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Draft Policies and Proposals

Recommended Draft Policy ARIN-2014-9: Resolve Conflict Between RSA and 8.2 Utilization Requirements
Status:

Implemented 24 February 2015

 
Discussion Tracking
Mailing List:
Formal introduction on PPML on 4 March 2014

Origin - ARIN-prop-199

Draft Policy - 4 March 2014

Revised - 16 May 2014

Recommended Draft Policy - 23 July 2014

Last Call - 15-29 October 2014

AC recommend Board adopt - 25 November 2014

Implemented - 24 February 2015

 

 

Public Policy Mailing List
ARIN Public Policy Meeting:

ARIN PPC At NANOG 60

ARIN 33

ARIN PPC at NANOG 61

ARIN PPC at NANOG 62

ARIN 34

ARIN Advisory Council:

AC Shepherds:
Heather Schiller, Scott Leibrand

ARIN Board of Trustees: 12 January 2015
Revisions Implementation
Implemented 24 February 2015

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."

Comments:

a.Timetable for implementation: Immediate

b.Anything else:

#####

Staff Assessment

Date of Assessment: 01 July 2014

1. Summary (Staff Understanding)

This proposal would revise NRPM 8.2 “Mergers and Acquisitions” by removing aggregation and reclamation of resources as a method to restore compliance with current policy.

2. Comments

A. ARIN Staff Comments

Removing the aggregation terminology from the policy is appropriate given the retirement of the aggregation policy language elsewhere in the NRPM.

Removing the reclamation terminology from the policy may encourage more people to complete 8.2 transfers because the reclamation aspect is no longer part of the policy.

Staff frequently sees cases where organizations are transferring resources that are not being utilized and lack a clear plan to utilize or transfer them in the future. This is a dilemma that exists today and will continue to exist with the revised policy. Staff will encourage such organizations to make use of their resources, work with staff to voluntarily return unused resources to ARIN, or transfer them to parties who need them.

The problem statement does not specify which version and date of the RSA [section 6]. This is a reconciliation issue between policy and RSA and therefore staff interprets this proposal as pertaining to current RSA version 11.0 (2012-04-20) [section 6].

B. ARIN General Counsel - Legal Assessment

This proposal does not appear to pose any material legal issues.

3. Resource Impact

This policy would have minimal resource impact from an implementation aspect. It is estimated that implementation would occur within 3 months after ratification by the ARIN Board of Trustees. The following would be needed in order to implement:

· Updated guidelines and internal procedures
· Staff training

4. Proposal/Draft Policy Text Assessed

Draft Policy ARIN-2014-9 Resolve Conflict Between RSA and 8.2 Utilization Requirements
Revised: 16 May 2014

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."

 

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