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

Thu Jul 27 13:44:14 EDT 2023

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 <mailto: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 <mailto: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 <mailto:Email%3Afarmer 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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