[arin-ppml] Draft Policy ARIN-2023-4: Modernization of Registration Requirements

Tue Aug 22 18:10:23 EDT 2023

Thanks for the comments so far, it's given us shepards some good input to
further refine this draft. Any other opinions on wording?

-Anita

On Thu, Jul 27, 2023 at 12:47 PM Owen DeLong via ARIN-PPML <
arin-ppml at arin.net> wrote:

> Agreed… Legal requirements always supersede any sort of non-statutory
> policy or contract in any case, so there is no need to open this can of
> worms in policy.
>
> Owen
>
>
> On Jul 27, 2023, at 07:31, Martin Hannigan <hannigan at gmail.com> wrote:
>
> Timely is open to interpretation by either party which means it could be
> abused by either party. I would support an explicit requirement that is
> measurable. Like 14 days.
>
> This is a can of worms which seems unnecessary:
> “At the same time, privacy laws have been introduced in many
> jurisdictions across ARIN’s service region which constrain registration in
> certain cases.”
> Shouldn’t that be/already is dealt with in the RSA?
>
> Thanks,
>
> -M<
>
>
>
>
> *From: *ARIN-PPML <arin-ppml-bounces at arin.net> on behalf of Hunter,
> Kathleen via ARIN-PPML <arin-ppml at arin.net>
> *Date: *Thursday, July 27, 2023 at 9:06 AM
> *To: *Peter Potvin <peter.potvin at accuristechnologies.ca>, David Farmer <
> farmer at umn.edu>
> *Cc: *arin-ppml at arin.net <arin-ppml at arin.net>
> *Subject: *Re: [arin-ppml] Draft Policy ARIN-2023-4: Modernization of
> Registration Requirements
> The current timeframe on registrations works for myself, however, in the
> event 7 days is changed to an extended period of time and not “timely”, I
> think 14 days would be sufficient for anyone having issues registering
> large amounts of data. “Where applicable by law” was discussed in the
> working group as states like California now have CCPA. There are some
> business customers which may be considered residential with a business IP
> account. The way the text is today, all business customers /29 or more must
> be registered. This would allow flexibility for those customers which fall
> into a gray area. The language is in very early stages so at any point the
> shepherds can adjust the text. As always, the AC appreciates your input.
>
> Kat Hunter
>
> *From:* ARIN-PPML <arin-ppml-bounces at arin.net> *On Behalf Of *Peter
> Potvin via ARIN-PPML
> *Sent:* Wednesday, July 26, 2023 10:08 PM
> *To:* David Farmer <farmer at umn.edu>
> *Cc:* arin-ppml at arin.net
> *Subject:* Re: [arin-ppml] Draft Policy ARIN-2023-4: Modernization of
> Registration Requirements
>
> +1 on David's point. Unless "a timely manner" is defined somewhere within
> the NRPM and a limit is provided, it's open to interpretation as the
> interpreting party sees fit.
>
> In addition to this, I'm personally not a fan of adding the "to the extent
> permitted and manner provided by applicable law" wording, because again:
> which legislation is being applied here, from which jurisdiction and by
> which party? This is also up to interpretation which without being defined
> may not result in the intended actions or meaning.
>
> Regards,
> Peter Potvin | Executive Director
>
> ------------------------------------------------------------------------------
> *Accuris Technologies Ltd.*
>
>
>
> On Wed, Jul 26, 2023 at 9:37 PM David Farmer via ARIN-PPML <
> arin-ppml at arin.net> wrote:
>
> I think the change from 7 days to timely, is unacceptable. Timely is
> simply too vague and indefinite, it could mean virtually any timeframe,
> even up to 90 days or 180 days.
>
> I’d be fine extending the timeframe to 14 days, or 10 business days, to
> allow some flexibility for holidays. I’d even accept 21 days, but it needs
> to be a definite timeframe.
>
> Thanks
>
> On Tue, Jul 25, 2023 at 11:11 ARIN <info at arin.net> wrote:
>
> On 20 July 2023, the ARIN Advisory Council (AC) accepted “ARIN-prop-322:
> Modernization of Registration Requirements” as a Draft Policy.
>
> Draft Policy ARIN-2023-4 is below and can be found at:
>
> https://www.arin.net/participate/policy/drafts/2023_4/
> <https://urldefense.com/v3/__https:/www.arin.net/participate/policy/drafts/2023_4/__;!!CQl3mcHX2A!CNMWCMCN350m3SFzf0lyRHiwCE0y6q9kLTUTjjxubQCCWlSppgbe0JzYlNG2AUHLgpoujj5KHGoTZQVx6uBeQjOHTfdt$>
