fwd ppml: ARIN asking about SWIP procedures

I thought folks in this forum might be interested in possibly
replying to the matter in this note from ppml, and got the author's
permission to forward it to this list. I'm trying to set the
Mail-Followup-To header on this note to the ppml@arin.net list, not
sure if I'm getting it right, but I think it would be appropriate if
any replies were directed to the ppml list, as that's what ARIN is
watching for this solicitation of public comment.

----- Forwarded message from ginny listman <ginny@arin.net> -----

Hi, my name is Ginny Listman. As of early December, I am the new Director
of Engineering here at ARIN. In a meeting yesterday, to discuss database
changes, the following policy issue came up.

Apparently, there have been some upstream ISPs that have assigned some
networks via SWIP, where later the downstream comes back saying it should
have been an allocation, ie they want a maintainer id so they can
assign/allocate further on down.

In most cases, RSG has been granting the downstream's wish, creating the
maintainer id, allowing them to further assign/allocate.

Many times, it is just a minor error in the SWIP template, and shouldn't
be a big deal. However, would there ever be a situation where the
upstream would not want the downstream to be assigning/allocating? Should
ARIN be responsible for notifying the upstream? We have be processing
these request because we do not want to delay the downstream's business.
Do we need a written policy to define how we should be processing such a

The upstream might not be all that fond of its customer reselling service,
and this may be taken into consideration by their contract, but the
downstream is going to dole out the space regardless of their ability to
SWIP subassignments. I would think that it's in ARIN's interest to foster
the maintenance of as accurate a database as possible, and leave quarrels
over type of service between a provider and its customers to the provider
and its customers. It's not the RIR's responsibility to enforce contract
terms between an ISP and its downstreams. Some mechanism should be provided
for the maintainer of a block (either directly obtained from ARIN or from an
upstream via SWIP) to list all allocations, assignments, suballocations, and
subassignments so that he or she can enforce contracts appropriately.

I'm personally glad that ARIN changes the status of blocks from assigned to
allocated and performs other active maintenance upon request. It's been of
direct value to me when upstreams do the wrong thing and assign instead of
allocate or set the wrong maintainer ID on an allocation. These are usually
misunderstandings, and getting them straigtened out would take weeks if done
through the provider.

All of that said, this can be taken to the logical extreme and the
distinction between allocations and assignments can be eliminated
altogether, and provider/maintainer IDs can be replaced purely with ARIN

Finally, the ability to submit assignment and allocation information via
rwhois seems like a license for inconsistency. Rwhois was a great idea that
never took off. It would be interesting if this information could be
provided by splintering off a new DNS class (or at least some new RR types.)
Has anyone ever considered this?