[arin-ppml] Draft Policy ARIN-2016-8: Removal of Indirect POC Validation Requirement

[ARIN]

On 15 December 2016, the ARIN Advisory Council (AC) advanced the 
following Proposal to Draft Policy status:

ARIN-prop-233: Removal of Indirect POC Validation Requirement

This Draft Policy has been numbered and titled:

Draft Policy ARIN-2016-8: Removal of Indirect POC Validation Requirement

Draft Policy text is below and can be found at:
https://www.arin.net/policy/proposals/2016_8.html

You are encouraged to discuss all Draft Policies on PPML. The AC will 
evaluate the discussion in order to assess the conformance of this draft 
policy with ARIN's Principles of Internet Number Resource Policy as 
stated in the Policy Development Process (PDP). Specifically, these 
principles are:

     > Enabling Fair and Impartial Number Resource Administration
     > Technically Sound
     > Supported by the Community

The PDP can be found at:
https://www.arin.net/policy/pdp.html

Draft Policies and Proposals under discussion can be found at:
https://www.arin.net/policy/proposals/index.html

Regards,

Sean Hopkins
Policy Analyst
American Registry for Internet Numbers (ARIN)

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ARIN-2016-8: Removal of Indirect POC Validation Requirement

Problem Statement:

There are over 600,000 POCs registered in Whois that are only associated 
with indirect assignments (reassignments) and indirect allocations 
(reallocations). NRPM 3.6 requires ARIN to contact all 600,000+ of these 
every year to validate the POC information. This is problematic for a 
few reasons:

1) ARIN does not have a business relationships with these POCs. By 
conducting POC validation via email, ARIN is sending Unsolicited 
Commercial Emails. Further, because of NRPM 3.6.1, ARIN cannot offer an 
opt-out mechanism. Finally, ARIN's resultant listing on anti-spam lists 
causes unacceptable damage to ARIN's ability to conduct ordinary 
business over email

2) ARIN has previously reported that POC validation to reassignments 
causes tremendous work for the staff. It receives many angry phone calls 
and emails about the POC validation process. I believe the ARIN staff 
should be focused on POC validation efforts for directly issued 
resources, as that has more value to internet operations and law 
enforcement than end-user POC information.

Policy statement:

Replace the first sentence of 3.6.1:

"During ARIN's annual Whois POC validation, an email will be sent to 
every POC in the Whois database."

with

"During ARIN's annual Whois POC validation, an email will be sent to 
every POC that is a contact for a direct assignment, direct allocation, 
reallocation, and AS number, and their associated OrgIDs."

Timetable for implementation: Immediate