[arin-ppml] Draft Policy ARIN-2018-6: Clarify Reassignment Requirements in 4.2.3.7.1

[hostmaster at uneedus.com]

Looking at this, I am a NO as it is currently written.

This section deals with /29 or more IPv4 addresses, or stated another way, 
8 or more addresses.  Someone who is running such a network in today's 
IPv4 exhausted world needs to have a means to contact them directly in the 
event of abuse from their network.  The reassign-simple does not provide 
for this, unless you consider postal mail a reasonable means of contact 
for abuse reports.  I have ALWAYS directed abuse reports by either email 
or telephone, as a letter is not fast enough for an ongoing abuse problem.

As for the current ISP impact in regard to this policy as it currently 
exists before amendment, the greatest majority of ISP customers, both 
Business and Residential only have a single IPv4 address or less (CGnat) 
and therefore are exempt from this policy. Only larger networks with 
multiple hosts are likely to have 8 or more IPv4 addresses and subject to 
this policy.  Those with a /29 or more are very likely a very small amount 
of the total ISP customers, but are also the ones with multiple hosts that 
would be more likely to be compromised compared those who just have 
machines behind a NAT router that cannot accept inbound traffic without a 
router that is programmed to allow it. I doubt this policy change will 
have much change at most ISP's, since the customer base it addresses is 
very small.

I would also suggest the residential exemption be eliminated for /29 or 
more, as nearly all residential IPv4 use today is NAT, rather than public 
IPv4 address assignment for each host.  We have talked of the problem of 
spammers on this list using such /29 or more of residential space, that 
are protected by the current privacy rules for residental customers, and 
their abuse reports being ignored by their upstream.

Looking at the differences between the Detailed and Simple reassign 
templates, I do see one thing that would merit a change.  It is that the 2 
fields that are most often used for abuse reporting (telephone and email) 
are missing from the simple reassignment, and fields that are rarely used 
for abuse reporting (mailing address) are instead present.  This is a 
decision that I would like to see changed.

I would have no problem with a template change to reassign simple to only 
have Name, Contact Email and Telephone number, and omitting all the 
mailing address fields.  If that change were made, I would have no problem 
with the proposal, as then the Simple Reassignment will at least provide 
me with a reasonable means of contact in the event of abuse from that 
network.

Eliminating the requirement for a Detailed Assignment, without changing 
the fields contained in a Simple Assignment will have the effect of 
eliminating the abuse contacts for that network.  I think that would be 
wrong.

Albert Erdmann
Network Administrator
Paradise On Line Inc.


On Fri, 25 Jan 2019, Alyssa Moore wrote:

> Helloooo PPML,
>
> It's been a couple weeks since there's been any action here, but it's time
> to shake off the winter and think about some policy! Woo!
>
> This proposal has to do with clarifying the language and requirements
> around reassignments. Please take a look and let your AC know if you think
> we're on the right track or not.
>
> Cheers,
> AM
>
> On Tue, Nov 20, 2018 at 3:55 PM ARIN <info at arin.net> wrote:
>
>> On 15 November 2018 the ARIN Advisory Council (AC) accepted
>> "ARIN-prop-258: Clarify Reassignment Requirements in 4.2.3.7.1" as a
>> Draft Policy.
>>
>> Draft Policy ARIN-2018-6 is below and can be found at:
>> https://www.arin.net/policy/proposals/2018_6.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-2018-6: Clarify Reassignment Requirements in 4.2.3.7.1
>>
>> Problem Statement:
>>
>> Current NRMP section “Reassignment and Reallocation Information” is
>> being interpreted by some organizations to require a “detailed
>> reassignment” for all customers.  Under the current reassignment schema,
>> only a “detailed reassignment or reallocation” contains fields for
>> “organizational information”.
>>
>> This policy intends to simplify the reassignment requirements by noting
>> that only a customer’s name is required.  Thus a “simple reassignment”
>> can be used for most reassignments.
>>
>> Policy Statement:
>>
>> Replace section 4.2.3.7.1 with the following:
>>
>> 4.2.3.7.1. Reassignment and Reallocation Information
>>
>> Each IPv4 reassignment or reallocation containing a /29 or more
>> addresses shall be registered via a directory services system which
>> meets the standards set forth in section 3.2.
>>
>> Reassignment registrations must include each customer name, except where
>> specifically exempted by this policy.  Reassignment registrations shall
>> only include point of contact (POC) information if either: (1) requested
>> by the customer; or (2) the reassigned block is intended to be routed
>> and announced outside of the provider's network.
>>
>> Reallocation registrations must contain the customer’s organization name
>> and appropriate point of contact (POC) information.
>>
>> Comments:
>>
>> Timetable for implementation: immediate
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>