[arin-ppml] New Version of ARIN-prop-126: Compliance Requirement

[David Farmer]

On 5/15/11 14:12 CDT, Chris Grundemann wrote:
> On Wed, Apr 20, 2011 at 18:41, Scott Leibrand<scottleibrand at gmail.com>  wrote:
>> All,
>> How would you feel about striking the following sentence in 12.6?: "If
>> progress of resource returns or record corrections is not visible within
>> sixty (60) days after correspondence with ARIN began, ARIN will cease
>> providing reverse DNS services for the resources in question."
>> The preceding sentence says that "ARIN may cease providing reverse DNS
>> services" at any time after 30 days, and the requirement that ARIN
>> *will* cease providing reverse DNS after 60 days seems like it would limit
>> ARIN's ability to do the right thing if an organization is cooperating...
>> Thoughts?
>
> I think that the last sentence already provides this flexibility to
> ARIN staff: "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." Do you disagree?
>
> At this point, I think there is enough support for this idea that we
> should move the current text forward to draft status and discuss it in
> Philly (and on the list before then of course). Those who have not
> spoken up regarding this proposal are highly encouraged to do so.
>
> Thanks,
> ~Chris
> (Primary Shepherd, ARIN-prop-126)

Chris,

In reviewing the responses to the current text I don't think this text 
is ready yet.  I think there is general support for the intent of this 
policy. But there seems to be support for the change Scott is 
suggesting, I think it is a good suggestion too.

Additionally, I'm still not fully comfortable with the details of how 
breaking RDNS will be implemented by staff.  I'm not sure this is a 
policy issue itself, but I would like to see some implementation 
recommendations included, like that when RDNS service has been withdrawn 
that is directly visible in Whois to everyone and there should be an 
alert for any ARIN online accounts that have POCs associated with the 
resource, similar to how the invalid POC thing is working now.  If we 
are going to do this it needs to jump out a bite you, right now I'm 
worried that it will be to subtle.

>> On Wed, Feb 16, 2011 at 11:34 AM, Chris Grundemann<cgrundemann at gmail.com>
>> wrote:
>>>
>>> Hail PPML!
>>>
>>> I am the primary AC shepherd for ARIN-prop-126: Compliance Requirement
>>> and I would like to hear your comments and feedback on this new
>>> version of the proposal (included below). If the community is happy
>>> with this text; I will take the necessary steps as shepherd to advance
>>> it to the next stage of the process, which would be getting the AC to
>>> promote it to a draft policy (https://www.arin.net/policy/pdp.html).
>>>
>>> One thing to note: This proposal updates existing policy and as such
>>> not all of the text is new or a change. Please review the current
>>> policy language when evaluating this proposal:
>>> https://www.arin.net/policy/nrpm.html#twelve.
>>>
>>> Thanks in advance for your input!
>>>
>>> Cheers,
>>> ~Chris
>>>
>>> ####
>>>
>>> ARIN-prop-126: Compliance Requirement
>>>
>>> Proposal Originator: Marla Azinger
>>>
>>> Proposal Version: 2
>>>
>>> Date: 16 February 2011
>>>
>>> Proposal type: new
>>>
>>> Policy term: permanent
>>>
>>> Policy statement:
>>>
>>> Resource Review
>>> Update the following NRPM Sections:
>>>
>>> 12.4 - Update to: Organizations found by ARIN to be out of compliance
>>> with current ARIN policy shall be required to update reassignment
>>> information or return resources as needed to bring them into (or
>>> reasonably close to) compliance.
>>>
>>> 1. The degree 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 organization's 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.
>>> 2. 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.
>>>
>>> (leave 12.5 as is)
>>>
>>> 12.6 - Update to: Except in cases of fraud, an organization shall be
>>> given a minimum of thirty (30) days to respond. If an organization
>>> does not respond within those thirty (30) days, ARIN may cease
>>> providing reverse DNS services to that organization. If progress of
>>> resource returns or record corrections is not visible within sixty
>>> (60) days after correspondence with ARIN began, ARIN will cease
>>> providing reverse DNS services for the resources in question. At any
>>> time after ninety (90) days have passed, ARIN may initiate resource
>>> revocation as allowed in paragraph 12.5. 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.
>>>
>>> Rationale:
>>>
>>> Version 2 addresses several staff and legal concerns with the original
>>> text of this policy by clarifying the language and making it more
>>> concrete.
>>>
>>> To date the community has not documented or firmly established use of
>>> an effective enforcement mechanism. This policy will support current
>>> policy and compel those who are allocated ARIN resources to maintain
>>> the proper WHOIS records in accordance with ARIN NRPM. While it is
>>> recognized this is not an absolute solution to ensure compliance, it
>>> is the best method under current ARIN policies.
>>>
>>> Timetable for implementation: Immediate

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