This is one unavoidable issue with this proposal. ISPs will effectively be 
forced into a workflow where a ISP must allocate addresses and submit the SWIP 
prior to routing the block, and then not start routing until the POC is 
validated, unless ISPs want to risk customer impact/ire from having to withdraw 
the routing 10 days afterwards should the POC not complete the validation.

Personally, I consider this a positive change in process, but those actually 
handling customer turnups are welcome to disagree.

-C

> On Apr 18, 2018, at 12:48 PM, Delacruz, Anthony B 
> <[email protected]> wrote:
> 
> The reject will likely alert us but my systems are not setup to wait 10+ day 
> and then have to go sort out fixing it. I’m worried this is probably going to 
> break some of that. Legacy Centurylink going back thru the Qwest side have 
> done a pretty good job of submitting to whois, other companies we have 
> purchased not so well and we’re working to improve that but it’s a constant 
> battle of staff and use of time. We won’t allocate folks to go chase down 
> customers to click off approval. Asking to do on the phone also not likely as 
> a great many of offerings are moving to more automation. We have entire 
> service classes that can be ordered online, instantly provisioned and 
> activated and then the customer plugs into a prewired/fiber’d port never once 
> interacting with a human. Concerned about both 10 limbo and the loss of info 
> that might be a lead for LEO’s at the very least. I’ve used at least company 
> name and phone number 100’s of times when the poc was old outdated as a 
> starting point in trying to reach folks for issues it would be unfortunate 
> not to have at least.
>  
> From: Jason Schiller [mailto:[email protected] 
> <mailto:[email protected]>] 
> Sent: Wednesday, April 18, 2018 9:01 AM
> To: Delacruz, Anthony B
> Cc: ARIN-PPML List
> Subject: Re: [arin-ppml] Draft Policy 2017-12: Require POC Validation Upon 
> Reassignment
>  
> Anthony,
>  
> I hear you.  And I think we should try a "lets do better" approach.
>  
> I think the goal here is to get good SWIP data, and make sure the 
> contact info is correct.
>  
> This specific approach is an attempt to prevent a SWIP targeting
> a (wrong) unwitting victim.  
>  
> In your case I believe you are suggesting you collected the proper 
> contact info, and explained it will be included in the SWIP, and 
> verified that they don't have a pre-existing OrgID or POC, to
> SWIP to.  But then they drop the ARIN email.  And the SWIP
> gets rejected.
>  
> Rejected SWIPs from email templates get an email
> from ARIN Hostmaster <[email protected] <mailto:[email protected]>>
> with a subject including --REJECTED
>  
> Is this sufficient for you to track down the 
> customers who didn't ack, and fix this issue?
>  
> Is there a better way to loop the ISP back in
> and unwedge the stuck request?
>  
> Would an ARIN Online page of here are all the SWIPs
> that cannot be SWIP'd due to pending ACK help?
> A button to resend the request (while your customer 
> is on the phone)?  
>  
> Are you concerned about the 10 days it is in limbo?
> Or the long term stuff that never gets acked?
>  
> __Jason
>  
> On Tue, Apr 17, 2018 at 4:54 PM Delacruz, Anthony B 
> <[email protected] <mailto:[email protected]>> 
> wrote:
> Howdy folks I very much hope I’m not a significant part of this problem but 
> we do submit 50-100 reassigns a week. If there is any evidence of us causing 
> trouble in the data I’d be happy to try to run it down and improve. As noted 
> by others we do this primarily to offload abuse but also to assist LEO’s and 
> to be upfront with the community how our space is being use. We also try as 
> hard as we can to populate those records with valid info and have our sales 
> guys collect and input into our system then the provisioning team validates 
> at turn up and the system auto generates at activation the record. I worry 
> greatly that if an entry we send up goes unvalidated for 10 days that it must 
> be deleted. I think you are going to be losing a lot of good data of legit 
> usage simply because folks maybe too lazy to click off on an acknowledgment. 
> If implemented I could be sending all these updates and not seeing them 
> appear and wondering till 10 days down the road which ones I have to 
> reattempt? Will there be a notification back that the record did not 
> populate? That reattempt piece will be a lot of fun to workout with our IT 
> guys I can tell you it’ll just be dropped for a long time until they work out 
> the code to automate and thus usability of whois will be impacted.
