Proposed Revision - ARIN Policy Development Process
This is a proposed revision of the ARIN Policy Development Process posted for consultation from 29 October, 2012 to 30 November, 2012. This proposed revision differs from the version posted for consultation from 29 May, 2012 to 28 June 2012. Please see the ARIN Policy Development Process page for the current version.
PART ONE – ARIN POLICY DEVELOPMENT PROCESS GOALS
This document describes the ARIN Policy Development Process (PDP). The ARIN PDP is the process by which policies for the management of Internet number resources in the ARIN region are developed by the community. These Internet number resource policies are developed in an open, transparent, and inclusive manner that allows anyone to participate in the process.
The Policy Development Process encourages community participation, including allowing anyone to submit proposals for changes to number resource policy. The PDP is designed to bring forth clear, technically sound and useful policies for ARIN to use in the management and administration of Internet number resources. To accomplish this goal, the PDP charges the member-elected ARIN Advisory Council (AC) as the primary facilitators of the policy development process with appropriate checks and balances on its performance in that role.
Part One of this document provides the underlying goals for the Policy Development Process (including its purpose, scope, principles, and criteria for policy changes) and Part Two details the specific Policy Development Process used for development of changes to Internet number resource policy. Part Three details the processes for petitioning specific aspects of the Policy Development Process.
- Internet Number Resources
- Internet number resources consist of Internet Protocol version 4 (IPv4) address space, Internet Protocol version 6 (IPv6) address space, and Autonomous System (AS) numbers.
- Policy Proposal
- An idea for a policy that is submitted to the Policy Development Process. Members of the ARIN Advisory Council and ARIN staff work with the originator to refine the Policy Proposal so that it contains a clear statement of the existing problem with Internet number resource policy and suggested changes to Internet number resource policy text to address the problem. In cooperation with ARIN staff, the Advisory Council also confirms each Policy Proposal is within scope (per Section 3) of the PDP.
- Draft Policy
- A Policy Proposal that is complete and in scope for the PDP is accepted by the Advisory Council and becomes a Draft Policy.
The Advisory Council further develops the Draft Policy, working in cooperation with the policy originator if available. A Draft Policy, once fully developed, consists of a clear problem statement, proposed changes to number resource policy text, and an assessment of the conformance of the Draft Policy to ARIN's Principles of Internet Number Resource Policy (as specified in Part One, Section 4 of the PDP).
- Recommended Draft Policy
- A Recommended Draft Policy is the result of a Draft Policy being fully developed (containing clear problem statement, proposed changes to policy text, and an assessment of conformance to the PDP principles) and then being recommended for adoption by action of the ARIN Advisory Council. A Draft Policy becomes a Recommended Draft Policy once the Advisory Council believes with a high likelihood that the Draft Policy satisfies ARIN's Principles of Internet Number Resource Policy. Recommended Draft Policies must undergo community consultation and a "Last Call" period before being considered for adoption.
- Adopted Policy
- A policy that has been adopted by the ARIN Board of Trustees. Adopted Policies are incorporated into ARIN's Number Resource Policy Manual (NRPM) as of their effective date.
- Public Policy Mailing List (PPML)
- The ARIN public mailing list for discussion of Internet number resource policy.
- Public Policy Consultation (PPC)
- An open public discussion held by ARIN of Internet number resource policy that provides for the contemporaneous interaction and polling of in-person and remote participants. These consultations may be held at ARIN's Public Policy Meetings and at other related forums as approved by the ARIN Board of Trustees.
- Public Policy Meeting (PPM)
- A public forum held periodically by ARIN that includes Public Policy Consultations of all Draft and Recommended Draft Policies. Public Policy Meetings are held at least annually, although Public Policy Consultations for selected Draft or Recommended Draft Policies may be held in between Public Policy Meetings in similar open forums.
- An action initiated by any member of the community (including a proposal originator) if they are dissatisfied with the action taken by the Advisory Council regarding a specific Policy Proposal, Draft Policy or Recommended Draft Policy.
