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

[Ted Mittelstaedt]

I think this is a load of baloney.  The requirement can be EASILY 
modified to only contact a RANDOMLY SELECTED SUBSET this is EXACTLY how 
auditing firms check validity.

You can simply modify it to say that instead of contacting every 
indirect POC every year that you are going to select a random group of 
POCs and contact them - this will verify if the subnet holders are
filing SWIPS that are accurate or if they are just making up stuff to 
meet utilization requirements.

That way the indirect POC holders will never know if this year they are 
going to be contacted or not - thus they have an incentive to maintain 
accurate records.

If ARIN is having trouble NOW with validating indirect POCs then it is 
CRYSTAL CLEAR that the direct allocation holders ARE SHIRKING THEIR
REQUIREMENT FOR HONESTY AND ACCURACY.  The solution of "oh they are
being a bunch of LAZY ASSES and not keeping their paperwork up so we are 
just going to eliminate the requirement" is to me kind of like saying 
that since the convicted felon out on parole is not honoring
his probation terms and checking in with his probation officer, that we 
are just going to end his probation.

Clearly the author of this recommendation was one of those kids who got
First prizes for "participation" and other such rubbish when he was 
growing up.


Ted

On 12/20/2016 10:09 AM, ARIN wrote:
> 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)
>
> ##########
>
> 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
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