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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