[arin-ppml] An article of interest to the community....

[Scott Leibrand]

We already have a policy proposal on the table to add "or transfer" to NRPM
12 to clarify that transfers are an acceptable way to get back into
compliance.  In addition, NRPM 12.6 already reads "Except in cases of fraud,
or violations of policy, an organization shall be given a minimum of six
months to effect a return."

What additional protections do you feel are needed? I'll be happy to help
put them into policy language for submission to policy at arin.net if you'd
like.

Thanks,
Scott

On Sep 2, 2011, at 12:25 AM, Matthew Kaufman <matthew at matthew.at> wrote:

On 9/2/11 6:16 AM, Owen DeLong wrote:

On Sep 1, 2011, at 7:14 PM, Brett Frankenberger wrote:


On Thu, Sep 01, 2011 at 06:38:44PM -0700, Owen DeLong wrote:

Mike,

  What risk do you see in listing un/under-utilized resources that is

not present in merely holding those resources?

Can't say for sure, but I'd guess it's comparable to the risk that

exists in taking out a full page add in the local newspaper announcing

"I will drive 80 in the 60 MPH speed zone at milepost X on highway Y at

XX:XX on XX/XX/2001" that isn't present in driving 80 in a 60 but not

advertising when and where you will be doing it.


Except that it would be more like doing that after the chief of police and

the commandant of the highway patrol had told you that making such

an announcement in and of itself would not cause them to pursue you.


No, it is more like taking out an ad that says "I drive 80 MPH in the 60 MPH
speed zone at milepost X on highway Y every day at 9 AM" after being told
that making such an announcement was ok and hoping that the chief of police
and the commandant of the highway patrol are never replaced with people who
noticed your ad.


The reason we change laws instead of just hoping the enforcers will just be
fair despite what the language says is precisely because the enforcers
change their minds and/or are retire and are replaced.



If your resources are underutilized, ARIN *could* do a section 12 audit

and initiate reclamation.  If you don't tell anyone that you are

underutilized, ARIN won't know, so they only way you'd get hit with an

audit is if you got really unlucky.  If you tell the world (by putting

them up for auction), the risks get higher, because ARIN knows (or at

least has a strong indication) that you are underutilized.


In spite of John's claims to the contrary, I actually believe that ARIN
should

begin performing random reviews as time permits and should certainly

be looking for resources that appear to have a pattern of un/under-

utilization.


And this is even worse. We have members of the community saying "I know
you've said that you're not going to be enforcing the speed limit for these
flagrant violators, but I'd like you to start doing so".



ARIN hasn't made a practice of doing that, and I agree with John's

statement that they aren't likely to start doing that.  But if they

don't know you are underutilized, your risk is lower than if they do

know and you're relying on them to nevertheless refrain from an audit.

In my view, the risk is very low either way.  But it is lower if ARIN

doesn't have the information, and some companies are going to play it

safe.


John's statement wasn't that they aren't likely to start doing so. John's

statement was that he did not feel that they should start doing so.

John and I disagree in this area and I think at the end of the day

as scarcity becomes more of an issue, there will be more pressure

from the community to change John's position on this. John answers

to the board. The board answers to the members.


And so the members have a legitimate reason to have the policy changed,
rather than simply relying on John's word as to what he would choose to do
this week as an indication of how policy will always be interpreted.


Matthew Kaufman

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