[arin-ppml] Recommended Draft Policy ARIN-2014-9: Resolve Conflict Between RSA and 8.2 Utilization Requirements

[Scott Leibrand]

On Wed, Jul 23, 2014 at 2:45 PM, Andrew Dul <andrew.dul at quark.net> wrote:

>
> > On 7/23/14, 10:27 , ARIN wrote:
> > ...
> >> Recommended Draft Policy ARIN-2014-9
> >> Resolve Conflict Between RSA and 8.2 Utilization Requirements
> >>
> >> Date: 23 July 2014
> >>
> >> AC's assessment of conformance with the Principles of Internet Number
> >> Resource Policy:
> >>
> >> "This proposal enables fair and impartial number resource administration
> >> by eliminating conflicting language in the NRPM with the RSA. This
> >> proposal is technically sound. The NRPM should not contain language that
> >> conflicts with the RSA. This proposal is supported by the community.
> >> This proposal reflects current practice."
> >>
> >> Problem Statement:
> >>
> >> 8.2 transfer policy has utilization requirements at the time of the
> >> review of the transfer request.
> >>
> >> The RSA section 6 expressly forbids ARIN from de-registering blocks (in
> >> whole or in part) due to under-utilization or no-justification during
> >> transfer requests.
> >>
> >> This is a direct conflict.
> >>
> >> Policy statement:
> >>
> >> Remove the words "aggregate" and "reclaim" from 8.2, so it reads:
> >>
> >> "In the event that number resources of the combined organizations are no
> >> longer justified under ARIN policy at the time ARIN becomes aware of the
> >> transaction, through a transfer request or otherwise, ARIN will work
> >> with the resource holder(s) to return or transfer resources as needed to
> >> restore compliance via the processes outlined in current ARIN policy."
> >
>
> I do not support this draft policy as written.
>
> This current draft does not do anything substantive to fix the conflict
> in the NRPM which exists because the RSA contractually obligates ARIN
> not to reclaim address space for underutilization.


You are correct that the RSA contractually obligates ARIN not to reclaim
address space.  That is why ARIN-2014-9 removes that word ("reclaim").
Given that, I'm not sure why you say that this "doesn't do anything
substantive to fix the conflict".


> The current 8.2
> policy and this proposed draft change will still result in orphan blocks
> with incorrect stale registry information even when legitimate network
> mergers and acquisitions occur.
>

Why do you say that?  Do you feel that when organizations acquire space via
M&A, they will be afraid of ARIN working with them to voluntarily return or
transfer unneeded resources, and will instead fail to tell ARIN about the
transaction?  I understand that fear based on the current language (which
threatens reclamation), but I'm having trouble understanding how that would
remain a concern once all ARIN is directed to do is work with the resource
holder to do something voluntary.


>
> The RSA is the controlling document between an organization and ARIN,
> and the NRPM should not have policy which directly contradicts the
> contractual limitations or obligations of the RSA.
>

I do not see how the remaining language ("In the event that number
resources of the combined organizations are no longer justified under ARIN
policy at the time ARIN becomes aware of the transaction, through a
transfer request or otherwise, ARIN will work with the resource holder(s)
to return or transfer resources as needed to restore compliance via the
processes outlined in current ARIN policy.") directly (or indirectly)
contradicts the contractual limitations or obligations of the RSA.  Perhaps
you could provide more details on why you think it does?

Thanks,
Scott
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