[arin-ppml] Draft Policy ARIN-2021-4: Clarifications to Sections 8.3, 8.4 and 8.5.6

[Alyssa Quinn]

Hi all,

Resurrecting this after many weeks. We've reviewed all the comments and
have netted out with the following. Thoughts?

*Add the ****text between asterisks**** to 8.1*



*8.1. PrinciplesNumber resources are nontransferable and are not assignable
to any other organization unless ARIN has expressly and in writing approved
a request for transfer. ARIN is tasked with making prudent decisions on
whether to approve the transfer of number resources. ****Only IPv4
addresses or ASNs are transferable, except where explicitly permitted
otherwise. The different number resource types are considered separately
and independently for the purposes of transfers.*****




*Then we'd dispense with the "IPv4 addresses and/or ASN
resources" awkwardness and just say "IPv4 addresses or ASNs." The updated
proposal language would look like this:In section 8.3, Replace*

*“In addition to transfers under section 8.2, IPv4 number resources and
ASNs may be transferred according to the following conditions.”*
*with*

*“In addition to transfers under section 8.2, IPv4 numbers or ASNs may be
transferred according to the following conditions.”*

*Replace*

*“The source entity must be the current registered holder of the IPv4
address resources, and not be involved in any dispute as to the status of
those resources.”*

with

*“The source entity must be the current registered holder of the IPv4
addresses or ASNs and not be involved in any dispute as to the status of
those resources.”*



*In Section 8.4:*

*Replace*


*“Inter-regional transfers of IPv4 number resources and ASNs may take place
only via RIRs who agree to the transfer and share reciprocal, compatible
needs-based policies.”*
*with*

*“Inter-regional transfers of IPv4 addresses or ASNs may take place only
via RIRs who agree to the transfer and share reciprocal, compatible
needs-based policies.”*

*Replace*

*“The source entity must be the current rights holder of the IPv4 address
resources recognized by the RIR responsible for the resources, and not be
involved in any dispute as to the status of those resources.”*

*with*

“The source entity must be the current rights holder of the IPv4 addresses
or ASN recognized by the RIR responsible for the resources, and not be
involved in any dispute as to the status of those resources.”


*In Section 8.5.6:*
*Replace*

*“Organizations with direct assignments or allocations from ARIN must have
efficiently utilized at least 50% of their cumulative IPv4 address blocks
in order to receive additional space. This includes all space reassigned to
their customers.”*

*with*

“Organizations with direct assignments or allocations from ARIN must have
efficiently utilized at least 50% of their cumulative IPv4 address blocks
in order to receive additional IPv4 space. This includes all IPv4 space
reassigned to their customers.”

On Thu, Oct 21, 2021 at 9:19 PM Owen DeLong via ARIN-PPML <
arin-ppml at arin.net> wrote:

