Re: [arin-ppml] Draft Policy ARIN-2024-5: Rewrite of NRPM Section 4.4 Micro-Allocation

[Douglas Camin]

Bill –

I think this is a valid point, though I do think both proposals are 
appropriate. The goals of 2024-4 and 5 are different, but the first bullet 
point in 2024-5 is fundamentally an IX definition. The other bullet points 
represent qualification criteria relevant to the allocation being considered. 
It makes sense to be written this way now because there is no IX definition in 
policy yet or until 2024-4 is completed.

One way to address this is to keep them moving together and in consideration of 
one another – 2024-5 relies on the 2024-4 definition and, if it is clear it 
will become adopted policy, 2024-5 references the new definition as part of the 
criteria rather than restate it.

Hope that helps –


Doug




--
Douglas J. Camin
ARIN Advisory Council
d...@dougcamin.com

From: ARIN-PPML  on behalf of Bill Woodcock 

Date: Friday, May 24, 2024 at 3:22 AM
To: arin-ppml 
Subject: Re: [arin-ppml] Draft Policy ARIN-2024-5: Rewrite of NRPM Section 4.4 
Micro-Allocation
This should be pointing out the obvious, but we need _either_ 2024-4 _or_ 
2024-5, but _definitely not both_.  That would be bad, having two different 
definitions that had to be kept synchronized.

I support having a stand-alone definition as in 2024-4, and removing all 
descriptive language from other uses of the phrase “Internet exchange” or “IX."

-Bill
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Re: [arin-ppml] Draft Policy ARIN-2024-5: Rewrite of NRPM Section 4.4 Micro-Allocation

[Douglas Camin]

+1 on using the more-specific term “Critical Internet Infrastructure” (as 
someone who spent time in government, where “Critical Infrastructure” is a 
broad ranging term.)

On the others, they seem reasonable as well.

Thank you –


Doug


--
Douglas J. Camin
ARIN Advisory Council
d...@dougcamin.com

From: ARIN-PPML  on behalf of Tyler O'Meara via 
ARIN-PPML 
Date: Wednesday, May 22, 2024 at 5:23 PM
To: arin-ppml@arin.net 
Subject: Re: [arin-ppml] Draft Policy ARIN-2024-5: Rewrite of NRPM Section 4.4 
Micro-Allocation
I support this change, but have a few suggestions:

1) I'd use Critical Internet Infrastructure (CII) as the official term for this
section; Critical Infrastructure seems a bit too vague.
2) Instead of "ARIN will reserve", should we change it to "ARIN has reserved",
since the reservation has already occurred and there's no intention in the
policy to keep the reserved block at a /15 equivalent?
3) Add the following sentence to the 2nd paragraph: "IP Addresses allocated
under this section must only be used for the operation of CII".
The current wording permits an operator of CII to use 4.4 space for any
purpose, which is likely not the intent.
4) In "Assigned addresses may be publicly reachable at the operators discretion
and be used to operate all of the Internet Exchange's infrastructure" replace
"operators" with "operator's".
5) Should we extend this policy to also cover legacy gTLD operators? It seems a
bit weird to call ".aq" Critical Internet Infrastructure, but not ".com", ".net"
or even ".arpa".

