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2007-14 Previous Version

View the current policy proposal text.

The following version was archived on 25 November 2008.

Policy Proposal 2007-14
Resource Review Process

Author: Owen DeLong, Stephen Sprunk

Proposal Version: 3.3

Date: 14 October 2008

Proposal type: modify

Policy term: permanent

Policy statement:

Add the following to the NRPM:

Resource Review

1. ARIN may review the current usage of any resources maintained in the ARIN database. The organization shall cooperate with any request from ARIN for reasonable related documentation.

2. ARIN may conduct such reviews:

      a. when any new resource is requested,

      b. whenever ARIN has reason to believe that the resources were originally obtained fraudulently or in contravention of existing policy, or

      c. at any other time without having to establish cause unless a prior review has been completed in the preceding 24 months.

3. At the conclusion of a review in which ARIN has solicited information from the resource holder, ARIN shall communicate to the resource holder that the review has been concluded and what, if any, further actions are required.

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.

      4a. The degree to which an organization may remain out of compliance shall be based on the reasonable judgment of the ARIN staff and shall balance all facts known, including the organization's utilization rate,
available address pool, and other factors as appropriate so as to avoid forcing returns which will result in near-term additional requests or unnecessary route de-aggregation.

      4b. To the extent possible, entire blocks should be returned. Partial address blocks shall be returned in such a way that the portion retained will comprise a single aggregate block.

5. If the organization does not voluntarily return resources as requested, ARIN may revoke any resources issued by ARIN as required to bring the organization into overall compliance. ARIN shall follow the same guidelines for revocation that are required for voluntary return in the previous paragraph.

6. Except in cases of fraud, or violations of policy, an organization shall be given a minimum of six months to effect a return. ARIN shall negotiate a longer term with the organization if ARIN believes the organization is working in good faith to substantially restore compliance and has a valid need for additional time to renumber out of the affected blocks.

7. ARIN shall continue to provide services for the resource(s) while their return or revocation is pending, except any maintenance fees assessed during that period shall be calculated as if the return or revocation was complete.

8. This policy does not create any additional authority for ARIN to revoke legacy address space. However, the utilization of legacy resources shall be considered during a review to assess overall compliance.

9. In considering compliance with policies which allow a timeframe (such as a requirement to assign some number of prefixes within 5 years), failure to comply cannot be measured until after the timeframe specified in the applicable policy has elapsed. Blocks subject to such a policy shall be assumed in compliance with that policy until such time as the specified time since issuance has elapsed.

Delete NRPM sections 4.1.2, 4.1.3, 4.1.4

Remove the sentence "In extreme cases, existing allocations may be affected." from NRPM section 4.2.3.1.

Rationale:

Under current policy and existing RSAs, ARIN has an unlimited authority to audit or review a resource holder's utilization for compliance at any time and no requirement to communicate the results of any such review to the resource holder.

This policy attempts to balance the needs of the community and the potential for abuse of process by ARIN in a way that better clarifies the purpose, scope, and capabilities of ARIN and codifies some appropriate protections for resource holders while still preserving the ability for ARIN to address cases of fraud and abuse on an expedited basis.

The intended nature of the review is to be no more invasive than what usually happens when an organization applies for additional resources. Additionally, paragraph 2c prevents ARIN from doing excessive without-cause reviews.

The authors believe that this update addresses the majority of the feedback received from the community to date and addresses most of the concerns expressed.

The following version was archived on 14 October 2008.

Policy Proposal 2007-14
Resource Review Process

Author: Owen DeLong, Stephen Sprunk

Proposal Version: 3.2

Date: 10 October 2008

Proposal type: modify

Policy term: permanent

Policy statement:

Add the following to the NRPM:

Resource Review

1. ARIN may review the current usage of any resources issued by ARIN
to an organization. The organization shall furnish whatever records
are necessary to perform this review.

2. ARIN may conduct such reviews:

a. when any new resource is requested,
b. whenever ARIN has cause to believe that the resources had
originally been obtained fraudulently, or
c. at any other time without cause unless a prior review has been
completed in the preceding 24 months.

3. At the conclusion of a review in which ARIN has solicited
information from the resource holder,  ARIN shall communicate to the
resource holder that the review has been concluded and what, if any,
further actions are required of said resource holder.

4. Organizations shown to be substantially out of compliance with
current ARIN policy shall return resources as needed to bring them
into (or reasonably close to) compliance.

