[arin-ppml] ARIN-prop-152 RSA Modification Limits

[Owen DeLong]

On May 27, 2011, at 1:57 PM, William Herrin wrote:

> On Fri, May 27, 2011 at 9:31 AM, ARIN <info at arin.net> wrote:
>> ARIN-prop-152 RSA Modification Limits
> 
>> All transfers conducted under section 8 of the NRPM shall require the
>> recipient to sign an RSA which provides at least the same limitations
>> and restrictions as the standard RSA that would be used with any new
>> allocation or assignment of number resources in at least the following
>> areas:
>> 
>>  a. Justified Need Requirements
>>  b. Subject to and Effect of NRPM 12
>>  c. Requirement for an annual fee to be paid
>>  d. Subject to future policy revisions adopted by the community
>> 
>> The above requirements may be waived to the extent necessary to meet a
>> court order or settlement, but, such court order must be public or such
>> settlement must include terms allowing the settlement terms to be
>> published by ARIN, including the list of affected addresses and the
>> exact resulting RSA. ARIN shall publish the terms of any such settlement
>> and the resulting RSA within 10 days of drafting the settlement or RSA
>> whichever comes later.
> 
> 
> Opposed.
> 
> For one thing, section 8.2 transfers occur because an organization and
> its network has new ownership. The organization hasn't changed. It's
> not even necessarily a transfer, it may just be a name change. The RSA
> rules belong under section 8.3 only, which is where we thought we had
> them.
> 

Regardless I believe it should still require a standard RSA or something
as reasonably close to it as we can get.

> For another, this language is needlessly verbose. "The recipient of an
> 8.3 transfer shall sign and adhere to the same RSA as a recipient of
> number resources under NRPM section 4." Nothing more needs be said.
> 

We've been advised by staff that such a restriction will be viewed as
operational and not a policy matter and that we need to address the
specific RSA aspects that are a policy concern.

So, while I agree with you about it, the reality we are faced with is that
such a requirement has been deemed a non-policy matter by staff
and we need to do what we can within the bounds of policy.

Owen