Tyler O'Meara
AS53727


On Tue, 2024-05-21 at 12:26 -0400, ARIN wrote:
> On 16 May 2024, the ARIN Advisory Council (AC) accepted “ARIN-prop-333:
> Rewrite of NRPM Section 4.4 Micro-Allocation” as a Draft Policy.
>
> Draft Policy ARIN-2024-5 is below and can be found at:
>
> https://na01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.arin.net%2Fparticipate%2Fpolicy%2Fdrafts%2F2024_5=05%7C02%7C%7Ca05623078f204ac3bbb308dc7aa55d85%7C84df9e7fe9f640afb435%7C1%7C0%7C638520097870111737%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C0%7C%7C%7C=%2FS%2F2T0PeDvhEw4fEB2x%2BuYa%2B4B1vpszi3iIqXsPCOGM%3D=0
>
> 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=05%7C02%7C%7Ca05623078f204ac3bbb308dc7aa55d85%7C84df9e7fe9f640afb435%7C1%7C0%7C638520097870120609%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C0%7C%7C%7C=2AjuZbVCfiga%2FoohPnDCml%2By0OuYH%2FjbevXrSACt9lA%3D=0
>
> 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=05%7C02%7C%7Ca05623078f204ac3bbb308dc7aa55d85%7C84df9e7fe9f640afb435%7C1%7C0%7C638520097870126655%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C0%7C%7C%7C=UB4ostT0JoyqMfMLRMl5ROb%2FH8mTfFSHw354cPp%2Bz1U%3D=0
>
> Regards,
>
> Eddie Diego
> Policy Analyst
> American Registry for Internet Numbers (ARIN)
>
>
> Draft Policy ARIN-2024-5: Rewrite of NRPM Section 4.4 Micro-Allocation
>
> Problem Statement:
>
> The current NRPM Section 4.4 language hasn’t aged well. As the ARIN 53 policy
> experience report demonstrated, 4.4 has also become difficult to implement by
> ARIN staff. Growth and use of Internet Exchanges has also changed. The
> overhaul seeks to improve technical soundness, respect the privilege of a
> dedicated pool and to more closely observe conservation principles using
> clear, minimum and enforceable requirements and underscoring the value of
> routability of assigned prefixes as required.
>
> ARIN 4.4 CI Assignments
>
> The intent of this policy is not to unreasonably preclude the use of an
> allocated or assigned prefix in servicing the needs of critical infrastructure
> of the Internet.
>
> ARIN will reserve a /15 equivalent of IPv4 address space for Critical
> Infrastructure (CI) of the Internet within the ARIN RIR service area.
> Assignments from this pool will be no smaller than a /24. Sparse allocation
> will be used whenever practical. CI includes Internet Exchanges, IANA
> authorized root servers, ccTLD operators, ARIN, and IANA. Addresses assigned
> from this pool may be revoked if no longer in use or not used for approved
> 

Re: [arin-ppml] Feedback on ARIN 53 question on micro-allocations for IXPs

[Douglas Camin]

Ryan –

Thanks so much for surfacing this discussion on PPML.

Reading through the responses from everyone, I think it’s clear there are use 
cases for IXPs to reasonably need a block of routable space for administrative 
purposes, particularly independent ones where there is no guaranteed sponsor 
pool to pull from. Ryan – did your IXP use a 4.4 allocation for the 
administrative prefix, or pull that from elsewhere?

I think a follow up question, from a policy perspective, would be: The policy 
(4.4) as written defines several critical infrastructure categories, but does 
not create a boundary for what services can run on those allocations. Does this 
create an avenue for abuse of this pool?

I think the example already shared of using this as a fast way to get v4 space 
to use as a CDN node seems like a good one – there may be a use case for it to 
exist on the member network, but using that IP for access for the Internet at 
large would appear (to me) to be in violation of the spirit of the policy and 
the reason for the allocation.

In the current setup, ARIN staff is almost certainly having to make 
interpretations and judgement calls, which leads to the additional question – 
does the community want more than that?

Thank you –


Doug


--
Douglas J. Camin
ARIN Advisory Council
d...@dougcamin.com

From: ARIN-PPML  on behalf of Ryan Woolley 

Date: Thursday, April 18, 2024 at 6:44 PM
To: arin-ppml@arin.net 
Subject: [arin-ppml] Feedback on ARIN 53 question on micro-allocations for IXPs
At ARIN 53, John Sweeting asked for clarification from the community on whether 
an internet exchange needs IP space beyond that used for the switching fabric, 
and whether IP allocations made to an IXP operator may need to be routable.  
Additionally, John shared a suggestion that the historical basis for 
maintaining a pool specific to IXPs was to enable the building of filters to 
prevent those addresses from being globally routable.

Community IX operates two IXPs, FL-IX in south Florida and CIX-ATL in Atlanta.  
FL-IX was founded in 2015 and now connects 158 member networks.  CIX-ATL began 
operations in 2019 and currently connects 66 member networks.

Both IXPs have been assigned IP address space from ARIN.  Each IXP uses one 
prefix for the member LAN, which is not announced outside of our members’ 
networks, and a second, routed, prefix for the IXP infrastructure.

