[arin-ppml] Policy Proposal 109: Standardize IP Reassignment Registration Requirements - revised

[Member Services]

The proposal originator submitted a revised version of the proposal.

The AC will review this proposal at their next regularly scheduled
meeting and decide how to utilize the proposal. Their decision will be
announced to the PPML.

Regards,

Member Services
American Registry for Internet Numbers (ARIN)


## * ##


Policy Proposal 109: Standardize IP Reassignment Registration
Requirements

Proposal Version: 2.0

Date: 9 FEB 2010

Proposal type: New

Policy term: Permanent

Policy statement:

## Definitions ##

  - Add:

2.3. Organizational Information

When required, organization Information must include at a minimum:
Legal name, city, state, zip code equivalent and at least one valid
technical or abuse POC; inclusion of street address is highly encouraged.

The POC shall be designated by the organization and must include at
least one verifiable email address, inclusion of a phone number is
highly encouraged.

## IPv4 ##

  - Rename 4.2.3.7. "Reassignment information" to "Registration"

  - Rename 4.2.3.7.1. "Customer organization information" to
"Reassignment Information" and replace text with:

When an organization holding an IPv4 address allocation makes IPv4
address assignments, it must register reassignment information via SWIP
or RWHOIS server. SWIP and RWHOIS reassignments shall include each
client's organizational information, except where specifically exempted
by this policy.

  - Replace 4.2.3.7.6. Residential Customer Privacy with:

4.2.3.7.6. Residential Subscribers

4.2.3.7.6.1. Residential Market Area

In most cases, ISPs that have residential subscribers assign address
space to the infrastructure to which their customers connect rather than
to individual subscribers. This assignment information regarding each
market area holding an address block should be registered with the
network name used to identify each market area. Initial allocations are
based on total number of homes that could purchase the service in a
given market area. Each assignment to specific end-users holding /29 and
larger blocks still requires registration. In order to obtain additional
IPv4 addresses, ISPs assigning addresses by market area must show, using
reassignment information published in whois, that they have reassigned
at least 80% of their current address space, with a >50% utilization rate.

4.2.3.7.6.2. Residential Customer Privacy

To maintain the privacy of their residential customers, an organization
with downstream residential customers holding /29 and larger blocks 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.

  - Strike section 4.2.6. "Cable Address Space Policy"

## IPv6 ##

  - Replace Section 6.5.5. with:

6.5.5. Registration

6.5.5.1. Reassignment information

When an organization holding an IPv6 address allocation makes IPv6
address assignments, it must register reassignment information in a
database, accessible by RIRs as appropriate (information registered by
an RIR may be replaced by a distributed database for registering address
management information in future). These reassignment registrations
shall include each client's organizational information, except where
specifically exempted by this policy.

6.5.5.2. /56 registered unit

Information is registered in units of assigned /56 networks. When more
than a /56 is assigned to a client organization, the assigning
organization is responsible for ensuring that the address space is
properly registered.

6.5.5.3. Submit within 7 days

Any time an LIR receives a new block of address space, reassignment
information should be submitted within 7 days of issuance of the new space.

6.5.5.4. Visible via WHOIS

This information must be visible via WHOIS prior to submitting a
request for a new allocation. For further information on reassigning IP
address space, please see RFC 2050.

6.5.5.6. Residential Subscribers

6.5.5.6.1. Residential Market Area

In most cases, ISPs that have residential subscribers assign address
space to the infrastructure to which their customers connect rather than
to individual subscribers. This assignment information regarding each
market area holding an address block should be registered with the
network name used to identify each market area. Initial allocations are
based on total number of homes that could purchase the service in a
given market area. Each assignment to specific end-users holding /56 and
larger blocks still requires registration. In order to obtain additional
IPv6 addresses, ISPs assigning addresses by market area must show, using
reassignment information published in whois, that they have reassigned
at least 80% of their current address space, with a >50% utilization rate.


6.5.5.6.2. Residential Customer Privacy

To maintain the privacy of their residential customers, an organization
with downstream residential customers holding /56 and larger blocks 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.


Rationale:

#Short Version:
This proposal intends to do several things:
1) Bring IPv4 and IPv6 policy more in line with each other to make the
NRPM easier to understand and comply with - at least as it relates to
reassignment information.
2) Specifically define what organizational information is required to
be added to whois when reassignments are made to client organizations.
3) To specifically state that a client organization may designate the
POC of their choice for any/all whois entries. This includes
designating an upstream POC as their own prefered POC.
4) Expands the priviledges previously reserved solely for IPv4 cable
ISPs to all ISPs/LIRs with residential subscribers.

#Expanded version:
1) This policy restructures the reassignment and registration sections
of the IPv4 and IPv6 policies.
        a) The IPv4 section is renamed "registration."
        b) The first section of the IPv4 policy is rewritten for clarity.
        c) The IPv6 policy is totally rewritten in a format that matches
the IPv4 policy.
* These structural changes are meant to make it easier to compare the
two sections. I believe that having the IPv6 and IPv4 policies written
in completely different formats and structures (as they are in many
cases now) confuses the issues and makes it very hard to understand
what is different and what is the same across the two sections.
Bringing them into a similar format should help ease the migration to
IPv6 as folks can quickly and easily understand the differences and
the similarities.

2) This policy adds a definition of "organizational information" which
is used in the existing policy but not currently defined anywhere in
the NRPM.
        a) The definition states that specific addresses are not
required for
client organizations but asks that they be included when possible.
        b) The definition states that a POC is required but can be
designated
by the client organization - it spells out that the client org can
choose to use their upstream as a POC.
        c) The definition requires that the POC have a valid email
address but only suggests that it include a phone number.
* This definition is meant to address the customer confidentiality
concerns that have been brought up recently (by specifically removing
the requirement to publish client addresses and telephone numbers),
with the smallest negative impact to whois usefulness (retains a valid
POC w/ email contact).

3) This policy takes the privileges granted specifically to IPv4 cable
operators in section 4.2.6. "Cable Address Space Policy" and grants
them to all ISPs who serve residential areas.
        a) It allows all ISPs with residential coverage to
register/swip/rwhois an entire market area.
        b) It retains the existing residential customer privacy policy
for all customers with larger IP blocks.
* This change removes the need for any ISP to enter residential
customers into whois at all.

4) This policy also extends the >50% utilization rate, currently granted
only to IPv4 cable operators, to all ISPs with a residential footprint.
* This change will make it easier for ISPs serving residential areas
to get the addresses they need - this is key for FTTH operators as
well as fixed-wireless and other residential ISPs.

#Specific changes in this version:
1) Sections 4.2.3.7.6.1. and 6.5.5.6.1. have an added sentance: "In
order to obtain additional IPvX addresses, ISPs assigning addresses by
market area must show, using reassignment information published in
whois, that they have reassigned at least 80% of their current address
space, with a >50% utilization rate." Currently this >50% utilization
rate is reserved solely for IPv4 cable operators, this addition
spreads it to all residential ISPs, both IPv4 and IPv6 alike.

2) The last line of section 6.5.5.2. was changed from "...is
registered in an RIR database." to "...is properly registered." To
reflect the fact that RWHOIS and other potential methods of publishing
WHOIS information are not in fact RIR databases.

#Note: Specific mention of SWIP and RWHOIS has been left in the IPv4
policy to avoid complicating this proposal further by rewriting the
entire IPv4 section without any substantive change. The IPv6 policy
has been written to be agnostic concerning the method of publishing
WHOIS information.

Timetable for implementation: Immediate