>
> You are encouraged to discuss all Draft Policies on PPML. The AC will
> evaluate the discussion to assess the conformance of this draft policy with
> ARIN's Principles of Internet number resource policy as stated in the
> Policy Development Process (PDP). Specifically, these principles are:
>
> * Enabling Fair and Impartial Number Resource Administration
> * Technically Sound
> * Supported by the Community
>
> The PDP can be found at:
>
> https://www.arin.net/participate/policy/pdp/
> <https://urldefense.com/v3/__https:/www.arin.net/participate/policy/pdp/__;!!CQl3mcHX2A!CNMWCMCN350m3SFzf0lyRHiwCE0y6q9kLTUTjjxubQCCWlSppgbe0JzYlNG2AUHLgpoujj5KHGoTZQVx6uBeQlDHuvwM$>
>
> Draft Policies and Proposals under discussion can be found at:
>
> https://www.arin.net/participate/policy/drafts/
> <https://urldefense.com/v3/__https:/www.arin.net/participate/policy/drafts/__;!!CQl3mcHX2A!CNMWCMCN350m3SFzf0lyRHiwCE0y6q9kLTUTjjxubQCCWlSppgbe0JzYlNG2AUHLgpoujj5KHGoTZQVx6uBeQjzoBBst$>
>
> Regards,
>
> Eddie Diego
> Policy Analyst
> American Registry for Internet Numbers (ARIN)
>
>
> Draft Policy ARIN-2023-4: Modernization of Registration Requirements
>
> Problem Statement:
>
> Registration is central to the value provided by ARIN to the
> community. Registry quality depends greatly upon the timely
> registration of reassignments from ISPs to end users. The motivation
> for registration has waned since the depletion of the free pool. At
> the same time, privacy laws have been introduced in many jurisdictions
> across ARIN’s service region which constrain registration in certain
> cases. This combination of forces has generally discouraged many ISPs
> from registering reassignments. Registration remains vital to a number
> of stakeholders, including law enforcement and network operators.
>
> This proposal aims to modernize the registration-related policies in
> Section 4 by introducing language that is meant to make registration
> requirements more adaptable to changing privacy laws, while reminding
> ISPs of the importance of registration when feasible for the benefit
> of the community.
>
> Policy Statement:
>
> In section 4.2.3.7.1,
> Replace
> "Each IPv4 reassignment or reallocation containing a /29 or more
> addresses shall be registered via SWIP or a directory services system
> which meets the standards set forth in section 3.2."
> With
> "Each IPv4 reassignment or reallocation containing a /29 or more
> addresses shall be registered in the WHOIS directory via SWIP or a
> directory services system which meets the standards set forth in
> section 3.2, in a timely manner, to the extent permitted and manner
> provided by applicable law."
>
> Retire section 4.2.3.7.2 Reassignments and Reallocations Visible
> Within Seven Days
>
> Rename 6.5.5.1
> From
> "Reassignment Information"
> To
> "Reassignment and Reallocation Information"
>
> In section 6.5.5.1,
> Replace
> "Each static IPv6 reassignment or reallocation containing a /47 or
> more addresses, or subdelegation of any size that will be individually
> announced, shall be registered in the WHOIS directory via SWIP or a
> distributed service which meets the standards set forth in section
> 3.2. Reassignment and reallocation registrations shall include each
> client’s organizational information, except where specifically
> exempted by this policy."
> With
> "Each static IPv6 reassignment or reallocation containing a /47 or
> more addresses, or subdelegation of any size that will be individually
> announced, shall be registered in the WHOIS directory via SWIP or a
> distributed service which meets the standards set forth in section
> 3.2, in a timely manner, to the extent permitted and manner provided
> by applicable law. Reassignment and reallocation registrations shall
> include each client’s organizational information, except where
> specifically exempted by this policy."
>
> Retire section 6.5.5.2 Reassignments and Reallocations Visible Within
> Seven Days
>
> Timetable for Implementation: Immediate
>
>
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> --
> ===============================================
> 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
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