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

Tue Dec 20 18:11:27 EST 2016

Thanks, Alyssa, for saying what we were all thinking. 

In addition to the question of whether it's a good idea to contact a random subset of indirect POCs, there's also the question of whether it's even legal. If not, then that isn't a viable approach either. 

Personally, if we think indirect POC validation is worthwhile, I would favor an approach whereby an indirect POC receives an email from ARIN *when they get added* (not some random amount of time later), and they have to approve the creation of the POC record before it goes in the database. At that point, they can actually create an account to control their own POC record, and have a valid relationship with ARIN on which to base future efforts to validate whether the POC is still accurate. 

I agree with Alyssa: that feels like a new alternative proposal to me. 

Scott

> On Dec 20, 2016, at 5:03 PM, Alyssa Moore <alyssa at alyssamoore.ca> wrote:
> 
> Ted, I think contacting a random subset of indirect POCs à la auditing practices is a valid suggestion. This would still address the human resource intensity from part 2 of the problem statement. This is a different approach than 2016-8, and could very well be be the basis of an alternative POC Validation policy proposal. 
> 
> However, the contribution certainly could have been framed with more tact and fewer personal attacks. I think the crass comments were wholly unnecessary additions. As a newer member of the community who is actively trying to get fresh faces involved, it's exactly that kind of rhetoric that serves to discourage new folks from participating in the PDP. Please also note that the Mailing List Acceptable Use Policy states: 
> 
> "The following activities are specifically prohibited on any ARIN mailing list:
> 1) Statements that include foul language, personal character attacks, or show disrespect for other participants, including ARIN."
> 
> Let's commit to a more refined level of discourse. 
> 
> With respect, 
> Alyssa 
> 
>> On Tue, Dec 20, 2016 at 12:32 PM Ted Mittelstaedt <tedm at ipinc.net> wrote:
>> 
>> 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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