[arin-ppml] Clarify /29 assignment identification requirement

[Larry Ash]

On Sat, 28 Apr 2012 21:07:08 +0000
  John Curran <jcurran at arin.net> wrote:
> On Apr 28, 2012, at 3:50 PM, William Herrin wrote:
>> 
>> Of the four folks across this conversation who've levied complaints
>> about ARIN asking for customer identities for /32 users, none have
>> expressed that ARIN inquired into customer identities for their
>> dynamic pools and one expressly stated that ARIN didn't ask about the
>> much larger dynamic pools at all. Four does not make a statistical
>> sample but it does suggest a pattern.
> 
> Indeed, it is an outline of a pleasant pattern that such information 
> isn't generally needed nor requested.
> 

John, my case is an interesting one to note.
I know why the reviewer was alerted. Some years earlier when I converted
from PA to PI space I promised to renumber out of PA space withing 6 months.

I did as requested but I didn't know until I made that request Qwest
never withdrew the assignment. So, when the reviewer saw my request it
looked like I had never made good on my original agreement. To this day
my nameservers still get reverse requests on those IP's. I don't know if
they every re-used any of that space but I'd guess not.

The request itself was interesting because it wasn't as a result of normal 
growth.
I had two small ISP customers that had PA from another provider and a third 
that
had 1200 customers behind a NAT with a /29 of IP on the front end. He had
some problems with law enforcement as he couldn't provide CALEA information
when requested. I know he was honest in his description because I provide
phone service to many of his customers and can see his ip's both RFC 1918 and 
public.

My request was to allow the two to return their PA to the old provider and to
try and get the third out of a bind. My actual utilization at the time was
probably 78 - 79%, SWIP probably showed the low 70's. I expected some 
discussions
and maybe some further justification.
When it was clear that the process was going to take quite some time to come
to a resolution we had to tell the customers we couldn't help them and drop 
it.

Another thing to note. When requested, there is very limited information we
can share. Any customer that is internet only, we can discuss it. Any customer
that we provide phone service to you'll have to talk to our telco lawyer. The
FCC has some very convoluted rules for phone companies about customer 
information
under the name of CPNI.  Mostly it has do do with call detail records but it's
not always clear on related information. Any information that could 
potentially
identify a phone customer and his voice traffic and/or equipment is 
problematic.
The fines can be a mega-buck per violation. We don't go there. We don't read 
the rules
and try and figure out if it applies or not. We just don't go there unless the
request comes with a court order.

>> ...
>> Per your statement above, ARIN considers itself at liberty to inquire
>> into the personally identifiable information (PII) of the smallest and
>> most ephemeral consumers of addresses among the ISP's customers during
>> an ISP's application for addresses. Is that correct?
> 
> Interesting phrasing, but could be literally correct (even if taken 
> to extreme...)  I would have said it as thus:
> 
> "In the absence of specific guidance from the community, ARIN will 
> request sufficient supporting details as necessary to verify a request."
> 
>> Folks, is that what we want?
> 
> A most excellent question, and one which the community should
> definitely discuss.  I'd ask that we set aside (temporarily)
> the question of retention of such detail, as it is apparent 
> that ARIN retaining of such detail past an approved request 
> should not be necessary (but we'll need to do some work to make
> sure this is the case.)

I have found it interesting. If I wanted to inflate the numbers /32's
wouldn't be where I'd do it.
However I'll bet I know where I could get thousands of names, addresses
,phone numbers, and GIS info so they were in similar neighborhoods etc.
As always where there is a will there is a way.

The methods have to be clear enough that we can be prepared
to provide the information that you need but understand there are other
forces in play so ARIN may need to be flexible.


> 
> Thanks,
> /John
> 
> John Curran
> President and CEO
> ARIN
> 
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Larry Ash
Network Administrator
Mountain West Telephone
123 W 1st St.
Casper, WY 82601
Office 307 233-8387