If you are going to change it to shall, then you also need to define the 
consequences of non-compliance.

From: ARIN-PPML [mailto:[email protected]] On Behalf Of Jason Schiller
Sent: Friday, September 29, 2017 9:59 AM
To: David Farmer <[email protected]>
Cc: [email protected]
Subject: Re: [arin-ppml] Recommended Draft Policy ARIN-2017-5: Improved IPv6 
Registration Requirements

David, Kevin, Alison

I am actually comfortable with an implementation that is short of revocation,
but I am still not comfortable with "should".

Should makes it optional.  Officially not being out of compliance with
ARIN policy makes it optional.

I suggest that an ISP refusing to register a downstream customer
is out of compliance with ARIN policy, and not just choosing to ignore
an optional recommendation.

If it is only "should" then an ISP can still hold the moral high ground
while refusing to support SWIP on the grounds that they will not
implement tooling and commit resources when it is only optional.

It is a question of if you can hold someone accountable for not
complying or if they are free to ignore something that is optional.



Owen, Chris, Kevin,

Certainly if there is enough support to move this forward, we shouldn't
wait another cycle. (I recognize this weakens the "shall" position)

My hope is if we can close out the discussion of this topic at the meeting
with a clear understanding of if there is community support to move forward
the policy with "shall" and also if there is clear support to move the policy 
forward
with "should" in this cycle.  This will give the AC a maximum of leverage to do
what is needed, and insure it doesn't fall to the next cycle by forcing people
to support only what they perceive as the best option.

Assuming there is support for both "shall" and "should" the AC could
choose to move "shall" to last call, and if there are then issues, move
should to last call.


We need to get clear on how to structure the question here.

My thoughts are

1. Do you support the policy with "shall" if it doesn't require an extra cycle
    and support "should" in this cycle if "shall" cannot advance?

2. Do you only support the policy as written?

3. Do you oppose both the policy as written and with "shall"?

When considering if there is enough support to move the policy as
written forward, the AC should consider the hands in both questions 1 & 2.


I support the policy with "shall" with a fall back to "should".

__Jason



On Thu, Sep 28, 2017 at 1:18 PM, David Farmer 
<[email protected]<mailto:[email protected]>> wrote:
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 
<[email protected]<mailto:[email protected]>> 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:[email protected]<mailto:[email protected]>] On 
Behalf Of John Curran
Sent: Wednesday, September 27, 2017 5:59 PM
To: Jason Schiller <[email protected]<mailto:[email protected]>>
Cc: [email protected]<mailto:[email protected]>
Subject: Re: [arin-ppml] Recommended Draft Policy ARIN-2017-5: Improved IPv6 
Registration Requirements

On 26 Sep 2017, at 3:18 PM, Jason Schiller 
<[email protected]<mailto:[email protected]>> 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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