[arin-ppml] Revised - Draft Policy ARIN-2022-12: Direct Assignment Language Update

Wed Feb 21 09:46:26 EST 2024

Tyler –

My apologies, I misstated my 4.4/4.10 response, corrected below (with emphasis on the correction):

Re: 4.4/4.10 exclusion: Current practice already excludes holders of space under these sections from _being counted_ from getting on the waitlist, so this would not change that. My understanding is that staff will attempt to redirect applicants for waitlist space to 4.4 or 4.10 as a more rapid alternative than the multi-year waitlist queue, since 4.4 and 4.10 allocations can happen immediately.

Basically, people with 4.4/4.10 space allocations are not restricted from making a waitlist request. The revised language is not intended to change that practice.

Thank you –

Doug

--
Douglas J. Camin
doug at dougcamin.com

From: ARIN-PPML <arin-ppml-bounces at arin.net> on behalf of Douglas Camin <doug at dougcamin.com>
Date: Wednesday, February 21, 2024 at 9:15 AM
To: arin-ppml at arin.net <arin-ppml at arin.net>
Subject: Re: [arin-ppml] Revised - Draft Policy ARIN-2022-12: Direct Assignment Language Update
Tyler –

Appreciate the input.

Re: “automatically”: Our (the shepherds) thought was that the word automatically was superfluous to the qualification, but I can see your point that it emphasizes the fact that no further justification is required. We’ll revisit adding this back in – thank you.

Re: 4.4/4.10 exclusion: Current practice already excludes holders of space under these sections from getting on the waitlist, so this would not change that. My understanding is that staff will attempt to redirect applicants for waitlist space to 4.4 or 4.10 as a more rapid alternative than the multi-year waitlist queue, since 4.4 and 4.10 allocations can happen immediately.

Hope that helps –

Doug

--
Douglas J. Camin
ARIN Advisory Council
doug at dougcamin.com

From: Tyler O'Meara <arin at tyleromeara.com>
Date: Tuesday, February 20, 2024 at 6:36 PM
To: Douglas Camin <doug at dougcamin.com>, arin-ppml at arin.net <arin-ppml at arin.net>
Subject: Re: [arin-ppml] Revised - Draft Policy ARIN-2022-12: Direct Assignment Language Update
Overall, I support this change as I think it resolves a common source of
confusion and helps to clean up legacy terminology and phrasing.

I did have a couple of comments:

In the change to section 4.2.2, the word "automatically" was dropped. I think
the "automatically" qualifier helps to get across the intent that an ISP/LIR may
obtain their first (IPv4) /24 without further justification being required.
Therefore, I would propose simply re-adding automatically in the first
statement, so that section 4.2.2 now reads:

“All ISP organizations without any IPv4 addresses from ARIN automatically
qualify for an initial allocation of a /24. ISPs providing a 24-month
utilization plan for the request size specified may receive up to a /22. ISPs
holding re-allocations and/or reassignments must show the efficient utilization
of their resources consistent with the requirements in sections 4.2.3 and
4.2.4.”

Second, and this applies to other sections as well, the new phrasing seems to
imply that an organization holding special use IPv4 addresses (via 4.4 or 4.10)
would not be eligible for the automatic general purpose /24 justification. I
think enforcing such a policy would be counter-productive, as for example it may
discourage an organization from requesting and using 4.10 space (for IPv6
transition) until they had been allocated their general purpose block.