>  
>  
> Anthony Delacruz
> Senior Lead Engineer
> IP Admin Backbone Planning and Design
> Office: +1 703 363 8503
> [email protected] <mailto:[email protected]>
> [email protected] <mailto:[email protected]>
>  
>  
>  
> From: ARIN-PPML [mailto:[email protected] 
> <mailto:[email protected]>] On Behalf Of John Santos
> Sent: Tuesday, April 17, 2018 1:58 PM
> To: [email protected] <mailto:[email protected]>
> Subject: Re: [arin-ppml] Draft Policy 2017-12: Require POC Validation Upon 
> Reassignment
>  
> I think anyone who supplies someone else's email address to a third party 
> without their permission is responsible for any mail they receive.  Unless a 
> SWIPer has permission from their customer to SWIP the customer's email 
> address, the ISP doing the SWIPing is responsible, not ARIN.  If they do this 
> repeatedly or as a matter of course, they should be barred from SWIPing and 
> any subnets they have previously SWIPed should revert to them, making them 
> responsible for all network abuse and connectivity problems originating from 
> those subnets.
> 
> Isn't the entire point of SWIP to allow ISPs to offload the abuse and other 
> points of contact to their customers, who presumably are more capable of 
> dealing with the issues?  And shouldn't the customers expect to receive email 
> at those POC addresses as part of that?  Either the ISP has explained that to 
> their customers, who have agreed to this, in which case no mail sent to them 
> as a consequence is SPAM, or  the ISP has not, in which case the POC (and 
> SWIP) should be removed or never allowed in the first place.
> 
>  
> 
>  
> On 4/17/2018 11:11 AM, Christian Tacit wrote:
> Hi Jason,
>  
> After discussion with staff, I can report that it would be much easier to 
> send a notification to the email that is swipped as the POC but to add in any 
> type of ACK or NACK turns it into a very, very heavy lift for the 
> organizations as it completely changes the flow. Furthemore, the addition of 
> a requirement for a response could end up creating issues (whether real or 
> perceived) that ARIN would be sending UCE (Unsolicited Commercial Email) 
> (SPAM) to all of those contacts as we do not have a formal relationship with 
> them.
>  
> Chris
>  
> 
> Christian S. Tacit,
> Tacit Law
> 
> P.O. Box 24210 RPO Hazeldean
> Kanata, Ontario
> K2M 2C3 Canada
> 
> Tel: +1 613 599 5345
> Fax: +1 613 248 5175
> E-mail: [email protected] <mailto:[email protected]>
> 
> This message is intended only for the use of the individual or entity to 
> which it is addressed and may contain information that is subject to 
> copyright, privileged, confidential, proprietary or exempt from disclosure 
> under applicable law. If you are not the intended recipient or the person 
> responsible for delivering the message to the intended recipient, you are 
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> using this message. If you have received this communication in error, please 
> notify the sender and destroy or delete copies you may have received.
>  
> From: Jason Schiller <[email protected]> <mailto:[email protected]> 
> Sent: April 16, 2018 3:05 PM
> To: Christian Tacit <[email protected]> <mailto:[email protected]>
> Cc: ARIN-PPML List <[email protected]> <mailto:[email protected]>
> Subject: Re: [arin-ppml] Draft Policy 2017-12: Require POC Validation Upon 
> Reassignment
>  
> Chris,
>  
> Thanks.  
>  
> One of the problems with POC validation is that ARIN tries to validate all 
> POCS, and does not have a relationship with some.
>  
> There is a proposal to reduce the validation to only the set of POCs that 
> ARIN has a direct relationship with.
>  
> This is problematic because it is through this annual validation that one 
> finds they have become a POC on some resource.
> So without out the annual check, those organizations will NOT have the 
> awareness and knowledge to resolve that issue between themselves.
>  
> The solution is a bi-directional check.  
>  
> I think the ARIN objection is that it is problematic for the SWIPee to modify 
> the record of the SWIPer.
> But I see no problem with the SWIPee getting notified, or even ACKing or 
> NACKIing the SWIP.
>  
> __Jason
>  
>  
>  
> On Sat, Apr 14, 2018 at 2:23 PM Christian Tacit <[email protected] 
> <mailto:[email protected]>> wrote:
> Hi Jason,
>  
> Although I did look into the issue raised by your March 15 email promptly 
> after receiving it. I inadvertently forgot to reply to you. Please accept my 
> apology.
