[arin-ppml] Draft Policy ARIN-2017-11: Reallocation and Reassignment Language Cleanup

[hostmaster at uneedus.com]

Recommended policy 2017-5 proposes changing the language in 6.5.5.1 from 
/64 or more to /47 or more.  According to an earlier email, this has been 
sent to the ARIN Board for adoption.

The editoral changes in this draft include cleanup of 6.5.5.1, without 
noting that the ARIN Board may soon change the standard from /64 or more 
to /47 or more.  I would not like to see this draft adopted as is, as it 
might be considered proposingg changing that standard back to /64 or more.

I propose that this draft make clear that it does not seek to change 
whatever the current standard is (/47 or /64) at the time of its adoption, 
but simply desires to modify the remaining editoral language in that 
section.

Albert Erdmann
Network Administrator
Paradise On Line Inc.


On Tue, 21 Nov 2017, ARIN wrote:

> On 16 November 2017, the ARIN Advisory Council (AC) advanced "ARIN-prop-246: 
> Reallocation and Reassignment Language Cleanup" to Draft Policy status.
>
> Draft Policy ARIN-2017-11 is below and can be found at:
> https://www.arin.net/policy/proposals/2017_11.html
>
> You are encouraged to discuss all Draft Policies on PPML. The AC will 
> evaluate the discussion in order to assess the conformance of this draft 
> policy with ARIN's Principles of Internet number resource policy as stated in 
> the Policy Development Process (PDP). Specifically, these principles are:
>
> * Enabling Fair and Impartial Number Resource Administration
> * Technically Sound
> * Supported by the Community
>
> The PDP can be found at:
> https://www.arin.net/policy/pdp.html
>
> Draft Policies and Proposals under discussion can be found at:
> https://www.arin.net/policy/proposals/index.html
>
> Regards,
>
> Sean Hopkins
> Policy Analyst
> American Registry for Internet Numbers (ARIN)
>
>
>
> Draft Policy ARIN-2017-11: Reallocation and Reassignment Language Cleanup
>
> Problem Statement:
>
> The current text of NRPM uses the terms ‘reallocate’ and ‘reassign’ 
> in ways that are both internally inconsistent within NRPM and inconsistent 
> with the definitions of Reassignments and Reallocations as fields within the 
> ARIN database. Frequently the term ‘reassignment’ or ‘reassign’ is 
> used in NRPM as an umbrella term for both reallocations and reassignments. As 
> a result, someone familiar with the ARIN Whois database, but unfamiliar with 
> history of particular portions of NRPM and their intended meaning may 
> interpret certain NRPM requirements as applying only to reassignments and not 
> to reallocations. This is particularly problematic when it comes to SWIP 
> requirements and the requirement to record reallocations and reassignments 
> with ARIN, which under current text could be read to only apply to 
> reassignments.
>
> Policy Statement:
>
> Make the following changes to the definitions in Section 2.5
>
> Current text:
>
> 2.5. Allocate and Assign
>
> A distinction is made between address allocation and address assignment, 
> i.e., ISPs are "allocated" address space as described herein, while end-users 
> are "assigned" address space.
>
> Allocate - To allocate means to distribute address space to IRs for the 
> purpose of subsequent distribution by them.
>
> Assign - To assign means to delegate address space to an ISP or end-user, for 
> specific use within the Internet infrastructure they operate. Assignments 
> must only be made for specific purposes documented by specific organizations 
> and are not to be sub-assigned to other parties.
>
> Proposed Editorial Change:
>
> 2.5 Allocation, Assignment, Reallocation, Reassignment
>
> Allocation - Address space delegated to an organization directly by ARIN for 
> the purpose of subsequent distribution by the recipient organization to other 
> parties.
>
> Assignment - Address space delegated to an organization directly by ARIN for 
> the exclusive use of the recipient organization.
>
> Reallocation - Address space sub-delegated to an organization by an upstream 
> provider for the purpose of subsequent distribution by the recipient 
> organization to other parties.
>
> Reassignment - Address space  sub-delegated to an organization by an upstream 
> provider for the exclusive use of the recipient organization.
>
> Make the following editorial changes to section 4.2:
>
> Current text:
>
> 4.2.1.1. Purpose
>
> ARIN allocates blocks of IP addresses to ISPs for the purpose of reassigning 
> that space to their customers.
>
> Proposed Editorial Change:
>
> 4.2.1.1. Purpose
>
> ARIN allocates blocks of IP addresses to ISPs for the purpose of reassigning 
> and reallocating that space to their customers.
>
> Current text:
>
> 4.2.3. Reassigning Address Space to Customers
>
> Proposed Editorial Change:
>
> 4.2.3. Reassigning and Reallocating Address Space to Customers
