ARIN XXV is fast approaching, which means that it is time for me to catch up on PPML posts and organize my thoughts surrounding the current proposals and impending issues. This is especially true for this meeting since I have a couple proposals of my own up for discussion at this meeting.
Draft Policy 2010-5
I discussed the first, Policy Proposal 102: Reduce and Simplify IPv4 Initial Allocations, back in January. It has since been accepted as a draft policy and added to the meeting agenda as Draft Policy 2010-5.
Draft Policy 2010-4
A second policy that I authored was merged into David Farmer’s Draft Policy 2010-4: Rework of IPv6 allocation criteria which will also be presented for discussion at ARIN XXV.
Policy Proposal 109
That brings us to the final policy proposal of mine that will be discussed at ARIN XXV. Only draft policies are presented and discussed for adoption at ARIN’s public policy meetings but Policy Proposal 109: Standardize IP Reassignment Registration Requirements will be discussed during the AC On-Docket Proposals Report. I may even be allowed to present the proposal in a slightly different manner than the typical On-Docket report. EDIT: I will be presenting pp109 on Sunday night as part of the Open Policy Hour – so make sure you are there Sunday night! The reason for this possible exception is twofold; for one, it is the only on-docket proposal at the moment and secondly, pp109 is somewhat of a counter-proposal to Draft Policy 2010-3: Customer Confidentiality, which will be up for discussion in Toronto as well. Cathy Aronson from the ARIN AC explained the situation in a ppml post:
Policy Proposal 109 is under consideration as well as Draft Policy 2010-3. However, due to timeline, proposal 109 will not make it to adoption discussion at the Toronto meeting although we will make time on the agenda for a presentation and some discussion of proposal 109. Draft Policy 2010-3 will be discussed at the Toronto meeting for possible adoption.
Since proposal 109 and draft policy 2010-3 relate to the same topic, but contain very different approaches to the issue, the AC feels it is important to call the community’s attention to the fact that they will be at different stages in the policy development process when we meet in Toronto.
Why Standardize IP Reassignment Registration Requirements?
Getting beyond the logistics of what will be presented when and in what form, the more important question is likely why.
So, why did I write this proposal? As alluded to above, the idea was sparked by the resurrection of Policy Proposal 95: Customer Confidentiality via petition into Draft Policy 2010-3. That proposed policy statement is:
ISPs may choose to enter the customer’s name along with the ISP’s
address and phone number in reassignments and reallocations in lieu of
the customer’s address and phone number. The customer’s actual
information must be provided to ARIN on request and will be held in the
strictest confidence.
This proposed policy is meant to allow ISPs to protect themselves from competitors who may use WHOIS information to target their existing customer lists. Whether or not you believe that this is a goal or aim that should be pursued by ARIN, the end result would be much more detrimental to the Internet community than any possible benefit. Without going into a longer examination of 2010-3, suffice it to say that I oppose this proposal but was intrigued by many of the comments surrounding it.
This led me to dig into the current policy regarding reassignment information. I didn’t particularly like what I found. For one thing the IPv4 and IPv6 policies are completely out of whack with each other. Beyond the structural problems, organizational information is required by the current policy but not defined anywhere in the NRPM. Additionally, the current IPv4 policy grants privileges specifically to cable operators – this does not seem fair to competing ISPs, be they DSL, FTTH (Fiber to the Home), or fixed wireless operators.
With these three primary issues in mind and taking great heed of many key comments and critiques from others on the ppml, I devised a proposal to replace both the IPv4 and IPv6 reassignment registration sections of the NRPM with something that is hopefully more clear, more fair and more in-line with the goals and needs of the entire Internet community served by ARIN. Below is the policy statement and full published rational for Policy Proposal 109: Standardize IP Reassignment Registration Requirements:
Policy statement:
## Definitions ##
– Add:
2.3. Organizational Information
When required, organization Information must include at a minimum: Legal name, city, state, zip code equivalent and at least one valid technical or abuse POC; inclusion of street address is highly encouraged. The POC shall be designated by the organization and must include at least one verifiable email address, inclusion of a phone number is highly encouraged.
2.12. Residential Customer
End-users who are individual persons and not organizations and who recieve service at a place of residence are considered residential customers.## IPv4 ##
– Rename 4.2.3.7. “Reassignment information” to “Registration” and add text:
ISPs are required to demonstrate efficient use of IP address space allocations by providing appropriate documentation, including assignment histories, showing their efficient use.– Rename 4.2.3.7.1. “Customer organization information” to “Reassignment Information” and replace text with:
Each IPv4 assignment containing a /29 or more addresses shall be registered in the WHOIS directory via SWIP or a distributed service which meets the standards set forth in section 3.2. Reassignment registrations shall include each client’s organizational information, except where specifically exempted by this policy.– Strike sections 4.2.3.7.2., 4.2.3.7.4. and 4.2.3.7.5.
– Renumber section 4.2.3.7.3. to 4.2.3.7.2., rename to “Assignments visible within 7 days” and replace text with:
All assignments shall be made visible as required in section 4.2.3.7.1 within seven calendar days of assignment.– Renumber and replace 4.2.3.7.6. Residential Customer Privacy with:
4.2.3.7.3. Residential Subscribers
4.2.3.7.3.1. Residential Market Area
ISPs that assign address space to the infrastructure to which their customers connect rather than to individual subscribers must register assignment information regarding each market area holding such an address block. Market area reassignments shall be registered with the network name used to identify each market area. Any assignment to specific end-users holding /29 and larger blocks still requires registration. A >50% utilization rate shall be considered efficient for market area reassignments from the ISPs most recent allocation.