4a. The extent to which an organization may remain out of compliance
shall be based on the best judgment of the ARIN staff and shall
balance the organizations utilization rate, available address pool,
and other factors as appropriate so as to avoid forcing returns which
will result in near-term additional requests or unnecessary route de-
aggregation.

4b. To the extent possible, entire blocks should be returned. Partial
address blocks shall be returned in such a way that the portion
retained will comprise a single aggregate block.

5. If the organization does not voluntarily return resources as
required, ARIN may revoke any resources issued by ARIN as required to
bring the organization into overall compliance. ARIN shall follow the
same guidelines for revocation that are required for voluntary return
in the previous paragraph.

6. Except in cases of fraud, an organization shall be given a minimum
of six months to effect a return. ARIN shall negotiate a longer term
with the organization if ARIN believes the organization is working in
good faith to substantially restore compliance and has a valid need
for additional time to renumber out of the affected blocks.

7. ARIN shall continue to maintain the resource(s) while their return
or revocation is pending, except no new maintenance fees shall be
assessed for the resource(s).

8. This policy does not create any additional authority for ARIN to
revoke legacy address space. However, the utilization of legacy
resources shall be considered during a review to assess overall
compliance.

9. In considering compliance with policies which allow a timeframe
(such as a requirement to assign some number of prefixes within 5
years) failure to comply cannot be measured until after the timeframe
specified in the applicable policy has elapsed. Blocks subject to such
a policy shall be assumed in compliance with that policy until such
time as the specified time since issuance has elapsed.

 

Delete NRPM sections 4.1.2, 4.1.3, 4.1.4

Remove the sentence "In extreme cases, existing allocations may be
affected." from NRPM section 4.2.3.1.

Rationale:

ARIN feels that current policy does not give them the power to review
or reclaim resources except in cases of fraud, despite this being
mentioned in the Registration Services Agreement. This policy proposal
provides clear policy authority to do so, guidelines for how and under
what conditions it shall be done, and a guarantee of a (minimum) six-
month grace period so that the current user shall have time to
renumber out of any resources to be reclaimed.

The nature of the "review" is to be of the same form as is currently
done when an organization requests new resources, i.e. the
documentation required and standards should be the same.

The intent of paragraph 2c is to prevent ARIN from doing more than one
without-cause review in a 24 month period.

The renumbering period does not affect any "hold" period that ARIN may
apply after return or revocation of resources is complete.

The deleted sections/text would be redundant with the adoption of this
proposal.

Timetable for implementation: Immediate

The following version was archived on 10 October 2008.

Policy Proposal 2007-14
Resource Review Process

Author: Owen DeLong, Stephen Sprunk

Proposal Version: 3.1

Date: 6 October 2008

Proposal type: modify

Policy term: permanent

Policy statement:

Add the following to the NRPM:

Resource Review

1. ARIN may review the current usage of any resources maintained in the ARIN database. The organization shall cooperate with any request from ARIN for reasonable related documentation.

2. ARIN may conduct such reviews:

a. when any new resource is requested,

b. whenever ARIN has reason to believe that the resources were originally obtained fraudulently or in contravention of existing policy, or

c. at any other time without having to establish cause unless a prior review has been completed in the preceding 24 months.

3. ARIN shall communicate the results of the review to the organization.

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.

4a. The degree to which an organization may remain out of compliance shall be based on the reasonable judgment of the ARIN staff and shall balance all facts known, including the organization's utilization rate,
available address pool, and other factors as appropriate so as to avoid forcing returns which will result in near-term additional requests or unnecessary route de-aggregation.

4b. To the extent possible, entire blocks should be returned. Partial address blocks shall be returned in such a way that the portion retained will comprise a single aggregate block.

5. If the organization does not voluntarily return resources as requested, ARIN may revoke any resources issued by ARIN as required to bring the organization into overall compliance. ARIN shall follow the same guidelines for revocation that are required for voluntary return in the previous paragraph.

6. Except in cases of fraud, or violations of policy, an organization shall be given a minimum of six months to effect a return. ARIN shall negotiate a longer term with the organization if ARIN believes the organization is working in good faith to substantially restore compliance and has a valid need for additional time to renumber out of the affected blocks.

7. ARIN shall continue to provide services for the resource(s) while their return or revocation is pending, however, any maintenance fees assessed during that period shall be calculated as if the return or revocation was complete.

8. ARIN will not reclaim or revoke Legacy resources in active use, regardless of utilization. However, the utilization of legacy resources shall be considered during a review to assess overall compliance.

