Hello Owen
*Any* revocation must always be governed by this forum which is the only
body who has power to define allocation policies and therefore
revocation. RIRs don't have power for that, except on exceptional
situations (section 10.1) which have to be confirmed by this forum.
The RIR, based on RSA may stop providing services to organizations that
are not up to their payments, but a policy that states loud and clear
that organizations that fail to pay their fees are also subject to
revocation, reason why I see no harm to leave the text as it is.
Yes, the Board is free to modify the RSA at will, but they need to make
it coherent to the whatever the policies say, where it applies of course
(ex: Policy say that undue payments leads to resources revocation. RSA
may outline the details how the services will stop being provided until
the resources are revoked in line with this forum has the sole
prerogative to define.)
Just as a comparison and knowing that each RIR PDP may have its
differences, the essence of ICP-2 is the same, the LACNIC policy manual
clearly states in section 7 that lack payment (among other reasons) is a
reason for revocation. Beyond that which is specifically stated in the
manual it also says that "violations on contractual obligations with
LACNIC" may be a reason for revocation. In resume, that is defined by
the Policy Forum for the RIR to execute.
Fernando
On 16/01/2021 04:24, Owen DeLong wrote:
On Jan 15, 2021, at 5:14 PM, Fernando Frediani <[email protected]
<mailto:[email protected]>> wrote:
Yes to focus solely on allocation policies that means make it clear
when a revocation may happen which is governed by this forum.
Fernando,
Only my personal opinion on the subject and subject to correction from
ARIN staff:
Revocation for non-payment is _NOT_ governed by this forum. A policy
which proposed to block revocation due to non-payment or likely even
one which sought to control the manner and timing of such revocation
would very likely be considered out of scope for the PDP.
Agree that RSA can have all the possible details, but I see no harm
in keeping the text exactly as it is. Could anyone explain what sort
of trouble keeping the text there may bring any issues to ARIN on the
allocation/revocation process in place ?
Christian has already explained this to you. I will expand… Text in
the NRPM may or may not be aligned with the RSA. The text in the RSA
is controlling, but if it becomes out of sync with text in the policy
document (NRPM), it creates unnecessary confusion. The board is free
to modify the RSA at will. The NRPM is not (generally) under their
direct control and there is a precise and well defined process for
updating it which, while supervised by the board, is generally managed
by the AC and the community.
Multiple sources of truth are never a good idea… Not in systems
administration, not in network management, and certainly not in policy.
Owen
Fernando
On 15/01/2021 21:07, Chris Woodfield wrote:
The language, as is, is problematic because there’s a clear
delineation between the NRPM and ARIN’s RSA/LRSAs. The former is
intended to focus solely on allocation policies, and is a living
document subject to change via the PDP. The RSA/LRSA agreements,
however, are contracts whose language can only be modified by action
from ARIN’s Board of Trustees. Contractual language on member fees,
terms and conditions, and related topics are solely the domain of
the RSA, and as such the inclusion of language regarding fees in the
NRPM should be stricken - this language is already present in the
RSA, where it belongs.
The primary reason for this delineation, as I understand it is that
language in the RSA is necessary contractual language that ARIN must
have in order to provide the necessary income to fulfill ARIN’s
mission and responsibilities, and to protect ARIN from unnecessary
legal liabilities that may threaten that mission. While number
policy is subject to a community-driven policy development process,
the language in ARIN's RSAs, for what I hope are obvious reasons,
must be controlled far more tightly, hence the separation between
the two.
I hope this helps clarify things.
-Chris
On Jan 15, 2021, at 3:36 PM, Fernando Frediani
<[email protected] <mailto:[email protected]>> wrote:
Applies to all resources of course. If not in the appropriate place
then add it there then. But not remove something that is very obvious.
How can it deal with the issues better by removing from the text
that part that makes it clear that resources may be revoked if they
are not payed ?
Fernando
On 15/01/2021 20:33, David Farmer wrote:
Are you saying fees only apply to ISPs with IPv4, the current text
is in section 4.2.1.4, where section 4.2 applies to Allocations to
ISPs...
Furthermore, not paying fees is only one reason resources may be
revoked or reclaimed.
I think the new text is a better way to deal with the issues.
On Fri, Jan 15, 2021 at 17:09 Fernando Frediani
<[email protected] <mailto:[email protected]>> wrote:
Yes fees are most a RSA thing, but I see no harm to keep the
actual wording as it is and make it loud and clear that
organizations that don't pay the fees are subjected to
resources revocation - which is up to this forum to define -
so no one may plead ignorance about it.
What is the problem to keep it as it is ? If the newly
proposed text mentions that ISPs should take care to ensure
that their annual renewal payment is made by their anniversary
due date, what's wrong to also remind them that if that is not
fulfilled the resources may be revoked ?
This makes part of the Fair and Impartial Number Resources
Administration principle.
I see no propose in this proposal therefore I do not support it.
Regards
Fernando
On 15/01/2021 17:55, ARIN wrote:
The following Draft Policy has been revised:
* ARIN-2020-8: Clarify and Update 4.2.1.2 Annual Renewal Fee
Revised text is below and can be found at:
https://www.arin.net/participate/policy/drafts/2020_8/
<https://www.arin.net/participate/policy/drafts/2020_8/>
You are encouraged to discuss all Draft Policies on PPML. The
AC will evaluate the discussion in order to assess the
conformance of this Draft Policy with ARIN's Principles of
Internet number resource policy as stated in the Policy
Development Process (PDP). Specifically, these principles are:
* Enabling Fair and Impartial Number Resource Administration
* Technically Sound
* Supported by the Community
The PDP can be found at:
https://www.arin.net/participate/policy/pdp/
<https://www.arin.net/participate/policy/pdp/>
Draft Policies and Proposals under discussion can be found at:
https://www.arin.net/participate/policy/drafts/
<https://www.arin.net/participate/policy/drafts/>
Regards,
Sean Hopkins
Policy Analyst
American Registry for Internet Numbers (ARIN)
Draft Policy ARIN-2020-8: Clarify and Update 4.2.1.2 Annual
Renewal Fee
Problem Statement:
The January 2020 Policy Experience Report highlighted that
the existing language in Section 4.2.1.2 "Annual Renewal"
references fees. Fees are not considered a member
qualification criteria. Since fees aren't referenced
elsewhere in community policy, the wording was reviewed by
the PEG.
Policy statement:
Given that the Registration Services Agreement (RSA) already
contains language regarding fees, the AC Shepherds recommend
to eliminate 4.2.1.2. entirely and add:
2.X Registration Services Agreement (RSA)
Number resources allocated or assigned by ARIN under these
policies are subject to a contractural agreement between ARIN
and the resource holder. Throughout this document, any and
all forms of this agreement, past or future, are simply
referred to as the Registration Services Agreement (RSA).
Comments:
The AC’s understanding is that community policy should not
include language referring to fees, as such language is
already present in the Registration Services Agreement (RSA)
Registration Services has informed us that "Section 4.2.1.2.
contains language detailing fee due dates, encouraging
on-time payments, and mentions potential revocations. It also
contains a reference to web documentation that has evolved
significantly since this policy was implemented, and may
continue to do so. Essentially the entire section is made of
language that is already in the Registration Services
Agreement, and is generally fee-focused, making it outside
normal scope for Internet number resource policy."
Timetable for implementation: Immediate
Anything else:
Community input since adopting draft has informed this
direction. The 2.X placeholder is used as this seems like it
might be foundational enough to not be 2.17 but the Shepherds
would rather not upset current indexing arbitrarily.
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