[arin-ppml] Recommended Draft Policy ARIN-2017-5: Improved IPv6 Registration Requirements

Thu Sep 28 13:18:00 EDT 2017

I agree with Kevin if a bigger stick is need to ensure compliance in the
future we can take that step if/when there proves to be a serious
non-compliance issue in the future. Personally, I'm not ready to threaten
revocation, in this case. My intent in suggesting what is now 6.5.5.4 was
to crate an avenue for ARIN Staff to intervene with ISPs on behalf of
customers, if a customer wanted their assignment registered and their ISP
refused to register their assignment as requested, the customer can appeal
the issue to ARIN.  I'm fine with that intervention being short of
threatening revocation, at least until their proves to be a serious issue
with ISP's refusing valid requests by endusers to register assignments.  I
think the current language provides the proper balance.

I'm fine with the standard procedure starting with ARIN Staff forwarding
such complaints to an ISP requesting an explanation of the situation.
However, if this develops into a chronic matter for an ISP, I would expect
ARIN Staff to escalate the issue beyond simply asking for an
explanation.  Further after escalation, if the matter continues to be
chronic, I would expect eventually the community to be altered to the
situation. Probably not the specifics of which ISP and customers, but at
least that there is an issue and some sense of the situation involved.

Therefore, I support the policy as written. I'm not strongly opposed to
changing from "should" to "shall" for section 6.5.5.4, but I'd prefer
keeping that change in reserve, so we can go there, if there proves to be
serious issues with non-compliance in the future. Put another way, I think
voluntary compliance is highly preferred for this issue, and if voluntary
compliance proves insufficient, then we can deal with that in the future.

Thanks.

On Thu, Sep 28, 2017 at 10:46 AM, Kevin Blumberg <kevinb at thewire.ca> wrote:

> I support the policy as written.
>
>
>
> If the stick isn’t big enough it appears a simple policy change could be
> used, not just for this section but all the other areas “should” is used.
>
>
>
> I would like to point out that “should” is currently used 30 times in the
> NRPM.
>
>
>
> In reading John’s explanation, I can’t see “should” and “shall” being
> considered an editorial change. To extend the policy cycle to another
> meeting would be far worse.
>
>
>
> Out of curiosity, how often has ARIN had to deal with SWIP issues like
> this, where the other party ignored you?
>
>
>
> Thanks,
>
>
>
> Kevin Blumberg
>
>
>
>
>
> *From:* ARIN-PPML [mailto:arin-ppml-bounces at arin.net] *On Behalf Of *John
> Curran
> *Sent:* Wednesday, September 27, 2017 5:59 PM
> *To:* Jason Schiller <jschiller at google.com>
> *Cc:* arin-ppml at arin.net
> *Subject:* Re: [arin-ppml] Recommended Draft Policy ARIN-2017-5: Improved
> IPv6 Registration Requirements
>
>
>
> On 26 Sep 2017, at 3:18 PM, Jason Schiller <jschiller at google.com> wrote:
>
>
>
> I oppose as written.
>
>
>
> There should not be a different standard of requirement for:
>
> - re-allocation
>
> - reassignment containing a /47 or more addresses
>
> - subdelegation of any size that will be individually announced
>
>
>
> which is "shall"
>
>
>
> and Registration Requested by Recipient
>
>
>
> which is "should"
>
>
>
> I would support if they are both "shall".
>
>
>
> Can ARIN staff discuss what actions it will take if an ISP's
>
> down stream customer contacts them and explains that their
>
> ISP refuses to SWIP their reassignment to them?
>
>
>
> Will they do anything more than reach out to the ISP and tell
>
> them they "should" SWIP it?
>
>
>
> Jason -
>
>    If this policy change 2017-5 is adopted, then a provider that has IPv6
> space from ARIN
>
>    but routinely fails to publish registration information (for /47 or
> larger reassignments)
>
>    would be in violation, and ARIN would have clear policy language that
> would enable
>
>    us to discuss with the ISP the need to publish this information in a
> timely manner.
>
>
>    Service providers who blatantly ignore such a provision on an ongoing
> basis will be
>    in the enviable position of hearing me chat with them about their
> obligations to follow
>    ARIN number resource policy, including the consequences (i.e. potential
> revocation
>
>    of the IPv6 number resources.)
>
>
>
>    If the langauge for the new section 6.5.5.4 "Registration Requested by
> Recipient”
>
>    reads “… the ISP should register that assignment”, then ARIN would send
> on any
>
>    received customer complaint to the ISP, and remind the ISP that they
> should
>
>    follow number resource policy in this regard but not otherwise taking
> any action.
>
>
>
>    If the language for the new section 6.5.5.4 "Registration Requested by
> Recipient”
>
>    reads “… the ISP shall register that assignment”, then failure to do so
> would be
>
>    a far more serious matter that, if left unaddressed on a chronic
> manner, could have
>
>    me discussing the customer complaints as a sign of potential failure to
> comply with
>
>    number resource policy, including the consequences (i.e. potential
> revocation of
>
>    the IPv6 number resources.)
>
>
>
>    I would note that the community should be very clear about its
> intentions for ISPs
>
>    with regard to customer requested reassignment publication, given there
> is large
>
>    difference in obligations that result from policy language choice.
> ARIN staff remains,
>
>    as always, looking forward to implementing whatever policy emerges from
> the
>
>    consensus-based policy development process.
>
>
>
> Thanks!
>
> /John
>
>
>
> John Curran
>
> President and CEO
>
> American Registry for Internet Numbers
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
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