I oppose this Policy,

The result of this would be I would have to pretty much stop SWIP submissions. 
Many of my reassignments are
small enough that SWIP is optional anyway. Of the aprox 110 reassignments I 
have made, 3 have someone there that could
respond to an issue, one of which for some reason hates ARIN and refuses to 
have anything to do with them. An additional
dozen or so might very well send you their email password if you ask and claim 
to be their email provider.

I have chosen to SWIP small reassignments for ease of justification if further 
IPv4 is needed and for transparency to
the net if an issue arises. Some are multiple geographically dispersed offices 
of a single enity. Some are multiple
tenents of a larger multi-tenent building. The IT resources for many of these 
offices are frequently consultants
or corporate folks that might be hundreds of miles away. Neither is likely to 
respond to POC requests.

That, I though, was the idea for the simple reassignment. I remain the POC for 
the reassignment and am responsive to
issues when contacted.

Larry Ash COO
Mountain West Telephone
123 W 1st St.
Casper, WY 82601
Office 307 233-8387


Draft Policy ARIN-2017-12: Require New POC Validation Upon Reassignment

Problem Statement:

Some large ISPs assign individuals to be POCs for reassigned blocks without consultation of the individual they are inserting into Whois. One year later, the POC is contacted by ARIN as part of Annual POC Validation policies. The POC often does not know who ARIN is, what Whois is, and why they are in Whois.

This policy proposal seeks to improve the situation where a POC is unwittingly 
and unwantingly inserted into Whois.

It also seeks to mitigate the significant amount of time that ARIN staff reports that they spend fielding phone calls from POCs who have no idea they are in Whois.

Finally, it is hopeful that this proposal will improve the overall POC validation situation, by forcing ISPs and customers to work together to insert proper information into Whois at the time of sub-delegation.

Policy statement:

Insert two new sections into NRPM 3:

3.7 New POC Validation Upon Reassignment

When an ISP submits a valid reallocation or detailed reassignment request to ARIN which would result in a new POC object being created, ARIN must (before otherwise approving the request) contact the new POC by email for validation. ARIN's notification will, at a minimum, notify the POC of:

- the information about the organization submitting the record; and
- the resource(s) to which the POC is being attached; and
- the organization(s) to which the POC is being attached.

If the POC validates the request, the request shall be accepted by ARIN and the new objects inserted into Whois. If the POC does not validate the request within 10 days, ARIN must reject the request.

3.8 Downstream Validation of Simple Reassignments

When an ISP submits a valid simple reassigment request to ARIN with an organization name OR postal address that is identical to one or more existing OrgIDs, ARIN will notify the downstream organization and obtain guidance on whether to accept the simple reassigment, or redirect it to one of the existing OrgIDs as a detailed reassignment.

Comments:

Timetable for implementation: Immediate
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