3. Scope of Internet Number Resource Policies
3.1. Policies, not Processes, Fees, or Services
Internet number resource policies developed through the PDP describe the policies and guidelines to be followed in number resource management, not the procedures that ARIN staff will use to implement the policies. ARIN staff develops appropriate procedures to implement policies after they are adopted.
Internet number resource policies are also distinctly separate from ARIN general business practices. ARIN's general business processes, fees, and services are not within the purview of the Policy Development Process, and while policies developed through the PDP may apply to ARIN's service offering, they cannot define or establish ARIN fees or service offerings. All matters concerning fees and service offerings are part of the fiduciary responsibility of the Board of Trustees. Note that the ARIN Consultation and Suggestion Process (ARIN ACSP) may be used to propose changes in non-policy areas.
Changes to policy that are purely editorial and non-substantial in nature are outside the scope of the full Policy Development Process and may only be made with 30 days public notice followed by the concurrence of both the ARIN Advisory Council and ARIN Board of Trustees that the changes are non-substantial in nature.
3.2. Relevant and Applicable within the ARIN Region
Policies developed through the PDP are community self-regulatory statements that govern ARIN's actions in the management of Internet number resources. Policy statements must be applicable to some portion of the community for number resources managed within the ARIN region, and proposals to change policy must address a clearly defined, existing or potential problem with number resource policy in the region.
Note that the Policy Development Process for global policies follows a similar process within each RIR region with the additional process of ratification by the Internet Corporation for Assigned Names and Numbers (ICANN). The Global Policy Development Process is separately documented and facilitated by the Address Supporting Organization Address Council (ASO AC), and in these circumstances, the ARIN PDP is also used in the development of number resource policies with global applicability.
4. Principles of Internet Number Resource Policy
Internet number resource policy must satisfy three important principles, specifically: 1) enabling fair and impartial number resource administration, 2) technically sound (providing for uniqueness and usability of number resources), and 3) supported by the community.
4.1. Enabling Fair and Impartial Number Resource Administration
Internet number resources must be managed with appropriate stewardship and care. Internet number resource policy must provide for fair and impartial management of resources according to unambiguous guidelines and criteria. All policy statements must be clear, complete, and concise, and any criteria that are defined in policy must be simple and obtainable. Policy statements must be unambiguous and not subject to varying degrees of interpretation.
4.2. Technically Sound
Policies for Internet number resource management must be evaluated for soundness against three overarching technical requirements: conservation, aggregation, and registration. More specifically, policies for managing Internet number resources must:
- Support both conservation and efficient utilization of Internet number resources to the extent feasible. Policy should maximize number resource availability to parties with operational need.
- Support the aggregation of Internet number resources in a hierarchical manner to the extent feasible. Policy should permit the routing scalability that is necessary for continued Internet growth. (Note that neither ARIN, nor its policies, can guarantee routability of any particular Internet number resource as that is dependent on the actions of the individual Internet operators.)
- Support the unique registration of Internet number resources. Policy should prevent to the extent feasible any unknown or duplicate use of Internet number resources that could disrupt Internet communications.
Policies must achieve a technically sound balance of these requirements, and support for these technical requirements must be documented in the assessment of the policy change.
4.3. Supported by the Community
Changes to policy must be shown to have a strong level of support in the community in order to be adopted. The determination of support for the policy change is done by polling the community for support during a Public Policy Consultation (PPC).
The Policy Development Process, as a consensus-based collaborative development process, encourages incorporation of feedback received from participants where possible with the goal of increasing community support for policy changes.
A strong level of community support for a policy change does not mean unanimous; it may be demonstrated by a subset of the community, as long as the policy change enjoys substantially more support than opposition in the community active in the discussion.
5. ARIN Board of Trustees Criteria for Policy Changes
In order to maintain fidelity to the duty performed by ARIN on behalf of the Internet community, changes to Internet number resource policy must meet two specific criteria before being adopted by the ARIN Board of Trustees: 1) in compliance with law and ARIN's mission, and 2) developed via open and transparent processes.
5.1. In Compliance with Law and ARIN's Mission
Policies developed through the PDP must advance ARIN's mission, not create unreasonable fiduciary or liability risk, and must be consistent with ARIN's Articles of Incorporation, Bylaws, and all applicable laws and regulations.
