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

[ARIN]

The message below started a petition regarding the ARIN Advisory
Council's decision not to select "Policy Proposal 109. Standardize IP
Reassignment Registration Requirements" as a draft policy at this time.
The AC's decision was posted by ARIN staff to PPML on 20 July 2010.

If successful, this petition will change Proposal 109 into a Draft
Policy which will be published for adoption discussion on the PPML and
at the Public Policy Meeting in October. If the petition fails, the
proposal will remain on the AC's docket.

For this petition to be successful, the petition needs statements of
support from at least 10 different people from 10 different
organizations. If you wish to support this petition, post a statement of
support to PPML on this thread. Point of contact information is
required, either to the entire PPML or with a follow up post to
petition at arin.net with full POC information (name, organization, street
address, email, phone).

The duration of the petition is until through five business days after
the AC's draft meeting minutes are published. ARIN staff will post the
result of the petition to PPML.

For more information on starting and participating in petitions, see PDP
Petitions at:
https://www.arin.net/policy/pdp_petitions.html

The proposal text is below and at:
https://www.arin.net/policy/proposals/index.html

The ARIN Policy Development Process can be found at:
https://www.arin.net/policy/pdp.html

Regards,

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


#####


> -----Original Message-----
> From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On
> Behalf Of Chris Grundemann
> Sent: Friday, July 23, 2010 1:51 PM
> To: ARIN PPML
> Subject: [arin-ppml] Discussion Petition for Proposal 109 - Standardize
> IP Reassignment Registration Requirements
>
> 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
>
> --
>
> 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
>
> --
>
> 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
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