>
>
> On Oct 21, 2021, at 20:05 , David Farmer via ARIN-PPML <arin-ppml at arin.net>
> wrote:
>
> The problem I have with that is it strongly implies IPv6 isn’t ever
> transferable, even though it is through section 8.2.
>
>
> If IPv6 becomes more generally transferrable, then section 2 can be
> updated along side the other policy changes required.
>
> In terms of 8.2, IPv6 transferability under 8.2 is exceptional compared to
> other transfers, so I think it’s OK to note that
> exception as part of the language update in 8.2
>
>
> A few thoughts;
>
> 1. Adding that resource types are considered “separately and
> independently”, should eliminate the need to use the awkward “and/or”
> construction, and we should be able to simply use “IPv4 addresses or ASNs”
> without confusion following that statement. I’d prefer to do this is
> section 8.1 instead of section 2. So it isn’t disconnected from section 8
> where it is important to understand.
>
>
> Personally, I don’t see a significant difference between inclusive or
> (and/or) and phrasing elsewhere that clarifies that the or is inclusive
> followed by use of the normally exclusive or.
>
> I do think that the global definition in section 2 for “transferable
> resources” (or if you have a better choice of terms, go for it, but some
> term that identifies IPv4 + ASNs and not IPv6 currently).
>
> I still like making the clarification that each resource type is
> considered separately for each transfer.
>
> 2. Rather than defining “transferable resources” in section 2, how about
> saying “only IPv4 addresses or ASNs are transferable, except where
> explicitly noted otherwise,” again in section 8.1, for similar reason as
> above. Then add “including IPv6” in the heading to section 8.2, making it
> clear that IPv6 is included for section 8.2 transfers, and only section 8.2.
>
>
> How about section 2 defining “Transferable resources" as “IPv4 addresses
> and ASNs, except where specifically noted otherwise” and then proceeding
> apace?
>
> 3. In sections 8.3 and 8.4, either just simply say “number resources”,
> with the above clearly scoping that to IPv4 addresses or ASNs. Or, say “ IPv4
> addresses or ASNs”, without the awkward “and/or” construction. I prefer
> using just “number resources”, as I think it is simpler and cleaner.
>
>
> I don’t find and/or any more awkward than or, so I’m not convinced that’s
> really an issue. I don’t like just using “number resources” in a place
> where we don’t intend IPv6 because it’s not the plain language meaning of
> the term.
>
> 4. Where a clause only applies to “IPv4 addresses”, such as for block
> sizing, and the wait list, make sure they are explicitly scoped to IPv4.
>
>
> I think that’s already generally the case.
>
> Owen
>
>
> Thanks.
>
> On Thu, Oct 21, 2021 at 21:06 Chris Woodfield <chris at semihuman.com> wrote:
>
>> I think Joe’s got a good suggestion that I would support - define
>> “transferable number resources” as IPv4 addresses and ASNs in Section 2,
>> and go from there.
>>
>> -C
>>
>> On Oct 21, 2021, at 5:39 PM, Martin Hannigan <hannigan at gmail.com> wrote:
>>
>>
>>
>> On Thu, Oct 21, 2021 at 14:53 Chris Woodfield <chris at semihuman.com>
>> wrote:
>>
>>> I support this edit, for same reasons others have mentioned.
>>>
>>> If I’m recalling yesterday’s presentation correctly, it was ARIN Staff
>>> and Legal, not the AC, that determined that this language could not be
>>> implemented an editorial change, so that’s not up for debate here.
>>>
>>> One possible adjustment that I’d like to suggest is that the term “IPv4
>>> and/or ASN resources” seems a bit awkward, given how many times it appears
>>> in the section. Perhaps we could add a new section that incorporates
>>> David’s suggested language, but also handles the clarification of the
>>> definition of number resources in a single place, scoped to Section 8.
>>>
>>> So, a new Section 8.1.1, which I’d propose would be named “Definitions”,
>>> could read as follows:
>>>
>>>
>>> All references to “number resources" in this section, unless stated
>>> otherwise, refer to IPv4 addresses and/or ASN resources.
>>>
>>> When number resources of multiple types, including IPv6 resources, are
>>> transferred, each resource type is considered separately and independently,
>>> both for any conditions on their transferability and the application of any
>>> restrictions following a transfer.
>>>
>>>
>>> Following this, the other edits to Section 8 in the proposal can simply
>>> be changed to “number resources” to suit.
>>>
>>> Opinions?
>>>
>>> -C
>>>
>>
>> We’d be better off using defined terms. Easier to construct, but end up
>> being document global.
