Policy Proposal 117: Required Resource Reviews - text revised

[Member Services]

The proposal originator submitted a revised version of the proposal.

Regards,

Communications and Member Services
American Registry for Internet Numbers (ARIN)

Summary of changes:

Reworded paragraph 10(b) to bring in line with staff recommendation and 
incorporate feedback from counsel.

Removed paragraph 10(c) to incorporate feedback from counsel

Renumbered 10(d) to 10(c)

Renumbered 10(e) to 10(d)

Added new 10(e) to accommodate staff feedback requesting clarification 
that 12.2(c) does not exempt most of these reviews.

--------Revised policy text-----------

Policy Proposal 117: Required Resource Reviews

Proposal Originator: Owen DeLong

Proposal Version: 2

Date: 6 July 2010

Proposal type: new

Policy term: permanent

Policy statement:

Replace the text "under sections 4-6" in section 12, paragraph 7 with 
"under paragraphs 12.4 through 12.6"

Add to section 12 the following text:

10.    Except as provided below, resource reviews are conducted at the
discretion of the ARIN staff.  In any of the circumstances mentioned 
below, a resource review must be initiated by ARIN staff:

a.    Report or discovery of an acquisition, merger, transfer, trade or
sale in which the infrastructure and customer base of a network move 
from one organization to another organization, but, the applicable IP 
resources are not transferred. In this case, the organization retaining 
the IP resources must be reviewed. The organization receiving the 
customers may also be reviewed at the discretion of the ARIN staff.

b.    Upon receipt by ARIN of one or more credible reports of fraud or
abuse of an IP address block. Abuse shall be defined as use of the block 
in violation of the RSA or other ARIN policies and shall not extend to 
include general reports of host conduct which are not within ARIN's scope.

c.    In the case where an organization wishes to act as recipient of
resources pursuant to a transfer under section 8.3, unless otherwise 
prohibited by paragraph 12.2(c).

d.    An organization which submits a request for additional resources
when more than 25% of their existing resources are obscured in SWIP or 
RWHOIS pursuant to section 4.2.3.7.6 (residential customer privacy).

e.    Other than as specified in 12.10(c), paragraph 12.2(c) does not
exempt organizations from the reviews required under section 12.10.

Rationale:

The first change is a minor correction which improves clarity and 
consistency of the original policy without changing the meaning.

The addition of 12.10 (a) through (e) serves to create a set of 
circumstances under which a  resource review is required, rather than 
optional and entirely at ARIN staff discretion.

The majority of early comments on this proposal focused on 12.10 (e).
Mostly it was confusion about the exact ramifications. This section will 
cause ARIN to maintain greater scrutiny only in cases where a given ISP 
issues more than 25% of their total space to residential customers who 
wish to remain anonymous and receive network blocks of /29 or larger. To 
the best of my knowledge, there are not currently any ISPs which meet 
this criteria. Additionally, it would only apply that scrutiny to IPv4, 
and will not carry forward into IPv6 residential assignments.

This policy should improve the compliance verification of ARIN policies 
and may result in the improved reclamation of under-utilized IP address 
space. It should also serve as a deterrent to certain address hoarding 
tactics which have come to light in recent history.

Timetable for implementation: Immediately upon ratification by the Board