The routed prefix supports operations critical to the operation of the 
exchange.  Our member portal, network management systems, and equipment 
loopback addresses are, by need and design, addressed in routable IP space.  
For example, route servers build filters based on ROAs and IRR databases, and 
configurations are replicated off-site.

Unlike an IXP affiliated with an ISP or data center operator, we have no line 
of business which would enable us to borrow IP space from, for example, a pool 
maintained for allocation to IP transit customers.  Our transit is provided as 
a donation by members, who may come or go as their connectivity needs require, 
so we cannot reasonably use non-provider-independent IP space.

On the second question of whether space reserved for IXP allocations should be 
unroutable as a feature, we have not, in our years of operation, encountered 
any issues with reachability for these allocations.  If networks are building 
filters for this purpose, our experience suggests that is not a common practice.

IXPs do commonly have a desire to prevent their member LAN prefix from being 
routable.  The current best practice is that this prefix is signed in RPKI with 
an origin ASN of zero (as described in RFC 6483), and Community IX does this 
for both our IXPs’ member LANs.  To the extent that filtering based on IP 
addressing may have been contemplated in the past, is it now obsoleted by RPKI.

Regards,

Ryan Woolley
Community IX
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Re: [arin-ppml] Revised - Draft Policy ARIN-2022-12: Direct Assignment Language Update

[Douglas Camin]

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
d...@dougcamin.com

From: ARIN-PPML  on behalf of Douglas Camin 

Date: Wednesday, February 21, 2024 at 9:15 AM
To: arin-ppml@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
d...@dougcamin.com

From: Tyler O'Meara 
Date: Tuesday, February 20, 2024 at 6:36 PM
To: Douglas Camin , arin-ppml@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 +, 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
> d...@dougcamin.com
>
>
>
>
> From:Douglas Camin 
> Date: Thursday, February 1, 2024 at 3:23 PM
> To: arin-ppml@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 fu

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

[Douglas Camin]

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
d...@dougcamin.com

From: Tyler O'Meara 
Date: Tuesday, February 20, 2024 at 6:36 PM
To: Douglas Camin , arin-ppml@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 +, 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
> d...@dougcamin.com
>
>
>
>
> From:Douglas Camin 
> Date: Thursday, February 1, 2024 at 3:23 PM
> To: arin-ppml@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
> d...@dougcamin.com
>
>
>
>
> From:ARIN-PPML  on behalf of ARIN 
> Date: Thursday, February 1, 2024 at 1:53 PM
> To: arin-ppml@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=05%7C02%7C%7C6ec648f1170746b9b93808dc326cc

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

[Douglas Camin]

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
d...@dougcamin.com

From: Douglas Camin 
Date: Thursday, February 1, 2024 at 3:23 PM
To: arin-ppml@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
d...@dougcamin.com

From: ARIN-PPML  on behalf of ARIN 
Date: Thursday, February 1, 2024 at 1:53 PM
To: arin-ppml@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://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://www.arin.net/participate/policy/pdp/

Draft Policies and Proposals under discussion can be found at:

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

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

[Douglas Camin]

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
d...@dougcamin.com

From: ARIN-PPML  on behalf of ARIN 
Date: Thursday, February 1, 2024 at 1:53 PM
To: arin-ppml@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://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://www.arin.net/participate/policy/pdp/

Draft Policies and Proposals under discussion can be found at:

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 

Re: [arin-ppml] Sections 6.4.1 and 6.4.2 - Potential Simplification (from the NRPM Working Group)

[Douglas Camin]

I think Owen’s feedback here is important and worth highlighting to potentially 
reinforce knowledge of that point – duplicative language likely exists in the 
NRPM because in the past it was pointed out that people reading the document 
had a hard time jumping around to piece together the full meaning of a 
particular section. So, effort was made to replicate language inline to meet 
that need. The pendulum is currently swinging the other way – we are discussing 
efforts to remove duplicative language because it is difficult to keep in sync 
administratively.

I bring this up not to take a stance one way or another but to point out that 
having a (relatively) agreed-to organizing principal on this concept will be 
helpful to the AC and anyone contributing policy suggestions.