4.2.3.7.3.2. Residential Customer Privacy
To maintain the privacy of their residential customers, an organization with downstream residential customers holding /29 and larger blocks may substitute that organization’s name for the customer’s name, e.g. ‘Private Customer – XYZ Network’, and the customer’s street address may read ‘Private Residence’. Each private downstream residential reassignment must have accurate upstream Abuse and Technical POCs visible on the WHOIS directory record for that block.– Strike section 4.2.6. “Cable Address Space Policy”
## IPv6 ##
– Replace Section 6.5.5. with:
6.5.5. Registration
ISPs are required to demonstrate efficient use of IP address space allocations by providing appropriate documentation, including assignment histories, showing their efficient use.
6.5.5.1. Reassignment information
Each IPv6 assignment containing a /56 or more addresses shall be registered in the WHOIS directory via SWIP or a distributed service which meets the standards set forth in section 3.2. Reassignment registrations shall include each client’s organizational information, except where specifically exempted by this policy.
6.5.5.2. Assignments visible within 7 days
All assignments shall be made visible as required in section 4.2.3.7.1 within seven calendar days of assignment.
6.5.5.3. Residential Subscribers
6.5.5.3.1. Residential Market Area
ISPs that assign address space to the infrastructure to which their customers connect rather than to individual subscribers must register assignment information regarding each market area holding such an address block. Market area reassignments shall be registered with the network name used to identify each market area. Any assignment to specific end-users holding /56 and larger blocks still requires registration. A >50% utilization rate shall be considered efficient for market area reassignments from the ISPs most recent allocation.
6.5.5.3.2. Residential Customer Privacy
To maintain the privacy of their residential customers, an organization with downstream residential customers holding /56 and larger blocks may substitute that organization’s name for the customer’s name, e.g. ‘Private Customer – XYZ Network’, and the customer’s street address may read ‘Private Residence’. Each private downstream residential reassignment must have accurate upstream Abuse and Technical POCs visible on the WHOIS record for that block.Rationale:
#New and Improved! Specific changes in this version (based on Staff and PPML comments):
1) Added section 2.12. to define residential customers. There is no current definition of residential customers and this has reportedly been an on-going problem for ARIN and it’s customers.
2) 4.2.3.7. and 6.5.5. were re-written to include current text in order to aid ARIN staff when requesting detailed utilization information as part of the normal request process.
3) 4.2.3.7.1. and 6.5.5.1. were re-written to simplify policy by combining the /29 and /56 rules as well as the WHOIS directory visibility requirements directly in a single statement (thanks to Owen DeLong for the suggestion).
3) Several sections were struck do to the clarity and detail gained in revision 3, above.
4) The “7-day” provision was renamed and rewritten for clarity (thanks again to Owen DeLong for the wording).
5) 4.2.3.7.3.1 & 6.5.5.3.1 were re-written for clarity based on many comments on and off list.#Short Rational:
This proposal intends to do several things:
1) Bring IPv4 and IPv6 policy more in line with each other to make the NRPM easier to understand and comply with – at least as it relates to reassignment information.
2) Specifically define what organizational information is required to be added to WHOIS when reassignments are made to client organizations.
3) To specifically state that a client organization may designate the POC of their choice for any/all WHOIS entries in policy. This includes designating an upstream POC as their own prefered POC (which allows for simple reassignments).
4) Expands the priviledges previously reserved solely for IPv4 cable ISPs to all ISPs/LIRs with residential/dhcp-type subscribers.
5) Specifically define the term “residential customer.”#Expanded Rational:
1) This policy restructures the reassignment and registration sections
of the IPv4 and IPv6 policies.
a) The IPv4 section is renamed “registration.”
b) The IPv4 policy is shortened and rewritten for clarity.
c) The IPv6 policy is totally rewritten in a format that matches the IPv4 policy.
* These structural changes are meant to make it easier to compare the two sections. I believe that having the IPv6 and IPv4 policies written in completely different formats and structures (as they are in many cases now) confuses the issues and makes it very hard to understand what is different and what is the same across the two sections. Bringing them into a similar format should help ease the migration to IPv6 as folks can quickly and easily understand the differences and the similarities.2) This policy adds a definition of “organizational information” which is used in the existing policy but not currently defined anywhere in the NRPM.
a) The definition states that specific addresses are not required for client organizations but asks that they be included when possible.
b) The definition states that a POC is required but can be designated by the client organization – it spells out that the client org can choose to use their upstream as a POC.
c) The definition requires that the POC have a valid email address but only suggests that it include a phone number.
* This definition is meant to address the customer confidentiality concerns that have been brought up recently (by specifically removing the requirement to publish client addresses and telephone numbers), with the smallest negative impact to whois usefulness (retains a valid POC w/ email contact).3) This policy takes the privileges granted specifically to IPv4 cable operators in section 4.2.6. “Cable Address Space Policy” and grants them to all ISPs who serve residential areas.
a) It allows all ISPs with residential coverage to register/swip/rwhois an entire market area.
b) It retains the existing residential customer privacy policy for all customers with larger IP blocks.
* This change removes the need for any ISP to enter residential customers into whois at all.4) This policy also extends the >50% utilization rate, currently granted only to IPv4 cable operators, to all ISPs with a residential footprint.
* This change will make it easier for ISPs serving residential areas to get the addresses they need – this is key for FTTH operators as well as fixed-wireless and other residential ISPs.
*The 50% mark on the most recent allocation is because you can quickly distribute most of your address space across your provisioning footprint, leaving nothing left for growth while the lease count of the provisioned customers catches up to the blocks allocated. (Dan Alexander’s words)5) Current policy references “residential customers” but there is no current definition of residential customers in the NRPM. This has reportedly been an on-going problem for ARIN and it’s customers.