Tyler
AS53727

On Tue, 2024-02-20 at 19:39 +0000, Douglas Camin wrote:
>
>
> Hello PPML –
>
> Resurfacing this email about policy 2022-12 which got revised language as
> outlined below, in case it was originally lost in the mix of other
> discussions. Welcome any feedback (or none), as appropriate.
>
> Thank you!
>
>
> Doug
>
>
>
>
> --
> Douglas J. Camin
> ARIN Advisory Council
> doug at dougcamin.com
>
>
>
>
> From:Douglas Camin <doug at dougcamin.com>
> Date: Thursday, February 1, 2024 at 3:23 PM
> To: arin-ppml at arin.net <arin-ppml at arin.net>
> Subject: Re: Revised - Draft Policy ARIN-2022-12: Direct Assignment Language
> Update
>
> Howdy Community –
>
> As the lead shepherd on this policy, I wanted to provide some additional
> information about the most recent changes to this draft.
>
>  * At ARIN52 in October, and on PPML in the few weeks prior to that meeting,
> feedback was received about the revisions in this draft policy to the
> definitions of “Allocation” and “Assignment.” Taking the feedback into
> account, we revised this update to retain the original definitions in their
> entirety and only add that allocations can now apply to end-user organizations
> (that is, organizations only using the resources internally) and that
> assignments is a deprecated term.
>  * There was a question about scoping changes because prior revisions had
> removed the “from ARIN” delineation when defining the origin of the resources
> the policy considers. An earlier draft had removed the “from ARIN” references
> as part of the Staff and Legal recommendation. After further consultation with
> legal and considering the feedback received, it was determined that should go
> back in.
>
> The rest of the draft remains unchanged from the original revisions previously
> presented.
>
> Hope that helps –
>
>
> Doug
>
>
>
> --
> Douglas J. Camin
> ARIN Advisory Council
> doug at dougcamin.com
>
>
>
>
> From:ARIN-PPML <arin-ppml-bounces at arin.net> on behalf of ARIN <info at arin.net>
> Date: Thursday, February 1, 2024 at 1:53 PM
> To: arin-ppml at arin.net <arin-ppml at arin.net>
> Subject: [arin-ppml] Revised - Draft Policy ARIN-2022-12: Direct Assignment
> Language Update
>
> The following Draft Policy has been revised:
>
> * ARIN-2022-12: Direct Assignment Language Update
>
> Revised text is below and can be found at:
>
> https://na01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.arin.net%2Fparticipate%2Fpolicy%2Fdrafts%2F2022_12%2F&data=05%7C02%7C%7C6ec648f1170746b9b93808dc326cc7f6%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C638440689995037405%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C0%7C%7C%7C&sdata=ZReYXwDa6IEtHgLH8YCW8rR5EpleO1ADjf7YBth22YM%3D&reserved=0<https://www.arin.net/participate/policy/drafts/2022_12/>
>
> You are encouraged to discuss all Draft Policies on PPML. The AC will evaluate
> the discussion 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://na01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.arin.net%2Fparticipate%2Fpolicy%2Fpdp%2F&data=05%7C02%7C%7C6ec648f1170746b9b93808dc326cc7f6%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C638440689995047677%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C0%7C%7C%7C&sdata=MS%2F7XuCjJ9a3tAf5HTL7iQvLVXoWEG13%2FcybqmGOrN0%3D&reserved=0<https://www.arin.net/participate/policy/pdp/>
>
> Draft Policies and Proposals under discussion can be found at:
>
> https://na01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.arin.net%2Fparticipate%2Fpolicy%2Fdrafts%2F&data=05%7C02%7C%7C6ec648f1170746b9b93808dc326cc7f6%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C638440689995053745%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C0%7C%7C%7C&sdata=KDO4oEsuHXaSiF7JXSGuNnU21%2BMe5XJUIp2I%2BD6Btp4%3D&reserved=0<https://www.arin.net/participate/policy/drafts/>
>
>
> Regards,
>
> Eddie Diego
> Policy Analyst
> American Registry for Internet Numbers (ARIN)
>
>
>
> Problem Statement:
>
> As a result of ARIN's fee harmonization direct assignments are no longer being
> utilized within ARIN databases therefore language around that has been
> deprecated and should be modernized and aligned with current ARIN practices.
>
> Policy Statement:
>
> Section 2.5:
>
> Update definition of Allocation and Assignment to reflect current practice.
>
>
> FROM:
>
> “Allocation - IP addresses delegated to an organization directly by ARIN for
> the purpose of subsequent distribution by the recipient organization to other
> parties.
>
> Assignment - IP addresses delegated to an organization directly by ARIN for
> the exclusive use of the recipient organization.”
>
>
> TO:
>
> “Allocation - IP addresses issued directly by ARIN to an organization for the
> purpose of subsequent distribution by the recipient organization to other