>
> Current Text:
>
> 4.2.3.1. Efficient utilization
>
> ISPs are required to apply a utilization efficiency criterion in providing 
> address space to their customers. To this end, ISPs should have documented 
> justification available for each reassignment. ARIN may request this 
> justification at any time. If justification is not provided, future receipt 
> of allocations may be impacted.
>
> Proposed Editorial Change:
>
> 4.2.3.1. Efficient utilization
>
> ISPs are required to apply a utilization efficiency criterion in providing 
> address space to their customers. To this end, ISPs should have documented 
> justification available for each reassignment and reallocation. ARIN may 
> request this justification at any time. If justification is not provided, 
> future receipt of allocations may be impacted.
>
> Current text:
>
> 4.2.3.4. Downstream customer adherence
>
> ISPs must require their downstream customers to adhere to the following 
> criteria:
>
> 4.2.3.4.1. Utilization
>
> Reassignment information for prior allocations must show that each customer 
> meets the 80% utilization criteria and must be available via SWIP / RWhois 
> prior to your issuing them additional space.
>
> Proposed Editorial Changes:
>
> 4.2.3.4. Downstream customer adherence
>
> ISPs must require their downstream customers to adhere to the following 
> criteria:
>
> 4.2.3.4.1. Utilization
>
> Reassignment and reallocation information for prior allocations must show 
> that each customer meets the 80% utilization criteria and must be available 
> via SWIP / RWhois prior to your issuing them additional space.
>
> Current text:
>
> 4.2.3.5. ARIN approval of reassignments/reallocations
>
> 4.2.3.5.1. /18
>
> All extra-large ISPs making reassignments of a /18 or larger to a customer 
> must first have these reassignments reviewed and approved by ARIN.
>
> 4.2.3.5.2. /19
>
> Small to large ISPs making customer reassignments of a /19 or larger must 
> first seek ARIN's approval.
>
> Proposed Editorial Changes:
>
> 4.2.3.5. ARIN approval of reassignments/reallocations
>
> 4.2.3.5.1. /18
>
> All extra-large ISPs making reassignments or reallocations of a /18 or larger 
> to a customer must first have these reassignments or reallocations reviewed 
> and approved by ARIN.
>
> 4.2.3.5.2. /19
>
> Small to large ISPs making customer reassignments or reallocations of a /19 
> or larger must first seek ARIN's approval.
>
> Current text:
>
> 4.2.3.7.1. Reassignment Information
>
> 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.
>
> Proposed Editorial Changes:
>
> 4.2.3.7.1. Reassignment and Reallocation Information
>
> Each IPv4 reassignment or reallocation 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 and 
> reallocation registrations shall include each client's organizational 
> information, except where specifically exempted by this policy.
>
> Current text:
>
> 4.2.3.7.2.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.
>
> Proposed Editorial Changes:
>
> 4.2.3.7.2.Reassignments and Reallocations visible within 7 days
>
> All reassignments and reallocations shall be made visible as required in 
> section 4.2.3.7.1 within seven calendar days of reassignment or reallocation.
>
> Current text:
>
> 4.2.4. ISP Additional Requests
>
> 4.2.4.1. Utilization percentage (80%)
>
> ISPs must have efficiently utilized all allocations, in aggregate, to at 
> least 80% and at least 50% of every allocation in order to receive additional 
> space. This includes all space reassigned to their customers.
>
> Proposed Editorial Changes:
>
> 4.2.4. ISP Additional Requests
>
> 4.2.4.1. Utilization percentage (80%)
>
> ISPs must have efficiently utilized all allocations, in aggregate, to at 
> least 80% and at least 50% of every allocation in order to receive additional 
> space. This includes all space reassigned or reallocated to their customers.
>
> Make the following editorial changes to section 6 to clarify language 
> regarding current practices and requirements for reallocations and 
> reassignments, and specifically to clarify that recording reallocation 
> information is required where current language is ambiguous:
>
> Current text:
>
> 6.5.2.1(e) Initial Allocations to LIRs, Size
>
> For purposes of the calculation in (c), an LIR which has subordinate LIRs 
> shall make such allocations according to the same policies and criteria as 
> ARIN. In such a case, the prefixes necessary for such an allocation should be 
> treated as fully utilized in determining the block sizing for the parent LIR. 
> LIRs which do not receive resources directly from ARIN will not be able to 
> make such allocations to subordinate LIRs and subordinate LIRs which need 
> more than a /32 shall apply directly to ARIN.
>
> Proposed Editorial Changes:
>
> 6.5.2.1(e) Initial Allocations to LIRs, Size
>
> For purposes of the calculation in (c), an LIR which has subordinate LIRs 