Not entirely sure how to reflect that, but as a policy shepherd on the AC, it 
would be helpful.

Thanks –


Doug



--
Douglas J. Camin
ARIN Advisory Council
d...@dougcamin.com

From: ARIN-PPML  on behalf of Owen DeLong via 
ARIN-PPML 
Date: Tuesday, November 28, 2023 at 1:29 PM
To: Dale W. Carder 
Cc: Christian Tacit , arin-ppml@arin.net 

Subject: Re: [arin-ppml] Sections 6.4.1 and 6.4.2 - Potential Simplification 
(from the NRPM Working Group)



On Nov 28, 2023, at 10:23, Dale W. Carder  wrote:

Thus spake owen--- via ARIN-PPML 
(arin-ppml@arin.net) on Tue, Nov 21, 2023 at 
05:54:49PM -0800:



On Nov 20, 2023, at 12:59, Christian Tacit  wrote:

Dear ARIN Community Members,

In our continuing effort to simplify the NRPM, we are also considering the 
retirement of sections 6.4.1 and 6.4.2.

We believe that section 6.4.1 is out of scope since it constitutes a legal 
conclusion regarding IPv6 addresses not constituting property, rather than 
policy. Section 6.4.2 is a general statement regarding the lack of guarantee of 
the routability of address space and also provides that RIRs (and not just 
ARIN) “must apply procedures that reduce the possibility of fragmented address 
space which may lead to a loss of routability”. To the extent that this section 
validly articulates policy statements, it applies more broadly to both IPv4 and 
IPv6 resources, and the statement in the NRMP should only apply to ARIN. In 
fact, a proper routability constraint statement limited to ARIN is already 
embedded in Section 1.3 of the NRPM, and thus not needed in Section 6.”

Community feedback and any proposals to address these sections are welcome.”

All valid points. The legal conclusion can be left to the RSA or anywhere else 
ARIN’s lawyers which to stick it.

Removing it from the NRPM makes sense to me.

I agree.


6.4.2 needs to at least keep the following key details:
+ ARIN must apply procedures to minimize fragmentation of the address space
+ AIRN cannot guarantee that any block can be routed or will be accepted by any 
particular peer.

Since we don’t have a section of the policy manual for things that apply 
broadly to IPv4 and IPv6, we have, traditionally, duplicated them in sections 4 
and 6, which I think is fine. Preventing fragmentation in IPv4 is already a 
lost cause at this point, so it is what it is.

There's overlap between 6.4.2 and 6.3.4 to some degree on 
fragmentation/aggregation.

The routability aspect in 6.4.2 is also covered in 1.3.

So with respect to Owen's points above this stuff could be merged
together and retained.

Merged, yes, but 6.3.4 talks about the goal and desirability of reducing 
fragmentation. 6.4.2 makes it actual policy that staff must take the 
appropriate steps to do so.

In the past, ew’ve received feedback that depending on a statement far removed 
is confusing to consumers of the document, hence several places in the NRPM 
where text has been duplicated from section 1 into more specific sections 
(mostly 4, 5, and 6). I’m not opposed to reducing or eliminating that 
duplication, so long as we do so consciously and don’t just spin back the other 
way putting duplication back in place a few years later when we get the same 
feedback again.

Owen

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Re: [arin-ppml] AC Candidates

[Douglas Camin]

Fearghas –

Next year holding an ASN only will be considered a valid path to being a 
general voting member of ARIN, so this limitation will be removed.

See: https://www.arin.net/announcements/20230921/

Hope that helps –


Doug



--
Douglas J. Camin
ARIN Advisory Council
d...@dougcamin.com




--
Douglas J. Camin
d...@dougcamin.com

From: ARIN-PPML  on behalf of Fearghas McKay 

Date: Friday, October 27, 2023 at 6:59 PM
To: Owen DeLong 
Cc: PPML 
Subject: Re: [arin-ppml] AC Candidates


> On 27 Oct 2023, at 18:54, Owen DeLong via ARIN-PPML  
> wrote:
>
>
> Sure, but there’s no other list open to those interested who are not general 
> members.

