Reading these changes, the majority of these proposed updates appear strictly 
editorial, but a few appear to at least have the potential to have an effect on 
policy, however subtle, as references to ASNs are being added in a few places 
where it wasn’t before, replacing the term “IPv4 address resources” had been 
used prior - a term could be interpreted as to *not* include ASNs. 

That said, these changes appear to be a positive clarification of the existing 
policy, and as such, I support as written.

Thanks,

-Chris

> On Mar 9, 2021, at 12:45 PM, ARIN <[email protected]> wrote:
> 
> On 18 February 2021, the ARIN Advisory Council (AC) accepted "ARIN-prop-296: 
> ASN Clarifications to Sections 2, 8 and 10" as a Draft Policy.
>  
> Draft Policy ARIN-2021-1 is below and can be found at:
>  
> https://www.arin.net/participate/policy/drafts/2021_1/ 
> <https://www.arin.net/participate/policy/drafts/2021_1/>
>  
> 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/ 
> <https://www.arin.net/participate/policy/pdp/>
>  
> Draft Policies and Proposals under discussion can be found at:
> https://www.arin.net/participate/policy/drafts/ 
> <https://www.arin.net/participate/policy/drafts/>
>  
> Regards,
>  
> Sean Hopkins
> Senior Policy Analyst
> American Registry for Internet Numbers (ARIN)
>  
>  
>  
> Draft Policy ARIN-2021-1: ASN Clarifications to Sections 2, 8 and 10
>  
> Problem Statement: 
>  
> The community has raised concerns that the current language in Section 8 is 
> not clear regarding ASN-only transactions. There are also some language and 
> reference inconsistancies which should be addressed while adjusting Section 8 
> and concordant adjustments to Sections 2 and 10.
>  
> Policy Statement: 
>  
> Add a definition for ASN in Section 2:
>  
> Section 2.X Autonomous System Number (ASN)
>  
> An Autonomous System Number (ASN) is a unique identifier which represents a 
> collection of network resources operated under a common routing policy 
> administration, known as an autonomous system.
>  
> In Section 8.2:
>  
> Replace
>  
> “The Internet number resources being transferred as part of an 8.2 transfer 
> will not be subject to a needs-based assessment during the process of the 8.2 
> transfer.”
>  
> with
>  
> “The Internet number resources being transferred as part of a transfer under 
> section 8.2 will not be subject to a needs-based assessment during the 
> process of the transfer.”
>  
> Replace
>  
> “The recipient must provide evidence that they have acquired the assets that 
> use the resources to be transferred from the current registrant.”
>  
> with
>  
> “The recipient must provide evidence that it has acquired the assets that use 
> the resources to be transferred from the current registrant.”
>  
> Replace
>  
> “The recipient must show that they have acquired the entire entity which is 
> the current registrant.”
>  
> with
>  
> “The recipient must show that it has acquired the entire entity which is the 
> current registrant.”
>  
> Replace
>  
> “An organization which serves as the source of an 8.2 IPv4 transfer will not 
> be allowed to apply for IPv4 address space under section 4.1.8 ARIN Waitlist 
> for a period of 36 months following said transfer unless the recipient 
> organization remains a subsidiary, parent company, or under common ownership 
> with the source organization.”
>  
> with
>  
> “An organization which serves as the source of an IPv4 transfer under section 
> 8.2 will not be allowed to apply for IPv4 address space under section 4.1.8 
> ARIN Waitlist for a period of 36 months following said transfer unless the 
> recipient organization remains a subsidiary, parent company, or under common 
> ownership with the source organization.”
>  
> 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.”
>  
> Replace
>  
> “Number resources received as the result of an 8.2 transfer are out of scope 
> for the purposes of this restriction.”
>  
> with
>  
> “Number resources received as the result of a transfer under section 8.2 are 
> out of scope for the purposes of this restriction.”
>  
> 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.”
>  
> Replace
>  
> “Source entities within the ARIN region must not have received a transfer, 
> allocation, or assignment of IPv4 number resources from ARIN for the 12 
> months prior to the approval of a transfer request, unless either the source 
> or recipient entity owns or controls the other, or both are under common 
> ownership or control. Number resources received as the result of an 8.2 
> transfer are out of scope for the purposes of this restriction.”
>  
> with
>  
> “Source entities within the ARIN region must not have received a transfer, 
> allocation, or assignment of IPv4 addresses from ARIN for the 12 months prior 
> to the approval of a transfer request, unless either the source or recipient 
> entity owns or controls the other, or both are under common ownership or 
> control. Number resources received as the result of a section 8.2 transfer 
> are out of scope for the purposes of this restriction.”
>  
> Add a space between “Section” and “4.4” in the fourth bullet under 
> “Conditions on source of the transfer”
>  
> 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.”
>  
> In Section 8.5.7:
>  
> Replace
>  
> “In lieu of 8.5.5 and 8.5.6, organizations may qualify for additional IPv4 
> address blocks by demonstrating 80% utilization of their currently allocated 
> space.”
>  
> with
>  
> “In lieu of the requirements in sections 8.5.5 and 8.5.6, organizations may 
> qualify for additional IPv4 address blocks by demonstrating 80% utilization 
> of their currently allocated space.”
>  
> Replace
>  
> “An organization may qualify via 8.5.7 for a total of a /16 equivalent in any 
> 6 month period.”
>  
> with
>  
> “An organization may qualify via section 8.5.7 for a total of a /16 
> equivalent in any 6 month period.”
>  
> In Section 10.3:
>  
> Replace
>  
> “This document describes the policy governing the allocation of Autonomous 
> System Numbers (ASNs) from the IANA to the Regional Internet Registries 
> (RIRs).”
>  
> with
>  
> “This document describes the policy governing the allocation of ASNs from the 
> IANA to the Regional Internet Registries (RIRs).”
>  
> Timetable for implementation: Immediate.
>  
> Anything else:
>  
> This proposal is intended to be purely editorial in nature
>  
> _______________________________________________
> ARIN-PPML
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