5.2. 5.2. Developed by Open, Transparent, and Inclusive Processes
Changes to policy must be developed via open and transparent processes that provide for participation by all. Policies must be considered in an open, publicly accessible forum as part of the adoption process. Policy discussions in the ARIN region are conducted on the Public Policy Mail List (PPML) and via Public Policy Consultation (PPC). There are no requirements for participation other than adherence to the guidelines of behavior and decorum, and anyone interested in following the process may subscribe to the PPML or may participate without charge in Public Policy Consultations via in person or remote participation methods.
All aspects of the PDP are documented and publicly available via the ARIN website. The PPML is archived. The proceedings of each PPM are published. All policies are documented in the Number Resource Policy Manual (NRPM). All Draft Policies are cross referenced to the original Policy Proposal, the archives of the PPML, all related PPC proceedings, and the minutes of the appropriate Advisory Council and the ARIN Board of Trustees meetings. The procedures that are developed to implement the policy are documented, publicly available, and followed by the ARIN staff.
The Policy Development Process itself may only be changed by the ARIN Board of Trustees after a public consultation period to consider the proposed changes.
Part Two – The Policy Development Process
This section provides the details of the ARIN Policy Development Process. A graphical flow depiction of the process is provided at Appendix A. All references to "days" are calendar days.
All ARIN Advisory Council (AC) decisions on policy matters require an affirmative roll call vote of the majority of the members of the full AC, unless otherwise specified.
1. The Policy Proposal
Policy Proposals may be submitted to the ARIN Policy Development Process (PDP) by anyone in the global Internet community except for members of the ARIN Board of Trustees or the ARIN staff. Policy Proposals may be submitted any time by sending them to email@example.com. Upon receipt of a new Policy Proposal, the ARIN staff assigns it a Policy Proposal number, posts the Policy Proposal to the public web site, and notifies the AC of a new Policy Proposal available for consideration. The AC designates one or more members to work with the policy originator as needed. The assigned AC members and ARIN staff will work with the originator as described below to prepare the Policy Proposal for evaluation by the AC.
The assigned members of the AC work with the proposal originator by providing feedback regarding the clarity and understanding of the Policy Proposal. The merits of the Policy Proposal itself are not considered at this time; the Policy Proposal is revised as needed so that it contains a clear statement of the problem with existing Internet number resource policy, that any suggested changes to Internet number resource policy text are understandable to the ARIN staff and community, and to identify and correct any potential scope considerations of the Policy Proposal.
The proposal originator may revise (or not) the Policy Proposal based on the feedback received. Once the originator and assigned members of the AC are satisfied with the scope and clarity of the Policy Proposal, it is evaluated by the AC.
2. Policy Proposal Evaluation
During Policy Proposal evaluation, the Advisory Council does not evaluate the merits of Policy Proposal other than to confirm that the Policy Proposal is within scope of the Policy Development Process and contains a clear statement of the problem and suggested changes to number resource policy text. Upon submission to the AC, each Policy Proposal is evaluated in a timely manner to determine if the Policy Proposal is within scope of the Policy Development Process. Policy Proposals that are determined by the AC to be out of scope (e.g. for not addressing a clearly defined existing or expected problem, or that propose solutions involving other than number resource policy in the region) are rejected at this point, and the AC announces the rejection of a Policy Proposal along with an explanation of its reasoning on the ARIN Public Policy Mailing List (PPML).
The AC also evaluates whether the Policy Proposal contains a clear statement of the existing problem with Internet number resource policy including suggested changes to number resource policy text to address the problem. Once this has been confirmed, the AC accepts it as a Draft Policy for further development work with the community. The AC announces the acceptance of a Policy Proposal as a Draft Policy on the PPML and encourages community discussion of its merits and concerns.
Policy Proposals that are determined by the AC to lack clarity are remanded back to the originator along with an explanation of the areas needing improvements in clarity. The proposal originator revises the Policy Proposal based on the feedback received, and again offers the revised Policy Proposal for evaluation by the AC.
