The proposed editorial changes do not conflict with the current language, nor 
do they present a conflict with the revised language that will occur if the 
board ratifies 2017-5. Staff can intelligently apply this update to the NRPM in 
either state without conflict or loss of fidelity in either case.

Owen

> On Nov 21, 2017, at 15:48 , [email protected] wrote:
> 
> For the same reason as stated in comments to ARIN-2017-10, this proposal 
> changes language in 6.5.5.1 which is before the ARIN Board regarding a change 
> of the standard from /64 or more to /47 or more, or any size individually 
> announced.
> 
> I suggest the author take into consideration the change of this section in 
> ARIN-2017-5 before the ARIN Board, before any changes to this section are 
> made.
> 
> 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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