>>
>> Warm regards,
>>
>> -M<
>>
>>
>>
>>
>>>
>>> On Oct 21, 2021, at 11:23 AM, Martin Hannigan <hannigan at gmail.com>
>>> wrote:
>>>
>>>
>>> I agree with Owen re: the editorial nature of the changes. However, I
>>> support it moving forward. I don't support the Farmer suggestion. That is
>>> possibly a material change that should undergo the rigors of "the process"
>>> on its own.
>>>
>>> Warm regards,
>>>
>>> -M<
>>>
>>>
>>>
>>>
>>>
>>> On Thu, Oct 21, 2021 at 11:33 AM Owen DeLong via ARIN-PPML <
>>> arin-ppml at arin.net> wrote:
>>>
>>>> I support this amendment.
>>>>
>>>> Owen
>>>>
>>>>
>>>> On Oct 20, 2021, at 12:45 , David Farmer via ARIN-PPML <
>>>> arin-ppml at arin.net> wrote:
>>>>
>>>> I support this proposal as currently written.
>>>>
>>>> However, regarding Kevin Blumberg's comment at the ARIN 48 discussion
>>>> of this policy earlier today; How about adding a paragraph like the
>>>> following to section 8.1, Principles;
>>>>
>>>> When number resources of multiple types, IPv4, IPv6, and/or ASNs, are
>>>> transferred, each resource type is considered separately and independently,
>>>> both for any conditions on their transferability and the application of any
>>>> restrictions following a transfer.
>>>>
>>>>
>>>> Something like this added to Section 8.1, Principles, along with the
>>>> already proposed changes should eliminate any possibility of confusion in
>>>> this regard.
>>>>
>>>> Thanks
>>>>
>>>> On Tue, Aug 24, 2021 at 7:52 AM ARIN <info at arin.net> wrote:
>>>>
>>>>> On 19 August 2021, the ARIN Advisory Council (AC) accepted
>>>>> "ARIN-prop-299: Clarifications to Sections 8.3, 8.4 and 8.5.6" as a Draft
>>>>> Policy.
>>>>>
>>>>>
>>>>>
>>>>> Draft Policy ARIN-2021-4 is below and can be found at:
>>>>>
>>>>>
>>>>>
>>>>> https://www.arin.net/participate/policy/drafts/2021_4/
>>>>>
>>>>>
>>>>>
>>>>> 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/participate/policy/pdp/
>>>>>
>>>>>
>>>>>
>>>>> Draft Policies and Proposals under discussion can be found at:
>>>>>
>>>>> https://www.arin.net/participate/policy/drafts/
>>>>>
>>>>>
>>>>>
>>>>> Regards,
>>>>>
>>>>>
>>>>>
>>>>> Sean Hopkins
>>>>>
>>>>> Senior Policy Analyst
>>>>>
>>>>> American Registry for Internet Numbers (ARIN)
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>> Draft Policy ARIN-2021-4: Clarifications to Sections 8.3, 8.4 and
>>>>> 8.5.6
>>>>>
>>>>>
>>>>> Problem Statement:
>>>>>
>>>>>
>>>>>
>>>>> The current language in Sections 8.3 and 8.4 is not clear regarding
>>>>> ASN-only transactions as well as the term “number resources”. The current
>>>>> language in Section 8.5.7 is not clear with regard to additional IPv4 space.
>>>>>
>>>>>
>>>>>
>>>>> Policy statement:
>>>>>
>>>>>
>>>>>
>>>>> In Section 8.3:
>>>>>
>>>>>
>>>>>
>>>>> Replace
>>>>>
>>>>>
>>>>>
>>>>> “In addition to transfers under section 8.2, IPv4 numbers resources
>>>>> and ASNs may be transferred according to the following conditions.”
>>>>>
>>>>>
>>>>>
>>>>> with
>>>>>
>>>>>
>>>>>
>>>>> “In addition to transfers under section 8.2, IPv4 address and/or ASN
>>>>> resources may be transferred according to the following conditions.”
>>>>>
>>>>>
>>>>>
>>>>> Replace
>>>>>
>>>>>
>>>>>
>>>>> “The source entity must be the current registered holder of the IPv4
>>>>> address resources, and not be involved in any dispute as to the status of
>>>>> those resources.”
>>>>>
>>>>>
>>>>>
>>>>> with
>>>>>
>>>>>
>>>>>
>>>>> “The source entity must be the current registered holder of the IPv4
>>>>> address and/or ASN resources, and not be involved in any dispute as to the
>>>>> status of those resources.”
>>>>>
>>>>>
>>>>>
>>>>> In Section 8.4:
>>>>>
>>>>>
>>>>>
>>>>> Replace
>>>>>
>>>>>
>>>>>
>>>>> “Inter-regional transfers of IPv4 number resources and ASNs may take
>>>>> place only via RIRs who agree to the transfer and share reciprocal,
>>>>> compatible needs-based policies.”
>>>>>
>>>>>
>>>>>
>>>>> with
>>>>>
>>>>>
>>>>>
>>>>> “Inter-regional transfers of IPv4 addresses and/or ASN resources may
>>>>> take place only via RIRs who agree to the transfer and share reciprocal,
>>>>> compatible needs-based policies.”
>>>>>
>>>>>
>>>>>
>>>>> Replace
>>>>>
>>>>>
>>>>>
>>>>> “The source entity must be the current rights holder of the IPv4
>>>>> address resources recognized by the RIR responsible for the resources, and
>>>>> not be involved in any dispute as to the status of those resources.”
>>>>>
>>>>>
>>>>>
>>>>> with
>>>>>
>>>>>
>>>>>
>>>>> “The source entity must be the current rights holder of the IPv4
>>>>> address and/or ASN resources recognized by the RIR responsible for the
>>>>> resources, and not be involved in any dispute as to the status of those
