[ARIN-Suggestions] Response to Suggestion 2012.13 - CUSTOMER IDENTITY NOT REQUIRED ON /29 AND SMALLER REASSIGNMENTS [CLOSED]

[ARIN]

ARIN has issued its initial response to ACSP Suggestion 2012.13. The 
suggestion and response text are provided below. This suggestion is now 
closed and is available at:

https://www.arin.net/participate/acsp/suggestions/2012-13.html

Regards,

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

****
Suggestion: *

Where ARIN must evaluate a LIR's IPv4 address utilization in order to 
perform any duty, ARIN should not compel the production of customer 
identities for any customer holding a total of less than 8 IPv4 
addresses unless all reasonable alternatives for verifying utilization 
have been exhausted.
(credit: Bill Herrin, 
http://lists.arin.net/pipermail/arin-ppml/2012-April/024550.html)*
*

*Response:*

Your suggestion that "ARIN should not compel the production of customer 
identities for any customer holding a total of less than 8 IPv4 
addresses unless all reasonable alternatives for verifying utilization 
have been exhausted" contradicts existing policy requirements.

NRPM 4.2.2.1.2, states:

"For blocks smaller than /29 and for internal space, ISPs should provide 
utilization data either via SWIP or RWhois server or by providing 
detailed utilization information."

NRPM 4.2.2.2.1, states:

"Utilization for blocks smaller than /29 can be documented via SWIP or 
RWhois server or by providing detailed utilization information."

These policy references allow ARIN to require the same detailed 
utilization information for /29 and smaller reassignments as it does for 
the larger reassignments that are required by policy to be swipped. So 
essentially this detailed utilization information is equivalent to what 
would be published via SWIP/RWhois.

Because there is a current policy requirement for ISPs to provide 
customer-level detail in policy, and this is very useful information for 
ARIN to have when assessing an organization's need for additional 
address space, we believe that policy supersedes suggestions, and that 
the customer-level detail is a necessary requirement. Therefore, ARIN 
will not be implementing your suggestion as written.
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