[ppml] ARIN's Interpretation of 2003-3

[Member Services]

On 27 October 2005 the following statement was made on the ppml:

"I interpret 2003-3 to allow suppression of all physical address 
information, up to and including country.  If ARIN's interpretation is 
otherwise, I'd like to hear a clear statement of that."

ARIN's interpretation:

A. Background.

1. Policy Proposal 2003-3 as implemented is stated in paragraphs 
4.2.3.7.6 and 6.5.5.1.  Section 4 deals with policy statements relative 
to IPv4 while section 6 deals with IPv6.  Both sections state the following:

"To maintain the privacy of their residential customers, an organization 
with downstream residential customers may substitute that organization's 
name for the customer's name, e.g. 'Private Customer - XYZ Network', and 
the customer's street address may read 'Private Residence'. Each private 
downstream residential reassignment must have accurate upstream Abuse 
and Technical POCs visible on the WHOIS record for that block."

Policy Proposal 2003-3 was adopted by the ARIN Board on 22 March 2004.

2. In section 3.2 the NRPM also mentions privacy where it states:

"The service may allow for privacy protections for customers. For 
residential users, the service may follow ARIN's residential privacy 
policy that includes displaying only the city, state, zip code, and 
country."

In this policy statement the address element that pertains to the street 
number and name is, by omission, identified as the portion of a postal 
address that may be chosen not to be displayed because of privacy 
protection. Section 3.2 is the implementation of Policy Proposal 2003-5. 
The Board adopted Policy Proposal 2003-5 on 10 June 2004.

The Board, by sequential adoption of these two proposals, has 
interpreted street address to mean that element of a postal address that 
conveys the street number and name.

This interpretation is substantiated by the USPS Domestic Mailing Manual 
publication DMM 300, Mailing Standards of the United States Postal 
Service, Section 602, paragraph 1.4 which describes the elements of a 
complete address.  In this description the element that contains the 
street name and number or PO Box are identified as a distinct element 
from that element that contains the city and state.  This distinction is 
further emphasized by the USPS Domestic Mail Manual publication DMM 100, 
A Customer's Guide to Mailing.  In DMM 100 the term "Street Address" is 
used to refer to the element described in DMM 300 as the street name and 
number.

B. Statement of Interpretation.

ARIN interprets street address to mean that element of a postal address 
that identifies street name and number.

Raymond A. Plzak
President & CEO
ARIN