[arin-ppml] Re-allocations (was: Revised/Retitled: Draft Policy ARIN-2017-5: Improved IPv6 Registration Requirements)

[David Farmer]

On Wed, Aug 30, 2017 at 12:27 PM, Jason Schiller <jschiller at google.com>
wrote:
...

> I recall there being a third class, any re-allocation.
>
> A re-allocation is when I ISP provides addresses to their down stream
> ISP customer who then in turn will further sub-delegate address space
> to their customer (who may also be an ISP with customers... and so on).
>
>
Jason,

I've been working on a separate proposal regarding re-allocations. It
really needs a bit of a different problem statement, and there is text
needed for both IPv4 and IPv6.  Here, is what I have so far;

Any comments would be appreciated;

Thanks.

--------
Policy Proposal Name:

Require Registration for Re-allocations to Downstream ISPs

Problem Statement:

It is critical that the best source for information about the end user
associated with any IP address is publicly known.  That is not to say that
the information about the end user associated with each IP address needs to
be publicly known, but that the entity that has a direct customer
relationship with, or otherwise knows, the end user for any IP address
needs to be publicly known.

Frequently civil and criminal litigation today involves electronic evidence
of some kind, this evidence is regularly associated with an IP addresses.
In such cases, the customer records associated with an IP address may need
to be subpoenaed as part of civil or criminal legal proceedings, therefore
the proper entity to issue a subpoena to needs to be readily known.  When
ARIN allocates address space to an ISP this information is provided in it's
registration database, and is publicly accessible via Whois. When addresses
are re-allocated from an ISP to another downstream ISP, and if this
re-allocation is not properly and publicly documented the wrong ISP could
be subpoenaed for the customer records associated with an IP address. This
wastes the time of judges and other court officials, but even worse it
could cause a delays in time-sensitive situations, for instance the
kidnapping of a child.

For these reasons, the re-allocation of address space to a downstream ISP
must be registered in ARIN's WHOIS directory via SWIP before the downstream
ISP uses the re-allocated addresses to provide any services to it's
customers.

Policy statement:

Add new subsections X for IPv4 and Y for IPv6 as follows, 4.2.3.7.4 and
6.5.5.5 are recommended respectively;

X. Re-allocations to other ISPs

Each IPv4 re-allocation to a downstream ISP, regardless of size, must be
registered to the downstream ISP in the WHOIS directory via SWIP before the
re-allocation is used to provide any services to the downstream ISP's
customers.

Y. Re-allocations to other ISPs

Each IPv6 re-allocation to a downstream ISP, regardless of size, must be
registered to the downstream ISP in the WHOIS directory via SWIP before the
re-allocation is used to provide any services to the downstream ISP's
customers.

Comments:
a. Timetable for implementation: Immediate
b. Anything else

The use of RWHOIS, or other distributed Distributed Information Server as
described in NRPM section 3.2, for this registration information is not
sufficient, the ARIN WHOIS directory needs direct knowledge of each
re-allocation to ensure the correct information is provided without needing
to access other services.

Processes and procedures should be developed for the reporting of incorrect
or unregistered re-allocations that result in official legal process going
to the wrong entity. ARIN Staff should investigate such reports and work
with upstream ISPs to ensure the reported registrations are correct. The
imposition of penalties, financial or otherwise, for incorrect or
unregistered re-allocations are not directly a policy question, but are
more a question of business practice, and should be considered separately
by the ARIN Board of Trustees assuming this policy proposal is adopted.

Previously in IPv4, slow-start essentially required new ISPs to use a
re-allocation from an upstream ISP to develop an allocation history before
they could receive a direct allocation from ARIN, even though the term
re-allocation wasn't specified in the NRPM.  In IPv6 this should not be
necessary, most new ISPs should be able to qualify for an initial
allocation directly from ARIN. However, there are other reasons for
re-allocations in both IPv4 and IPv6 generally, either on a permanent basis
or temporarily during a transition, such as the change in ownership of a
customer territory or the sale of only part of a network, etc...

-- 
===============================================
David Farmer               Email:farmer at umn.edu
Networking & Telecommunication Services
Office of Information Technology
University of Minnesota
2218 University Ave SE        Phone: 612-626-0815
Minneapolis, MN 55414-3029   Cell: 612-812-9952
===============================================
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