[arin-ppml] Draft Proposal for Needs-Free IPv4 Transfers

Stephen Sprunk stephen at sprunk.org
Tue May 10 14:56:38 EDT 2011

On 10-May-11 13:01, Mike Burns wrote:
> OK, maybe it would be easier to modify section 12 than the RSA, but
> both would probably have to be modified.
> Any discussion about modifying 12 to remove utilization requirements
> would probably inform the ARIN staff and counsel about community
> support for revising agreements.

Considering that RSA 8 predates NRPM 12 by a decade or so, I'm not sure
about that.

However, just modifying policy should be enough to get the effect you're
looking for.  The very reason I proposed (the text that became) NRPM 12
is that ARIN rejected my ACSP suggestion to enforce RSA 8, based on a
lack of activating policy.  If NRPM 12 went away, or were weakened in
the way you propose, presumably they'd go back to that position.

Also, ARIN still hasn't implemented NRPM 12.2(c) as intended, so I fail
to see why you think this matter is so urgent.

> ... could my resources be reviewed and revoked per NRPM section 12
> without recourse to the RSA section 8?

RSA 8 and NRPM 12 work together; neither has teeth without the other.

It has been argued (by me and others) that RSA 8 /could/ be used without
NRPM 12, and therefore NRPM 12 only serves to /limit/ how RSA 8 can be
used, but to date that hasn't been ARIN's interpretation.

It's been a while since I've read the LRSA, but AFAIK there is nothing
there for NRPM 12 to activate, and that absence is where the special
status comes from.

> My reading of it says no, section 12 does not give ARIN the right to
> request a return for under-utilization only.
> I think this is the salient section, 12.4:
> "Organizations found by ARIN to be materially out of compliance with
> current ARIN policy shall be requested or required to return resources
> as needed to bring them into (or reasonably close to) compliance."
> In my example, what current ARIN policy would I be materially out of
> compliance with?
> ARIN policy talks quite a bit about utilization, but always in the
> context of a new allocation, not the utilization of a prior allocation
> outside that context.

Resources are justified based on current and/or projected utilization. 
If that utilization disappears or fails to materialize, respectively,
then the registrant is no longer compliant.

> If I were allocated a /18 in 2002 order to host websites, and I have
> sold or lost the customers but retain the corporation, ...

You were allocated that /18 under a specific policy provision, which
requires certain current and projected utilization.  If you no longer
meet those requirements, then your /18--or a portion of it--can be revoked.

If anyone doesn't think this is clear enough from the text, please let
me know how it could be improved and I'll submit a proposal to clarify
the intent.


Stephen Sprunk         "God does not play dice."  --Albert Einstein
CCIE #3723         "God is an inveterate gambler, and He throws the
K5SSS        dice at every possible opportunity." --Stephen Hawking

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