[arin-ppml] Draft Policy ARIN-2017-12: Require New POC Validation Upon Reassignment

[hostmaster at uneedus.com]

While SWIP assignments are used for determining the amount of addressses 
in use, there is nothing in the current rules that would require reporting 
this data down to the individual customer level in most cases.

As an example, most ISP's/LIR's provide each customer with a single IPv4 
address for their use.  This address may be either static or dynamic.  In 
any case, since this assigment is below /27, there is no requirement that 
SWIP be done to the customer level.  Such ISP could SWIP a block of 
addresses used for dynamic customer addresses, showing them in use, but 
not showing an individual record for each customer.  Ditto with a block of 
addresses used for static single address assignments.  These collective 
SWIP records show the addresses are being used, but do not require detail 
down to the customer level.

In the dialup days of the past, blocks of addresses used for dial up pools 
were commonly registered as one collective block.  When these became 
address pools for CTMS and DSL PPPoe, the same thing was often done, 
registering the blocks to show their use, often showing what area in the 
detail records.  However, without an assignment of at least /27 to a 
individual customer, there has never been a requirement to SWIP to the 
customer level.  Before 2013, that line was /24.

Because of the massive (compared to IPv4) blocks given out with IPv6, the 
need for SWIP except for multihome and downstream ISP's may go away.  My 
experence is that many ISP's with v6 blocks have SWIP'ed nothing, and 
since they are not going back to ARIN for more space, and having to 
justify their current use, it is unlikely that SWIP in IPv6 will ever be 
used to the extent it is in IPv4, since they are not seeking another bite 
of the apple.

Albert Erdmann
Network Administrator
Paradise On Line Inc.


On Thu, 30 Nov 2017, Owen DeLong wrote:

> IMO, it is absolutely how the system should work.
>
> Owen
>
>> On Nov 30, 2017, at 07:51 , Chris Woodfield <chris at semihuman.com> wrote:
>>
>> One point to make on this proposal is that this may change how ISPs assign blocks, given that both transfers and allocations have needs-based policies in force (for both v4 and v6), and SWIPs are generally used as evidence of utilization of existing blocks. With this proposal in force, adding a SWIP to an allocated block should no longer be considered a parallel process to assigning space to a downstream customer; instead, the insertion of a SWIP with a validated POC will be a blocking function on the downstream allocation, otherwise customers will be utilizing blocks without SWIPs if the POC is never validated.
>>
>> IMO this is how I feel the system *should* work, but then again, I’m currently not in the business of doing these kinds of assignments. Those who would be more directly impacted by this may have a different point of view :)
>>
>> -C
>>
>>> On Nov 21, 2017, at 2:43 PM, ARIN <info at arin.net> wrote:
>>>
>>> On 16 November 2017, the ARIN Advisory Council (AC) advanced "ARIN-prop-247: Require New POC Validation Upon Reassignment" to Draft Policy status.
>>>
>>> Draft Policy ARIN-2017-12 is below and can be found at:
>>> https://www.arin.net/policy/proposals/2017_12.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)
>>>
>>>
>>>
>>> Draft Policy ARIN-2017-12: Require New POC Validation Upon Reassignment
>>>
>>> Problem Statement:
>>>
>>> Some large ISPs assign individuals to be POCs for reassigned blocks without consultation of the individual they are inserting into Whois. One year later, the POC is contacted by ARIN as part of Annual POC Validation policies.  The POC often does not know who ARIN is, what Whois is, and why they are in Whois.
>>>
>>> This policy proposal seeks to improve the situation where a POC is unwittingly and unwantingly inserted into Whois.
>>>
>>> It also seeks to mitigate the significant amount of time that ARIN staff reports that they spend fielding phone calls from POCs who have no idea they are in Whois.
>>>
>>> Finally, it is hopeful that this proposal will improve the overall POC validation situation, by forcing ISPs and customers to work together to insert proper information into Whois at the time of sub-delegation.
>>>
>>> Policy statement:
>>>
>>> Insert two new sections into NRPM 3:
>>>
>>> 3.7 New POC Validation Upon Reassignment
>>>
>>> When an ISP submits a valid reallocation or detailed reassignment request to ARIN which would result in a new POC object being created, ARIN must (before otherwise approving the request) contact the new POC by email for validation. ARIN's notification will, at a minimum, notify the POC of:
>>>
>>> - the information about the organization submitting the record; and
>>> - the resource(s) to which the POC is being attached; and
>>> - the organization(s) to which the POC is being attached.
>>>
>>> If the POC validates the request, the request shall be accepted by ARIN and the new objects inserted into Whois.  If the POC does not validate the request within 10 days, ARIN must reject the request.
>>>
>>> 3.8 Downstream Validation of Simple Reassignments
>>>
>>> When an ISP submits a valid simple reassigment request to ARIN with an organization name OR postal address that is identical to one or more existing OrgIDs, ARIN will notify the downstream organization and obtain guidance on whether to accept the simple reassigment, or redirect it to one of the existing OrgIDs as a detailed reassignment.
>>>
>>> Comments:
>>>
>>> Timetable for implementation: Immediate
>>> _______________________________________________
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>>>
>>
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