[arin-ppml] Clarify /29 assignment identification requirement

[Jack Bates]

On 4/28/2012 7:33 PM, Larry Ash wrote:
> 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. 

This was my big concern, and I did warn (after the fact) the telco that 
didn't talk to their lawyer before sending the information to ARIN 
(probably didn't get an NDA, either). They were most likely audited for 
asking for some obscene CIDR block initially, but that probably isn't 
unusual out of people switching from PA to PI. In their ignorance, they 
ask for someone big and cool and ARIN corrects them in the followup for 
what they justify.

However, as an ISP that serve's ISPs, I've never been requested to go to 
my ISP customers and ask them for this information. Some of them would 
laugh in my face. I wonder if this doesn't create an extra hardship 
between PI and PA justifications, and if that is something that is desired.

Also, are we just picking on the little guy, while some of the largest 
networks (as mentioned elsewhere) are leaving huge blocks of networks 
SWIP'd after they've been released and possibly asking for more space? 
The smaller ISPs are more likely to have a 4-30% static assignment ratio 
compared to the larger ISPs, which seems to indicate they are more 
likely to get PII detail audits. Only ARIN can confirm what size of 
aggregate allocated space tends to generate this kind of detail, though.


Jack