[arin-ppml] Discussion Petition for Proposal 109 - Standardize IP Reassignment Registration Requirements

[Chris Grundemann]

This post should act as my formal request to initiate a discussion
petition of proposal 109 and to request that it be moved to draft
policy status for discussion at ARIN XXVI.

> The AC decided not to select Proposal 109 as a draft policy at this time:
>
>  109. Standardize IP Reassignment Registration Requirements
>
> Regarding Proposal 109, the AC would really like to see the sentiments
> in this proposal re-surface in bite-size pieces. SWIP requirements, both
> IPv4 and IPv6, the distinction of residential customers, the utilization
> requirements for subsequent allocations, and customer privacy are all
> good topics, but agreement in some will be held up by any disagreements
> on the others when trying to address them as one.

Although I understand the sentiments of the AC, I am petitioning this
proposal as I feel strongly that it meets the basic requirements for
ARIN Policy and meets the immediate needs of the community. This
proposal was previously discussed at the open policy hour in Toronto
and I believe that the best next step is for the final (v4) text to be
discussed as a draft policy in Atlanta. If the petition is successful
I will continue to work with the AC in preparation for presenting it
at the PPM in Atlanta.

If you support this petition, please send the following:

I support the petition of proposal 109.
<Name, Organization, Contact info>

Either as a response to this thread or directly to petition at arin.net
if you do not want your information to be broadcast on the PPML.

--

Author contact information:

Chris Grundemann
cgrundemann at gmail.com
+1.303.351.1539

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Policy statement (v4):

## Definitions ##

- Add:

2.3. Organizational Information

When required, organization Information must include at a minimum:
Legal name, street address, city, state, zip code equivalent and at
least one valid technical and one valid abuse POC. Each POC shall be
designated by the organization and must include at least a verifiable
email address and phone number.

2.12. Residential Customer

End-users who are individual persons and not organizations and who
receive service at a place of residence for personal use only are
considered residential customers.

## IPv4 ##

- Rename 4.2.3.7. "Reassignment information" to "Registration" and add text:

ISPs are required to demonstrate efficient use of IP address space
allocations by providing appropriate documentation, including but not
limited to assignment histories, showing their efficient use.

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

Each IPv4 assignment containing a /29 or more addresses shall be
registered in the WHOIS directory via SWIP or a distributed service
which meets the standards set forth in section 3.2. Reassignment
registrations shall include each client's organizational information,
except where specifically exempted by this policy.

- Strike sections 4.2.3.7.2., 4.2.3.7.4. and 4.2.3.7.5.

- Renumber section 4.2.3.7.3. to 4.2.3.7.2., rename to "Assignments
visible within 7 days" and replace text with:

All assignments shall be made visible as required in section 4.2.3.7.1
within seven calendar days of assignment.

- Renumber and replace 4.2.3.7.6. Residential Customer Privacy with:

4.2.3.7.3. Residential Subscribers

4.2.3.7.3.1. Residential Market Area

ISPs that assign address space to the infrastructure to which their
customers connect rather than to individual subscribers must register
assignment information regarding each market area holding such an
address block. Market area reassignments shall be registered with the
network name used to identify each market area. Any assignment to
specific end-users holding /29 and larger blocks still requires
registration. A >50% utilization rate shall be considered efficient
for market area reassignments from the ISPs most recent allocation.

4.2.3.7.3.2. 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 directory record for that
block.

- Strike section 4.2.6. "Cable Address Space Policy"

## IPv6 ##

- Replace Section 6.5.5. with:

6.5.5. Registration

ISPs are required to demonstrate efficient use of IP address space
allocations by providing appropriate documentation, including but not
limited to assignment histories, showing their efficient use.

6.5.5.1. Reassignment information

Each IPv6 assignment containing a /64 or more addresses shall be
registered in the WHOIS directory via SWIP or a distributed service
which meets the standards set forth in section 3.2. Reassignment
registrations shall include each client's organizational information,
except where specifically exempted by this policy.

6.5.5.2. Assignments visible within 7 days

All assignments shall be made visible as required in section 4.2.3.7.1
within seven calendar days of assignment.

6.5.5.3. Residential Subscribers

6.5.5.3.1. Residential Market Area

ISPs that assign address space to the infrastructure to which their
customers connect rather than to individual subscribers must register
assignment information regarding each market area holding such an
address block. Market area reassignments shall be registered with the
network name used to identify each market area. Any assignment to
specific end-users holding /64 and larger blocks still requires
registration. A >50% utilization rate shall be considered efficient
for market area reassignments from the ISPs most recent allocation.

6.5.5.3.2. Residential Customer Privacy

To maintain the privacy of their residential customers, an
organization with downstream residential customers holding /64 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.

## Resource Review ##

- Move section 12.2. paragraph 2. bullet c. to bullet d. and insert
the following:

c. whenever ARIN has reason to believe that an organization is not
complying with reassignment policies, or

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Rationale:

#Changes in this version:
After many conversations both at and following the last public policy
meeting in Toronto, some revisions have been made. These all address
specific concerns raised by multiple interested parties:
1) Organizational Information – Phone number, street address and abuse
POC now required.
2) Residential Customer – Added “for personal use only” to the definition.
3) Registration  (4.2.3.7 & 6.5.5) – Added “but not limited to” WRT
assignment histories.
4) IPv6 – Requires all /64 and larger blocks to be registered.
5) Resource Review – Added this section.

#Short Rational:
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 in policy. This includes
designating an upstream POC as their own preferred POC (which allows
for simple reassignments).
4) Expands the privileges previously reserved solely for IPv4 cable
ISPs to all ISPs/LIRs with residential/dhcp-type subscribers.
5) Specifically define the term "residential customer."
6) Allow ARIN to conduct resource reviews based on failure to comply
with registration / reassignment policies.

#Expanded Rational:
1) This policy restructures the reassignment and registration sections
of the IPv4 and IPv6 policies.
a) The IPv4 section is renamed "registration."
b) The IPv4 policy is shortened and 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.
d) The IPv6 policy is altered from a /56 minimum needing to be
registered to a /64. A /64 is a single IPv6 subnet where as a /56
contains many subnets (that should all be recorded in the WHOIS
directory if handed out to other organizations).

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 legal name and physical address are
required for client organizations.
b) The definition states that POCs are 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 each POC have a valid email address
and phone number.

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 offsets the ability to register/swip/rwhois market
areas. For all other allocation types, efficient utilization is based
on SWIPs, not on actual utilization. When an organization is able to
SWIP an entire market area, this must be checked against actual
utilization. This policy maintains the current line set at >50%.
**The 50% mark on the most recent allocation is because you can
quickly distribute most of your address space across your provisioning
footprint, leaving nothing left for growth while the lease count of
the provisioned customers catches up to the blocks allocated. (Dan
Alexander's words)


5) Current policy references "residential customers" but there is no
current definition of residential customers in the NRPM. This has
reportedly been an on-going problem for ARIN and it’s customers.

6) Not properly registering reassignment information could be a sign
of other improper or illicit behavior and should justify a resource
review (audit) by ARIN when necessary, regardless of when the last
review took place.

--

Thank you,
~Chris


-- 
@ChrisGrundemann
weblog.chrisgrundemann.com
www.burningwiththebush.com
www.coisoc.org