9. In considering compliance with policies which allow a timeframe (such as a requirement to assign some number of prefixes within 5 years), failure to comply cannot be measured until after the timeframe specified in the applicable policy has elapsed. Blocks subject to such a policy shall be assumed in compliance with that policy until such time as the specified time since issuance has elapsed.

Delete NRPM sections 4.1.2, 4.1.3, 4.1.4

Remove the sentence "In extreme cases, existing allocations may be affected." from NRPM section 4.2.3.1.

Rationale:

Under current policy and existing RSAs, ARIN has an unlimited authority to audit or review a resource holder's utilization for compliance at any time and no requirement to communicate the results of any such review to the resource holder.

This policy attempts to balance the needs of the community and the potential for abuse of process by ARIN in a way that better clarifies the purpose, scope, and capabilities of ARIN and codifies some appropriate protections for resource holders while still preserving the ability for ARIN to address cases of fraud and abuse on an expedited basis.

The intended nature of the review is to be no more invasive than what usually happens when an organization applies for additional resources. Additionally, paragraph 2c prevents ARIN from doing excessive without-cause reviews.

The authors believe that this update addresses the majority of the feedback received from the community to date and addresses most of the concerns expressed.

The following version was archived on 6 October 2008.

Policy Proposal 2007-14
Resource Review Process

Author: Owen DeLong, Stephen Sprunk

Proposal Version: 3.0

Date: 14 August 2008

Proposal type: modify

Policy term: permanent

Policy statement:

Add the following to the NRPM:

Resource Review

1. ARIN may review the current usage of any resources covered by an ARIN RSA within the terms of that RSA. The organization shall cooperate with any request from ARIN for reasonable related documentation.

2. ARIN may conduct such reviews:

a. when any new resource is requested,

b. whenever ARIN has reason to believe that the resources were originally obtained fraudulently, or

c. at any other time without having to establish cause unless a prior review has been completed in the preceding 24 months.

3. ARIN shall communicate the results of the review to the organization.

4. Organizations found by ARIN to be substantially 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.

4a. The extent to which an organization may remain out of compliance shall be based on the reasonable judgment of the ARIN staff and shall balance all facts known, including the organizations utilization rate,
available address pool, and other factors as appropriate so as to avoid forcing returns which will result in near-term additional requests or unnecessary route de-aggregation.

4b. To the extent possible, entire blocks should be returned. Partial address blocks shall be returned in such a way that the portion retained will comprise a single aggregate block.

5. If the organization does not voluntarily return resources as requested, ARIN may revoke any resources issued by ARIN as required to bring the organization into overall compliance. ARIN shall follow the same guidelines for revocation that are required for voluntary return in the previous paragraph.

6. Except in cases of fraud, or intentional violations of policy, an organization shall be given a minimum of six months to effect a return. ARIN shall negotiate a longer term with the organization if ARIN believes the organization is working in good faith to substantially restore compliance and has a valid need for additional time to renumber out of the affected blocks.

7. ARIN shall continue to maintain the resource(s) while their return or revocation is pending, except any maintenance fees assessed during that period shall be calculated as if the return or revocation was complete.

8. Legacy resources in active use, regardless of utilization, are not subject to revocation by ARIN. pursuant to this subsection. However, the utilization of legacy resources shall be considered during a review to assess overall compliance.

9. In considering compliance with policies which allow a timeframe (such as a requirement to assign some number of prefixes within 5 years) failure to comply cannot be measured until after the timeframe specified in the applicable policy has elapsed. Blocks subject to such a policy shall be assumed in compliance with that policy until such time as the specified time since issuance has elapsed.

Delete NRPM sections 4.1.2, 4.1.3, 4.1.4

Remove the sentence "In extreme cases, existing allocations may be affected." from NRPM section 4.2.3.1.

Rationale:

Under current policy and existing RSAs, ARIN has an unlimited authority to audit or review a resource holder's utilization for compliance at any time and no requirement to communicate the results of any such review to the resource holder.

This policy attempts to balance the needs of the community and the potential for abuse of process by ARIN in a way that better clarifies the purpose, scope, and capabilities of ARIN and codifies some appropriate protections for resource holders while still preserving the ability for ARIN to address cases of fraud and abuse on an expedited basis.

The intended nature of the review is to be no more invasive than what usually happens when an organization applies for additional resources. Additionally, paragraph 2c prevents ARIN from doing excessive without-cause reviews.

The authors believe that this update addresses the majority of the feedback received from the community to date and addresses most of the concerns expressed.

The following version was archived on 15 August 2008.