> parties or the exclusive use of the recipient organization.
>
> Assignment - IP addresses delegated to an organization directly by ARIN for
> the exclusive use of the recipient organization. [Note: The use of assignment
> as a differentiating term has been deprecated. Assignment should instead be
> read as Allocation.]”
>
>
> Section 2.6:
>
> Change “receiving assignments of” to “allocated.”
>
>
> FROM:
>
> “2.6 End User
>
> An end-user is an organization receiving assignments of IP addresses
> exclusively for use in its operational networks.”
>
> TO:
>
> “2.6 End User
>
> An end-user is an organization allocated IP addresses exclusively for use in
> its operational networks.”
>
>
> Section 2.8
>
> Change “allocated or assigned” to “allocated.”
>
> FROM:
>
> “2.8. Registration Services Agreement (RSA)
>
> Number resources allocated or assigned by ARIN under these policies are
> subject to a contractual agreement between ARIN and the resource holder.
> Throughout this document, any and all forms of this agreement, past or future,
> are simply referred to as the Registration Services Agreement (RSA).”
>
> TO:
>
> “2.8. Registration Services Agreement (RSA)
>
> Internet number resources allocated by ARIN under these policies are subject
> to a contractual agreement between ARIN and the resource holder. Throughout
> this document, any and all forms of this agreement, past or future, are simply
> referred to as the Registration Services Agreement (RSA).”
>
>
> Section 3.6.3:
>
> Change paragraph 1 text
>
> FROM: “This policy applies to every Organization that has a direct assignment,
> direct allocation, or AS number from ARIN”
>
> TO: “This policy applies to every Organization that has Internet number
> resources issued by ARIN"
>
> RESULT: “This policy applies to every Organization that has Internet number
> resources issued by ARIN (or one of its predecessor registries) or a
> reallocation from an upstream ISP. This includes but is not limited to
> upstream ISPs and their downstream ISP customers (as defined by NRPM 2.5 and
> 2.6), but not reassignments made to their downstream end user customers.”
>
>
> Section 4.2.2:
>
> Replace text as follows
>
> FROM: “All ISP organizations without direct assignments or allocations from
> ARIN qualify for an initial allocation of up to a /22, subject to ARIN’s
> minimum allocation size.
>
> All ISP organizations without direct allocations, direct assignments, re-
> allocations or reassignments automatically qualify for a /24. These
> organizations are exempt from requirements of showing the efficient
> utilization of previously held IPv4 space. These organizations may qualify for
> a larger than a /24 by documenting how the requested allocation will be
> utilized within the request size specified in 4.2.4.3.
>
> ISPs holding re-allocations and/or reassignments must show the efficient
> utilization of their resources consistent with the requirements in sections
> 4.2.3 and 4.2.4.”
>
> TO: “All ISP organizations without any IPv4 addresses from ARIN qualify for
> an initial allocation of a /24. ISPs providing a 24-month utilization plan for
> the request size specified may receive up to a /22. ISPs holding re-
> allocations and/or reassignments must show the efficient utilization of their
> resources consistent with the requirements in sections 4.2.3 and 4.2.4.”
>
>
> Section 4.3.2:
>
> Change paragraph 1 text
>
> FROM: "End-user organizations without direct assignments or allocations from
> ARIN qualify for an initial assignment of ARIN’s minimum assignment size.”
>
> TO: “End-user organizations without an IPv4 allocation from ARIN qualify for
> an initial allocation of ARIN’s minimum allocation size.”
>
>
> Section 6.5.8:
>
> Change section title
>
> FROM: “Direct Assignments from ARIN to End-user Organizations”
>
> TO: “End-user Allocations”
>
>
> Section 8.5.4: 
>
> Change section text 
>
> FROM: “Organizations without direct assignments or allocations from ARIN
> qualify for transfer of an initial IPv4 block of ARIN’s minimum transfer
> size.”
>
> TO: “Organizations without an IPv4 allocation from ARIN qualify for transfer
> of an initial IPv4 allocation of ARIN’s minimum transfer size.”
>
>
> Section 8.5.6: 
>
> Change section text 
>
> FROM: “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 addresses. This includes all IPv4 space
> reassigned to their customers.”
>
> TO: “Organizations with an IPv4 allocation from ARIN must have efficiently
> utilized at least 50% of their cumulative IPv4 address blocks in order to
> receive additional IPv4 addresses. This includes all IPv4 space reallocated
> and/or reassigned to their customers.”
>
>
>
>
>
>
>
> _______________________________________________
> ARIN-PPML
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