[arin-ppml] ARIN-prop-145 STLS Listing Immunity

Jimmy Hess mysidia at gmail.com
Tue May 17 19:41:26 EDT 2011

On Mon, May 2, 2011 at 12:59 PM, ARIN <info at arin.net> wrote:
> ARIN may not revoke any resources issued by ARIN that are presently
> listed as "available" on the ARIN Specified Transfer Listing Service
> unless there is sufficient reason to believe that the holder does not in
> fact intend to transfer these resources.

I am opposed  to ARIN giving resource holders an unlimited pass on
policy and efficient utilization,
just because they have resources listed in the STLS or anywhere else.

This could encourage an organization to apply for resources they don't need,
and list those resources in the STLS,  to protect those resources from
even if there are other reasons for a review of the allocation.

They could list on the STLS,  and demand unreasonably high
consideration to effect transfer,
so no one wants to deal with them; then they can abuse STLS to
maintain permanent immunity...

I suggest instead a  12 month 'grace period'/waiver  for resource
holders who can show that they
_were_  utilizing IP resources efficiently,   on the date they apply
for the grace period,
but have decided to  go through the trouble of renumbering or ceasing
use of some address space
in order to release it or transfer it;  extendable to 24 months.

Providing they fill out some form, submit it to ARIN,  and pay a fee
similar to the STLS fee.
e.g.  "Statement of intent to renumber and transfer/return resources"
They will need to identify which resources they intend to transfer.

The resources must still be efficiently used as of the date of the application.

I suggest that if  they file that form, and have not performed some action that
requires ARIN to review their resources ,  and ARIN has not already
started a review
or inquiry into their resources in suspicion of fraud or error, they
receive a grace period
against future resource reviews, with regards to their change in
utilization _after_ the
date they completed the form,

On the condition they maintain their account in good standing with
ARIN for the duration
of the waiver and do not apply for or receive additional number
resources of the same type.

ARIN will treat their utilization of that block (for any review purposes),  as
the same as the utilization on the date the form was filed.

If the allocation was properly utilized on the date the form was submitted, then
the resources will not be subject to revokation until the waiver period lapses.

If they choose not to file the form,  then their resources might be
reviewed as normal,
and STLS listing might contribute to ARIN's reasoning.

Other types of resources, and other allocations not intended to be
returned still
subject to resource review.

If the filed the intent, but have not transferred the resources within
the waiver period,
have not received an extension, then ARIN may consider a resource review based
on failure to transfer,  or  ARIN may ask them to explain why they
have withdrawn
from their intent to release resources.


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