Policy Proposal 2007-14
Resource Review Process

Author: Owen DeLong, Stephen Sprunk

Proposal Version: 2.1

Date: 24 March 2008

Proposal type: modify

Policy term: permanent

Policy statement:

Add the following to the NRPM:

Resource Review

1. ARIN may review the current usage of any resources issued by ARIN to an organization. The organization shall furnish whatever records are believed to be necessary by ARIN to perform this review.

2. ARIN may conduct such reviews:

a. when any new resource is requested,
b. whenever ARIN has reason to believe that the resources were originally obtained fraudulently, or c. at any other time without having to establish cause unless a prior review has been completed in the preceding 24 months.

3. ARIN shall communicate the results of the review to the organization.

4. Organizations found by ARIN to be substantially 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.

4a. The extent to which an organization may remain out of compliance shall be based on the reasonable judgment of the ARIN staff and shall balance all facts known, including the organizations utilization rate, available address pool, and other factors as appropriate so as to avoid forcing returns which will result in near-term additional requests or unnecessary route de-aggregation.

4b. To the extent possible, entire blocks should be returned. Partial address blocks shall be returned in such a way that the portion retained will comprise a single aggregate block.

5. If the organization does not voluntarily return resources as requested, ARIN may revoke any resources issued by ARIN as required to bring the organization into overall compliance. ARIN shall follow the same guidelines for revocation that are required for voluntary return in the previous paragraph.

6. Except in cases of fraud, or intentional violations of policy, an organization shall be given a minimum of six months to effect a return. ARIN shall negotiate a longer term with the organization if ARIN believes the organization is working in good faith to substantially restore compliance and has a valid need for additional time to renumber out of the affected blocks.

7. ARIN shall continue to maintain the resource(s) while their return or revocation is pending, except no any maintenance fees assessed during that period shall be calculated as if the return or revocation was complete.

8. Legacy resources in active use, regardless of utilization, are not subject to revocation by ARIN. pursuant to this subsection. However, the utilization of legacy resources shall be considered during a review to assess overall compliance.

9. In considering compliance with policies which allow a timeframe (such as a requirement to assign some number of prefixes within 5 years) failure to comply cannot be measured until after the timeframe specified in the applicable policy has elapsed. Blocks subject to such a policy shall be assumed in compliance with that policy until such time as the specified time since issuance has elapsed.

 

Delete NRPM sections 4.1.2, 4.1.3, 4.1.4

Remove the sentence "In extreme cases, existing allocations may be affected." from NRPM section 4.2.3.1.

Rationale:

The authors have been told that current policy does not clearly give ARIN the power to review or reclaim resources except in cases of fraud, despite this being mentioned in the Registration Services Agreement. This policy proposal provides clear policy authority to do so, guidelines for how and under what conditions it shall be done, and a guarantee of a (minimum) six- month grace period so that the current user shall have time to renumber out of any resources to be reclaimed.

The nature of the "review" is to be of the same form as is currently done when an organization requests new resources, i.e. the documentation required and standards should be the same.

The intent of paragraph 2c is to prevent ARIN from doing more than one without-cause review in a 24 month period.

The renumbering period does not affect any "hold" period that ARIN may apply after return or revocation of resources is complete.

The deleted sections/text would be redundant with the adoption of this proposal.

Timetable for implementation: Immediate

 

The following version was archived on 24 March 2008.

Policy Proposal 2007-14
Resource Review Process

Author: Owen DeLong, Stephen Sprunk

Date: 21 February 2008

Proposal type: modify

Policy term: permanent

Policy statement:

Add the following to the NRPM:

Resource Review

1. ARIN may review the current usage of any resources issued by ARIN to an organization. The organization shall furnish whatever records are necessary to perform this review.

2. ARIN may conduct such reviews:

a. when any new resource is requested, b. whenever ARIN has cause to believe that the resources had originally been obtained fraudulently, or c. at any other time without cause unless a prior review has been completed in the preceding 24 months.

3. ARIN shall communicate the results of the review to the organization.

4. Organizations shown to be substantially out of compliance with current ARIN policy shall return resources as needed to bring them into (or reasonably close to) compliance.

4a. The extent to which an organization may remain out of compliance shall be based on the best judgment of the ARIN staff and shall balance the organizations utilization rate, available address pool, and other factors as appropriate so as to avoid forcing returns which will result in near-term additional requests or unnecessary route de- aggregation.

4b. To the extent possible, entire blocks should be returned. Partial address blocks shall be returned in such a way that the portion retained will comprise a single aggregate block.