> shall make such reallocations according to the same policies and criteria as 
> ARIN. In such a case, the prefixes necessary for such a reallocation should 
> be treated as fully utilized in determining the block sizing for the parent 
> LIR. LIRs which do not receive resources directly from ARIN will not be able 
> to make such reallocations to subordinate LIRs and subordinate LIRs which 
> need more than a /32 shall apply directly to ARIN.
>
> Current text:
>
> 6.5.2.2. Qualifications
>
> An organization qualifies for an allocation under this policy if they meet 
> any of the following criteria:
>
> a. Have a previously justified IPv4 ISP allocation from ARIN or one of its 
> predecessor registries or can qualify for an IPv4 ISP allocation under 
> current criteria.
>
> b. Are currently multihomed for IPv6 or will immediately become multihomed 
> for IPv6 using a valid assigned global AS number.
>
> In either case, they will be making reassignments from allocation(s) under 
> this policy to other organizations.
>
> Provide ARIN a reasonable technical justification indicating why an 
> allocation is necessary. Justification must include the intended purposes for 
> the allocation and describe the network infrastructure the allocation will be 
> used to support. Justification must also include a plan detailing anticipated 
> assignments to other organizations or customers for one, two and five year 
> periods, with a minimum of 50 assignments within 5 years.
>
> Proposed Editorial Changes:
>
> 6.5.2.2. Qualifications
>
> An organization qualifies for an allocation under this policy if they meet 
> any of the following criteria:
>
> a. Have a previously justified IPv4 ISP allocation from ARIN or one of its 
> predecessor registries or can qualify for an IPv4 ISP allocation under 
> current criteria.
>
> b. Are currently multihomed for IPv6 or will immediately become multihomed 
> for IPv6 using a valid assigned global AS number.
>
> In either case, they will be making reassignments or reallocations from 
> allocation(s) under this policy to other organizations.
>
> Provide ARIN a reasonable technical justification indicating why an 
> allocation is necessary. Justification must include the intended purposes for 
> the allocation and describe the network infrastructure the allocation will be 
> used to support. Justification must also include a plan detailing anticipated 
> reassignments and reallocations to other organizations or customers for one, 
> two and five year periods, with a minimum of 50 assignments within 5 years.
>
> Current text:
>
> 6.5.4. Assignments from LIRs/ISPs
>
> Assignments to end users shall be governed by the same practices adopted by 
> the community in section 6.5.8 except that the requirements in 6.5.8.1 do not 
> apply.
>
> Proposed Editorial Changes:
>
> 6.5.4. Reassignments from LIRs/ISPs
>
> Reassignments to end users shall be governed by the same practices adopted by 
> the community in section 6.5.8 except that the requirements in 6.5.8.1 do not 
> apply.
>
> Current text:
>
> 6.5.4.1. Assignment to operator's infrastructure
>
> An LIR may assign up to a /48 per PoP as well as up to an additional /48 
> globally for its own infrastructure.
>
> Proposed Editorial Changes:
>
> 6.5.4.1. Reassignment to operator's infrastructure
>
> An LIR may reassign up to a /48 per PoP as well as up to an additional /48 
> globally for its own infrastructure.
>
> Current text:
>
> 6.5.5. Registration
>
> ISPs are required to demonstrate efficient use of IP address space 
> allocations by providing appropriate documentation, including but not limited 
> to assignment histories, showing their efficient use.
>
> Proposed Editorial Changes:
>
> 6.5.5. Registration
>
> ISPs are required to demonstrate efficient use of IP address space 
> allocations by providing appropriate documentation, including but not limited 
> to reassignment and reallocation histories, showing their efficient use.
>
> Current text:
>
> 6.5.5.1. Reassignment information
>
> Each static IPv6 assignment containing a /64 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.
>
> Proposed Editorial Changes:
>
> 6.5.5.1. Reassignment information
>
> Each static IPv6 reassignment or reallocation containing a /64 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 and reallocation registrations shall include each client's 
> organizational information, except where specifically exempted by this 
> policy.
>
> Current text:
>
> 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
>
> Proposed Editorial Changes:
>
> 6.5.5.2. Reassignments and Reallocations visible within 7 days
>
> All reassignments and reallocations shall be made visible as required in 
> section 4.2.3.7.1 within seven calendar days of reassignment or reallocation.
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