Including those of us who only have ARIN ASNs but number resources are 
elsewhere who cannot be general  members despite paying fees.

f
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Re: [arin-ppml] AC candidates

[Douglas Camin]

Owen –

Appreciate your input here. Related to the policy you reference about the 
definition of Allocation. As the lead shepherd for that policy, I will share 
that your (and other) feedback about the definition was heard (I referenced it 
in the slide presentation specifically.)

Not changing the language immediately was not a result of picking one side or 
another, but more about keeping the draft language stable to allow for 
additional in-person community feedback at the public policy meeting. The 
policy had undergone many changes in August and September with final revisions 
from staff and legal review at the end of September. Given that, it seemed 
prudent to allow the as-written language to elicit a complete cycle of feedback 
both on PPML and in person. My apologies if that understanding wasn’t conveyed. 
The feedback received at the microphone and in the room was helpful in shaping 
the understanding for the next steps.

Hope that helps –


Doug



--
Douglas J. Camin
ARIN Advisory Council
d...@dougcamin.com

From: ARIN-PPML  on behalf of Owen DeLong via 
ARIN-PPML 
Date: Thursday, October 26, 2023 at 1:30 PM
To: William Herrin 
Cc: arin-ppml@arin.net 
Subject: Re: [arin-ppml] AC candidates


> On Oct 26, 2023, at 09:47, William Herrin  wrote:
>
> On Thu, Oct 26, 2023 at 9:28 AM Andrew Dul  wrote:
>> On 10/26/2023 9:20 AM, William Herrin wrote:
>>> It plummeted after the Board changed the AC's role from shepherding
>>> policy proposals to developing policy proposals.
>>
>> I realize that might be a distinction with out a difference, but I
>> wanted to point it out.
>
> Shepherds guide folks through process. They don't edit proposals.
> Today's AC does much more of the latter than the former.
>
>
>> From a policy development perspective the AC's role has not changed
>> significantly in more than a decade.
>
> I can still be sore about changes made a decade ago.
>
>
>> Should we disallow an AC member from submitting a policy proposal?
>
> I don't think that's the problem. The AC members are some of the best
> informed folks around. It would be a waste to be unable to leverage
> their ideas. The problem is the next step where they get together and
> edit them privately. This is inherently exclusionary of everybody else
> and IMO is uncorrectable as long as the AC has the unilateral power to
> edit an author's proposal.

In my experience, the AC works very hard to remain true to the author’s
original intent and involve author(s) in the editorial process of a policy.
The AC is also extremely receptive to whatever community input is
available on a policy in most cases.

The only recent counterexample I can point to is efforts to wordsmith
a proposal that sought to redefine assignment and (slightly) expand the
definition of allocation. You and I both wanted to choose a new term,
Mr. Curran was very clearly opposed to doing so. The AC obviously
chose to weigh Mr. Curran’s guidance more heavily than ours.

At the end of the day, that’s not one of the hills I’m willing to die on.

I don’t take that as an indication that the AC is conspiring with Mr. Curran
behind my back. That debate was quite open and public.

I have seen the AC depart from the author(s)’ intent in the following
circumstances:

+   Significant community pressure to go in a different direction
+   The author becomes unresponsive or unwilling to accommodate
community feedback

Otherwise, I’ve seen the AC work very hard to remain true to the author(s)’
original intent, even to the point of recognizing that editing a proposal would
be disingenuous and authoring a new proposal as an alternative rather than
override an existing proposal.

> What should be disallowed to AC members is:
>
> 1. Editing proposals, except by the individual who authored it (which
> if an AC member should be only that individual).

I think this would be significantly more dysfunctional than the current
process, TBH. The most likely result would be the AC abandoning more
proposals and spinning up competing proposals as a workaround.

> 2. Private debate about proposals between AC members. Restrict the AC
> meetings to voting on proposals without debate or advocacy. Require
> the discussion and debate to happen on PPML.

ROFLMAO… This would not be an improvement of the process. This would
be chaos. You could sooner ban hallway discussions of proposals at the meetings.


Owen

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

[Douglas Camin]

Owen, et al. –

Thank you for the feedback…follow up question after sharing some thoughts on 
the background and genesis of the policy draft:


  *   The rationale used was that it was more straightforward to revise the 
definition across the NRPM rather than replace each relevant instance of 
“allocation” and “assignment” with another term (allocation appears 245 times, 
and assignment appears 101 times.)