5. If the organization does not voluntarily return resources as required, ARIN may revoke any resources issued by ARIN as required to bring the organization into overall compliance. ARIN shall follow the same guidelines for revocation that are required for voluntary return in the previous paragraph.

6. Except in cases of fraud, an organization shall be given a minimum of six months to effect a return. ARIN shall negotiate a longer term with the organization if ARIN believes the organization is working in good faith to substantially restore compliance and has a valid need for additional time to renumber out of the affected blocks.

7. ARIN shall continue to maintain the resource(s) while their return or revocation is pending, except no new maintenance fees shall be assessed for the resource(s).

8. Legacy resources in active use, regardless of utilization, are not subject to revocation by ARIN. However, the utilization of legacy resources shall be considered during a review to assess overall compliance.

9. In considering compliance with policies which allow a timeframe (such as a requirement to assign some number of prefixes within 5 years) failure to comply cannot be measured until after the timeframe specified in the applicable policy has elapsed. Blocks subject to such a policy shall be assumed in compliance with that policy until such time as the specified time since issuance has elapsed.

Delete NRPM sections 4.1.2, 4.1.3, 4.1.4

Remove the sentence "In extreme cases, existing allocations may be affected." from NRPM section 4.2.3.1.

 

Rationale:

ARIN feels that current policy does not give them the power to review or reclaim resources except in cases of fraud, despite this being mentioned in the Registration Services Agreement. This policy proposal provides clear policy authority to do so, guidelines for how and under what conditions it shall be done, and a guarantee of a (minimum) six- month grace period so that the current user shall have time to renumber out of any resources to be reclaimed.

The nature of the "review" is to be of the same form as is currently done when an organization requests new resources, i.e. the documentation required and standards should be the same.

The intent of paragraph 2c is to prevent ARIN from doing more than one without-cause review in a 24 month period.

The renumbering period does not affect any "hold" period that ARIN may apply after return or revocation of resources is complete.

The deleted sections/text would be redundant with the adoption of this proposal.

Timetable for implementation: Immediate

 

#####

The following version was archived on 22 February 2008.

Policy Proposal 2007-14 Resource Review Process

Author: Owen DeLong, Stephen Sprunk

Proposal type: modify

Policy term: permanent

Policy statement:

Add the following to the NRPM:

Resource Review

1. ARIN may review the current usage of any resources issued by ARIN to an organization. The organization shall furnish whatever records are necessary to perform this review.

2. ARIN may conduct such reviews:

a. when any new resource is requested, b. whenever ARIN has cause to believe that the resources had originally been obtained fraudulently, or c. at any other time without cause unless a prior review has been completed in the preceding 12 months.

3. ARIN shall communicate the results of the review to the organization.

4. If the review shows that existing usage is substantially not in compliance with current allocation and/or assignment policies, the organization shall return resources as needed to bring them substantially into compliance. If possible, only whole resources shall be returned. Partial address blocks shall be returned in such a way that the portion retained will comprise a single aggregate block.

5. If the organization does not voluntarily return resources as required, ARIN may revoke any resources issued by ARIN as required to bring the organization into overall compliance. ARIN shall follow the same guidelines for revocation that are required for voluntary return in the previous paragraph.

6. Except in cases of fraud, an organization shall be given a minimum of six months to effect a return. ARIN shall negotiate a longer term with the organization if ARIN believes the organization is working in good faith to substantially restore compliance and has a valid need for additional time to renumber out of the affected blocks.

7. ARIN shall continue to maintain the resource(s) while their return or revocation is pending, except no new maintenance fees shall be assessed for the resource(s).

8. Legacy resources in active use, regardless of utilization, are not subject to revocation by ARIN. However, the utilization of legacy resources shall be considered during a review to assess overall compliance.

Delete NRPM sections 4.1.2, 4.1.3, 4.1.4

Remove the sentence "In extreme cases, existing allocations may be affected." from NRPM section 4.2.3.1.

Rationale:

ARIN feels that current policy does not give them the power to review or reclaim resources except in cases of fraud, despite this being mentioned in the Registration Services Agreement. This policy proposal provides clear policy authority to do so, guidelines for how and under what conditions it shall be done, and a guarantee of a (minimum) six-month grace period so that the current user shall have time to renumber out of any resources to be reclaimed.

The nature of the "review" is to be of the same form as is currently done when an organization requests new resources, i.e. the documentation required and standards should be the same.

The renumbering period does not affect any "hold" period that ARIN may apply after return or revocation of resources is complete.

The deleted sections/text would be redundant with the adoption of this proposal.

Timetable for implementation: Immediate

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