The AC maintains a docket of all Policy Proposals. A submitted Policy Proposal that is not rejected upon evaluation as being out of scope remains on the docket as a Policy Proposal until it is withdrawn by the originator or accepted by the Advisory Council as a Draft Policy. Remanded Policy Proposals that are not revised by the originator within 60 days are deemed abandoned. Policy Proposals that have not been accepted as a Draft Policy after 60 days may be petitioned to Draft Policy status. Refer to PDP Part Three: Petition Process for a list of petitionable policy actions.
3. Draft Policy Discussion and Development
The Advisory Council is responsible for the development of policies to meet ARIN's Principles of Internet Number Resource Policy (as described in Part One, Section 4). The Advisory Council maintains a docket of all Draft Policies.
As part of the policy development effort, the AC participates in and encourages the discussion of the Draft Policies on the PPML, notes the merits and concerns raised, and then based on its understanding of the relevant issues, the Advisory Council may take various actions including abandoning, revising or merging the Draft Policy with other Draft Policies. To the extent that the policy originators are available and responsive, the AC includes them in the revision process.
The AC may submit a Draft Policy at any time for a combined staff and legal review (and should do so after significant revisions to a Draft Policy). This review will be completed within 14 days. Upon receipt of the staff and legal review comments, the AC examines the comments to ensure their understanding and resolve any issues that may have been raised.
The AC announces any actions taken on Draft Policies along with an explanation of its reasoning on the PPML.
4. Recommendation of Draft Policies
The Advisory Council develops and refines Draft Policies until they are satisfied that the Draft Policy meets ARIN's Principles of Internet Number Resource Policy (Part One, Section 4). Specifically, these principles are:
- Enabling Fair and Impartial Number Resource Administration
- Technically Sound
- Supported by the Community
Guided by the discussion of the Draft Policy on the PPML, Public Policy Consultations with the community (if any) and its best judgment, the AC assesses the conformance of each Draft Policy to these principles and documents the result in an assessment section within the Draft Policy. Any specific concerns expressed by a significant portion of the community must be explicitly noted and addressed in the assessment of the policy change.
Once a Draft Policy is fully developed and the AC is satisfied that it meets the principles of Internet number resource policy (including the support of the community based on online discussion that has occurred thus far), the AC recommends the Draft Policy for adoption. Recommended Draft Policies must undergo Public Policy Consultation with the community before proceeding to Last Call and being sent for consideration by the ARIN Board of Trustees.
5. Community Consultation and Public Policy Meetings
ARIN holds periodic Public Policy Meetings (PPM) where the Advisory Council reports on the status of all Draft Policies and Recommended Draft Policies on its docket for discussion and feedback from the community. The presentation and discussion is referred to as a "Public Policy Consultation." Recommended Draft Policies may not be changed in the 30 days prior to its Public Policy Consultation.
As each Draft and Recommended Draft Policy is presented for Public Policy Consultation, members of the AC will provide the arguments for and against adoption (petitioned items are handled per PDP Part Three: Petition Process). The AC participates in the discussion during the Public Policy Consultation, and notes significant merits and concerns that were raised in the discussion for inclusion in the policy assessment. Based on the feedback received and its best judgment, the AC revises the Draft Policy to address concerns raised where it will improve the overall community support for the policy change.
Within the 60 days following a Public Policy Consultation on a Recommended Draft Policy, the AC reviews the result of the discussion (including any polls of support) and decides the appropriate next action.
6. Confirming Community Support for Recommended Draft Policies
The Advisory Council confirms community support for Recommended Draft Policies, and this is done by polling community support for the policy change during a Public Policy Consultation.
The AC should carefully weigh the community support shown for a Recommended Draft Policy. Absence of clear community support is a strong indication that policy abandonment should be considered. A low level of overall support without opposition for a Recommended Draft Policy suggests further discussion of the merits of the policy change or abandonment. A clear split in the community support suggests that the AC should revise the Recommended Draft Policy to accommodate the concerns raised or further explain its consideration of the matter.
A Recommended Draft Policy that has demonstrated clear support (and only relatively low opposition for well-understood reasons) may be advanced to Last Call by the AC within 60 days of its Public Policy Consultation.
