umn.edu
Networking & Telecommunication Services
Office of Information Technology
University of Minnesota	
2218 University Ave SE	    Phone: 612-626-0815
Minneapolis, MN 55414-3029   Cell: 612-812-9952

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