>>>>> resources.”
>>>>>
>>>>>
>>>>>
>>>>> In Section 8.5.6:
>>>>>
>>>>>
>>>>>
>>>>> Replace
>>>>>
>>>>>
>>>>>
>>>>> “Organizations with direct assignments or allocations from ARIN must
>>>>> have efficiently utilized at least 50% of their cumulative IPv4 address
>>>>> blocks in order to receive additional space. This includes all space
>>>>> reassigned to their customers.”
>>>>>
>>>>>
>>>>>
>>>>> with
>>>>>
>>>>>
>>>>>
>>>>> “Organizations with direct assignments or allocations from ARIN must
>>>>> have efficiently utilized at least 50% of their cumulative IPv4 address
>>>>> blocks in order to receive additional IPv4 space. This includes all IPv4
>>>>> space reassigned to their customers.”
>>>>>
>>>>>
>>>>>
>>>>> Comments:
>>>>>
>>>>>
>>>>>
>>>>> These changes were originally included in ARIN-edit-2021-1. Staff and
>>>>> Legal review of ARIN-edit-2021-1 on June 14, 2021 indicated that some
>>>>> changes were not editorial in nature. The editorial changes went forward in
>>>>> ARIN-edit-2021-1 and the non-editorial changes are included here.
>>>>>
>>>>>
>>>>>
>>>>> Timetable for implementation: Immediate
>>>>>
>>>>>
>>>>> _______________________________________________
>>>>> ARIN-PPML
>>>>> You are receiving this message because you are subscribed to
>>>>> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
>>>>> Unsubscribe or manage your mailing list subscription at:
>>>>> https://lists.arin.net/mailman/listinfo/arin-ppml
>>>>> Please contact info at arin.net if you experience any issues.
>>>>>
>>>>
>>>>
>>>> --
>>>> ===============================================
>>>> David Farmer               Email:farmer at umn.edu
>>>> Networking & Telecommunication Services
>>>> Office of Information Technology
>>>> University of Minnesota
>>>> 2218 University Ave SE
>>>> <https://www.google.com/maps/search/2218+University+Ave+SE?entry=gmail&source=g>
>>>>       Phone: 612-626-0815
>>>> Minneapolis, MN 55414-3029   Cell: 612-812-9952
>>>> ===============================================
>>>> _______________________________________________
>>>> ARIN-PPML
>>>> You are receiving this message because you are subscribed to
>>>> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
>>>> Unsubscribe or manage your mailing list subscription at:
>>>> https://lists.arin.net/mailman/listinfo/arin-ppml
>>>> Please contact info at arin.net if you experience any issues.
>>>>
>>>>
>>>> _______________________________________________
>>>> ARIN-PPML
>>>> You are receiving this message because you are subscribed to
>>>> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
>>>> Unsubscribe or manage your mailing list subscription at:
>>>> https://lists.arin.net/mailman/listinfo/arin-ppml
>>>> Please contact info at arin.net if you experience any issues.
>>>>
>>> _______________________________________________
>>> ARIN-PPML
>>> You are receiving this message because you are subscribed to
>>> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
>>> Unsubscribe or manage your mailing list subscription at:
>>> https://lists.arin.net/mailman/listinfo/arin-ppml
>>> Please contact info at arin.net if you experience any issues.
>>>
>>>
>> _______________________________________________
>> ARIN-PPML
>> You are receiving this message because you are subscribed to
>> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
>> Unsubscribe or manage your mailing list subscription at:
>> https://lists.arin.net/mailman/listinfo/arin-ppml
>> Please contact info at arin.net if you experience any issues.
>>
> --
> ===============================================
> David Farmer               Email:farmer at umn.edu
> Networking & Telecommunication Services
> Office of Information Technology
> University of Minnesota
> 2218 University Ave SE        Phone: 612-626-0815
> Minneapolis, MN 55414-3029   Cell: 612-812-9952
> ===============================================
> _______________________________________________
> ARIN-PPML
> You are receiving this message because you are subscribed to
> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
> Unsubscribe or manage your mailing list subscription at:
> https://lists.arin.net/mailman/listinfo/arin-ppml
> Please contact info at arin.net if you experience any issues.
>
>
> _______________________________________________
> ARIN-PPML
> You are receiving this message because you are subscribed to
> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
> Unsubscribe or manage your mailing list subscription at:
> https://lists.arin.net/mailman/listinfo/arin-ppml
> Please contact info at arin.net if you experience any issues.
>
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