All Recommended Draft Policies not advanced to Last Call within 60 days of completion of their Public Policy Consultation will revert to Draft Policy status.
7. Last Call
The Advisory Council advances Recommended Draft Policies with clear support to Last Call. Last Call provides an opportunity for final review by the community via discussion on the PPML. The last call period will be for a minimum of 14 days. The AC may decide that certain Recommended Draft Policies require a longer last call period of review (such as those that were revised based on comments received during Public Policy Consultation). If the AC sends a Recommended Draft Policy different than the
Recommended Draft Policy presented during the Public Policy Consultation, then the Advisory Council will provide a detailed explanation for all changes to the text and these specific changes must have been discussed during the community consultation.
The AC will review the results of the Last Call discussion, and will determine if they still recommend adoption by the ARIN Board of Trustees. The AC may make minor editorial changes to a Recommended Draft Policy and reissue it for Last Call. No other changes may be made while the policy is in Last Call.
A Recommended Draft Policy that has undergone a successful Last Call discussion may be sent to the ARIN Board of Trustees for adoption consideration. Decisions to send Recommended Draft Policies to the ARIN Board shall be made by the affirmative roll call vote of the two thirds of the members of the full Advisory Council. The results of the AC's decisions, and the reasons for them, are announced on the PPML.
All recommended policies not sent to the ARIN Board of Trustees for consideration within 60 days of Last Call completion will revert to Draft Policy status.
8. Board of Trustees Review
The ARIN Board of Trustees evaluates a Recommended Draft Policy for adoption once it is received from the Advisory Council. In its review, the Board of Trustees evaluates the policy with respect to the Policy Development Goals of the PDP including specifically whether the ARIN Policy Development Process has been followed, and whether the policy is in compliance with law and ARIN's mission.
The Board of Trustees may adopt, reject or remand Recommended Draft Policies to the AC. All rejections will include an explanation. Remands will explain the need for further development. The Board of Trustees may also seek clarification from the AC without remanding the recommended policy. The results of the Board of Trustees' decision are announced on the ARIN Public Policy Mailing List (PPML).
The projected implementation date of the policy is announced at the time that adoption of the policy is announced. ARIN staff implements the policy and publishes an updated Number Resource Policy Manual (NRPM) that incorporates the adopted policy and which is identified by a new version number.
10. Special Policy Actions
10.1 Emergency PDP
If urgently necessary pursuant to ARIN’s mission, the Board of Trustees may initiate policy by declaring an emergency and posting a Recommended Draft Policy on the PPML for discussion for a minimum of 14 days. The Advisory Council will review the Recommended Draft Policy within 7 days of the end of the discussion period and make a recommendation to the Board of Trustees. If the Board of Trustees adopts the policy, it will be presented at the next Public Policy Meeting for reconsideration.
10.2 Policy Suspension
If, after a policy has been adopted, the Board receives credible information that a policy is flawed in such a way that it may cause significant problems if it continues to be followed, the Board of Trustees may suspend the policy and request a recommendation from the AC on how to proceed. The recommendation of the AC will be published for discussion on the PPML for a period of at least 14 days. The Board of Trustees will review the AC's recommendation and the PPML discussion. If suspended, the policy will be presented at the next scheduled Public Policy Meeting in accordance with the procedures outlined in this document.
PART THREE – PDP PETITION PROCESS
This section provides the details of the petitions within the Policy Development Process. Petitions can be made at points where decisions are made in the policy process. Points where petitions are available are depicted on the main PDP flow diagram in Appendix A. All "days" in the process below are calendar days.
1. Petition Principles
1.1. Available to the community
Any member of the community may initiate a petition if they are dissatisfied with a specific action taken by the ARIN Advisory Council (AC) regarding a Policy Proposal, Draft Policy or Recommended Draft Policy. The petitioner does not have to be located in the ARIN region or associated with an organization that is a Member of ARIN; any party (including a Policy Proposal originator) with interest in policy development matters within the ARIN region may initiate a petition.
Notwithstanding the above, ARIN Staff and ARIN Board of Trustees members may not initiate or be counted in support of petitions as these individuals already have a formally defined role in the Policy Development Process.