>  
> Based on ARIN Staff input, a major impediment to the proposed Section 3.8 is 
> that ARIN cannot be involved in the contractual relationship between its 
> customer and any of the customer’s customers. The ARIN customer may be 
> submitting a simple reassignment, precisely because it wants to maintain 
> control over POC records. Examples may include branches located in different 
> states of an entity that may want to use address information corresponding to 
> its  head office and or other locations in which it has a presence. If there 
> is a dispute with an entity that already has an OrgID with ARIN and its 
> upstream provider on how to register the entity’s reassignments, those 
> organizations will have the awareness and knowledge to resolve that issue 
> between themselves. 
>  
> Chris
>  
> From: Jason Schiller <[email protected] <mailto:[email protected]>> 
> Sent: March 15, 2018 4:29 PM
> To: Christian Tacit <[email protected] <mailto:[email protected]>>
> Cc: [email protected] <mailto:[email protected]>
> Subject: Re: [arin-ppml] Draft Policy 2017-12: Require POC Validation Upon 
> Reassignment
>  
> This problem is not scoped only to with a new POC is created.
>  
> This was also supposed to be a check in 3.7 to insure a resource is not
> randomly SWIP'd to a pre-existing org.
>  
> 3.8 was intended to chatch when a resource is SWIP'd to a pre-existing org, 
> but that org ID is not used, and that org's address is put into a reassign 
> simple.
>  
> I don't see how this is not implementable..
>  
> - If the compnay name is a match for something ARIN already has a 
> relationship with,
>   then they should have good contact info.
>  
> - If the contact info is a known address of a compnay that ARIN already has a 
>   relationship with, then they should have good contact info for that compnay.
>  
> - If all else fails they can send a post card to the mailing address.
>  
> At a mimimum, if the post card is undeliverable, or a holder of the the post 
> card
> contacts ARIN, they should revoke the SWIP.
>  
> ___Jason
>  
>  
>  
>  
>  
>  
> On Mon, Mar 12, 2018 at 5:47 PM, Christian Tacit <[email protected] 
> <mailto:[email protected]>> wrote:
> Dear Community Members,
>  
> The shepherds for the Draft Policy 2017-12: Require POC Validation Upon 
> Reassignment, are making two changes to its text.
>  
> First, the problem statement is being expanded a bit to explain how POCs for 
> reassigned blocks can be assigned without the knowledge of the individuals so 
> assigned under the present policy.
>  
> Second, proposed section 3.8 has been deleted. This is because it is 
> unintentionally misleading because a simple reassignment results in a 
> customer identifier versus an OrgID.   There is no contact information 
> contained in a simple reassignment other than street address that could be 
> used for notification, and thus it does not appear that the proposed NRPM 3.8 
> policy text is implementable.  Even if notification were possible, the “OR 
> postal address” in this section may also cause significant problems for some 
> companies as many companies have the same name associated with many different 
> locations and there are several locations that have many companies registered 
> there.
>  
> Based on these changes, the revised text reads:
>  
> Version Date: March 12, 2018
>  
> Problem Statement:
> Some large ISPs assign individuals to be POCs for reassigned blocks without 
> consultation of the individual they are inserting into Whois. For example, 
> during the reassignment/reallocation process, some large ISPs automatically 
> create POCs from their customer’s order form. This process is automated for 
> many ISPs and therefore the resulting POCs are not validated prior to being 
> created in the ARIN Whois database. This creates unknowing POCs that have no 
> idea what Whois is or even who ARIN is at the time they receive the annual 
> POC validation email. It can also create multiple POCs per email address 
> causing that same person to receive a multitude of POC Validation emails each 
> year.
> 
> This policy proposal seeks to improve the situation where a POC is 
> unwittingly and unintentionally 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 one new section 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.
> 
>  
> Timetable for implementation: Immediate
>  
> Comments from the community are welcome!
>  
> 
> Christian S. Tacit
> 
>  
> 
> _______________________________________________
> PPML
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> 
>  
> --
> _______________________________________________________
> Jason Schiller|NetOps|[email protected] 
> <mailto:[email protected]>|571-266-0006
>  
> 
>  
> --
> _______________________________________________________
> Jason Schiller|NetOps|[email protected] 
> <mailto:[email protected]>|571-266-0006
>  
> 
> 
> 
> _______________________________________________
> PPML
> You are receiving this message because you are subscribed to
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> 
> -- 
> John Santos
> Evans Griffiths & Hart, Inc.
> 781-861-0670 ext 539
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>  
> -- 
> _______________________________________________________
> Jason Schiller|NetOps|[email protected] 
> <mailto:[email protected]>|571-266-0006
>  
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