  *   Reading the terms Allocation and Assignment, I see the primary 
distinction between them as one is “for you” and one is “for you to give to 
others.”



  *   The key wording for Allocation and Assignment was changed from 
“delegated” to “issued” to reflect current practice and nomenclature.


My understanding is that NRPM’s goal is to reflect current practice – 
collapsing the two definitions together since the “For you\for you to give” 
distinction isn’t relevant for NRPM’s purposes and current practice is to issue 
number resources rather than delegate seems like a very straightforward and 
practical way to achieve it. I follow the idea that the term has varying 
definitions elsewhere and in the past, but if we’re defining it as we see fit 
here, that would be the controlling definition for NRPM purposes.

Definitely open to suggestions, so my follow up question is do you see any 
practical way (or have additional suggestion) to fix the widely distributed 
“allocation” and “issued” language through NRPM if we were to create a new 
definition such as “Issuance”?

Thanks in advance –


Doug



--
Douglas J. Camin
ARIN Advisory Council
d...@dougcamin.com

From: ARIN-PPML  on behalf of Owen DeLong via 
ARIN-PPML 
Date: Friday, September 29, 2023 at 5:51 PM
To: ARIN 
Cc: arin-ppml@arin.net 
Subject: Re: [arin-ppml] Revised - Draft Policy ARIN-2022-12: Direct Assignment 
Language Update
Personally, I am of the opinion that if we are going to take this step, we 
should
consider new terminology altogether.

Perhaps “registration” or “issuance” or similar.

The meaning of allocation and assignment while a source of multiple 
misunderstandings over the years hsve
been etched into many of our brains as having distinct connotations. If we’re 
going to change the connotation,
then I think rather than moving to one of the previous terms, we should use a 
new term.

Owen


> On Sep 29, 2023, at 11:21, ARIN  wrote:
>
> 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=05%7C01%7C%7C6bfff29def12461afcb208dbc136345c%7C84df9e7fe9f640afb435%7C1%7C0%7C638316210773049340%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C=bVRQA6SYC%2B29AIu13ZnH%2BYXcMGdgm%2BWBkyymhQfxu4A%3D=0
>
> 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=05%7C01%7C%7C6bfff29def12461afcb208dbc136345c%7C84df9e7fe9f640afb435%7C1%7C0%7C638316210773049340%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C=d86KlL4yygkpi%2BKvDdDuy8WKrLavJs7B7DmTw%2FfJ%2Fp8%3D=0
>
> 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=05%7C01%7C%7C6bfff29def12461afcb208dbc136345c%7C84df9e7fe9f640afb435%7C1%7C0%7C638316210773049340%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C=Rgy1y3TmDwSg7Ncj1hRbOc%2B8SvdHIyXFjcFE7EseAcY%3D=0
>
>
> 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 
> 

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

[Douglas Camin]

Owen –

Great, thanks for the feedback, and thanks for your previous editorial feedback 
– was most helpful. Looking forward to presenting this at ARIN52.


Doug




--
Douglas J. Camin
d...@dougcamin.com

From: ARIN-PPML  on behalf of Delong.com via 
ARIN-PPML 
Date: Thursday, September 7, 2023 at 3:50 PM
To: ARIN 
Cc: arin-ppml@arin.net 
Subject: Re: [arin-ppml] Revised - Draft Policy ARIN-2022-12: Direct Assignment 
Language Update
Support as written, recommend the editorial process as this is an editorial 
change in keeping with the fee structure realities rather than a change in 
policy regarding how the registry is administered.