1.2. Petition Initiation and Process
A petition may be initiated by sending an email message to the ARIN Public Policy Mailing List (PPML) clearly requesting a petition against a specific action as listed below and including a statement to the community on why the petition is warranted. ARIN Staff will confirm the validity of the petition and then announce the start of the petition period on the PPML mailing list.
Until the close of the petition period, members of the community (as allowed to petition per 1.1 above) may be counted in support for an existing petition by sending an email message to the PPML clearly stating their support for the petition. Only one petition will be considered for a given policy action; all subsequent requests to petition for the same action within the petition period shall be considered as support for the original petition.
The petition shall remain open for 5 days, at which time the ARIN Staff shall determine if the petition succeeds (a successful petition requires expressions of petition support from at least 10 different people from 10 different organizations unless otherwise specified.) A successful petition will result in a change of status for the Policy Proposal or Draft Policy as specified below.
Staff and legal reviews will be conducted and published for Draft Policies that result from successful petitions.
Successfully petitioned Draft Policies are presented for community consideration at the next Public Policy Meeting (or at an earlier scheduled Public Policy Consultation if desired) by an individual chosen by the petition supporters, with preference given to the proposal originator. If consensus is not achieved in determining the presenter, then the President may facilitate the selection process.
Petitions may be made regarding specific actions against Policy Proposals, Draft Policies, and Recommended Draft Policies as described below.
2.1. Petition against Abandonment, Delay, or Rejection due to Scope
The Advisory Council's decision to abandon a Policy Proposal, Draft Policy or Recommended Draft Policy may be petitioned.
Petitions may be initiated within the 5 days following the announcement date of an Advisory Council abandonment of a specific Policy Proposal or any Draft Policy. For sake of clarity, the "announcement date" of an action shall be the publication date of the action in the ARIN AC draft minutes. Additionally, Policy Proposals that have not been accepted as a Draft Policy after 60 days may also be petitioned to Draft Policy status at anytime.
For a Policy Proposal that has been rejected due to being out of scope of the PDP, a successful petition will refer the question of whether the Policy Proposal is in scope to the ARIN Board of Trustees for consideration.
For all other petitions against abandonment or delay, a successful petition will result in the Draft Policy being placed back on the Advisory Council docket under control of the petitioner and scheduled for public policy consultation at the next PPM. After the public consultation, control returns to the Advisory Council and subsequently may be revised or abandoned per the normal Policy Development Process.
2.2. Petition for Recommended Status
Any member of the community may initiate a Petition for Recommended Status if they believe that a Draft Policy (either the original version as proposed or the current version) is fully developed to meet the requirements of Recommended Draft Policy, and the Advisory Council has not advanced the Draft Policy to Recommended Draft Policy status after 90 days as a Draft Policy.
A successful petition for Recommended Status requires expressions of petition support from at least 15 different people from 15 different organizations. If successful, the petition will result in the Draft Policy being put under control of the petitioner, advanced to Recommended Draft status, and scheduled for public policy consultation at the next PPM. The resulting Recommended Draft Policy shall be under control of the Advisory Council after the public policy consultation and subsequently may be revised or abandoned per the normal Policy Development Process.
2.3. Petition for Last Call
Any member of the community may initiate a Last Call Petition if they are dissatisfied with the Advisory Council's failure to act within the allotted time (60 days) to advance a Recommended Draft Policy as presented during public policy consultation to last call. A successful Petition for Last Call requires expressions of petition support from at least 20 different people from 20 different organizations. If successful, the petition will move the Recommended Draft Policy as presented during its Public Policy Consultation to last call discussion and review by the community on the PPML. The Recommended Draft Policy shall be under the control of the Advisory Council after Last Call.
2.4. Petition for Board of Trustees Consideration
Any member of the community may initiate a Board of Trustees Consideration Petition if they are dissatisfied with the Advisory Council's failure to act within the allotted time (60 days) to send a Recommended Draft Policy in last call to the Board of Trustees for consideration. A successful petition for Board of Trustees Consideration requires expressions of petition support from at least 25 different people from 25 different organizations. If successful, this petition will send the Recommended Draft Policy from last call to the Board of Trustees for consideration.