Owen


> On Sep 5, 2023, at 10:35, ARIN  wrote:
>
> 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=05%7C01%7C%7Cf18a558d7dfd43277d1e08dbafdba6a3%7C84df9e7fe9f640afb435%7C1%7C0%7C638297130162047254%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C=VW5ZNl81TM5bczxIzvO80GxmK7uFfQbdqc0oiyqQL3s%3D=0
>
> 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=05%7C01%7C%7Cf18a558d7dfd43277d1e08dbafdba6a3%7C84df9e7fe9f640afb435%7C1%7C0%7C638297130162047254%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C=B3XvHYAed0mLO6%2BcjdzkJDO733iVBS%2BzOAf%2F5syaP6Y%3D=0
>
> 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=05%7C01%7C%7Cf18a558d7dfd43277d1e08dbafdba6a3%7C84df9e7fe9f640afb435%7C1%7C0%7C638297130162047254%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C=RDJayrz6akJ6L57Eno0lKyr2%2F8IokELUl3wS2YH6Lsg%3D=0
>
> 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 - The method by which ARIN directly issues IP address resources 
> to an Organization.
>
> Assignment - The use of Assignment as a differentiating term has been 
> deprecated.  Assignment should instead be read as Allocation or Issued.”
>
> Section 2.6:
>
> Change “receiving assignments of” to “issued.”
>
> 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 issued IP addresses exclusively for use in its 
> operational networks.”
>
> Section 2.8
>
> Change “allocated or assigned” to “issued.”
>
> 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)
>
> Number resources issued 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 
> 

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

[Douglas Camin]

Owen –

Ah, I follow now, my mistake. Thanks for the clarification.


Doug





--
Douglas J. Camin
d...@dougcamin.com

From: Owen DeLong 
Date: Friday, August 4, 2023 at 5:23 PM
To: Douglas Camin 
Cc: Scott Leibrand , arin-ppml@arin.net 

Subject: Re: [arin-ppml] Revised - Draft Policy ARIN-2022-12: Direct Assignment 
Language Update
No, I’m looking to replace Scott’s language specifying organizations that may 
have IPv4 addresses, but don’t yet have any directly issued by an RIR.

There are multiple places an ISP may get IP addresses these days besides an 
upstream provider (e.g. a leasing agency, etc.).

Owen



On Aug 4, 2023, at 13:17, Douglas Camin  wrote:

Owen –

Thanks for the input, looking to clarify.

In the proposal, it suggests breaking Section 4.2.2 into multiple subsections. 
Scott’s suggestion was for new subsection 4.2.2.2 “ISPs with Existing 
Addresses.”

Your language looks like it may apply to new subsection 4.2.2.1 “ISPs without 
existing IPv4 addresses” where the first sentence is “All ISPs without any IPv4 
addresses automatically qualify for a /24.”

Reading it I think you’re suggesting a change to 4.2.2.1, but I wasn’t fully 
sure since you replied to the comment about 4.2.2.2.

Just wanted to confirm we’re on the same page for your suggestion (which is an 
excellent one providing more clarity.)

Thanks!



Doug



--
Douglas J. Camin
ARIN Advisory Council
d...@dougcamin.com<mailto:d...@dougcamin.com>

From: ARIN-PPML  on behalf of Owen DeLong via 
ARIN-PPML 
Date: Friday, August 4, 2023 at 3:23 PM
To: Scott Leibrand 
Cc: arin-ppml@arin.net 
Subject: Re: [arin-ppml] Revised - Draft Policy ARIN-2022-12: Direct Assignment 
Language Update
As long as we are wordsmithing this, may I humbly suggest:

“All ISP organizations who have no IPv4 resources directly issued to them by an 
RIR qualify for an initial allocation of up to a /22”.

Owen




On Aug 3, 2023, at 22:35, Scott Leibrand  wrote:

The placement of "only" in "All ISP organizations with only IPv4 addresses from 
an upstream provider qualify for an initial allocation of up to a /22..." would 
have a presumably unintended effect of excluding ISP organizations that have 
both IPv4 and IPv6 addresses from an upstream provider. I think you want it to 
say something like "All ISP organizations with IPv4 addresses solely from 
upstream provider(s) qualify..."

-Scott

On Wed, Aug 2, 2023 at 3:06 PM ARIN mailto:i...@arin.net>> wrote:
The following Draft Policy has been revised:

* ARIN-2022-12: Direct Assignment Language Update

Revised text is below and can be found at:

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://www.arin.net/participate/policy/pdp/

Draft Policies and Proposals under discussion can be found at:

https://www.arin.net/participate/policy/drafts/


Regards,

Eddie Diego
Policy Analyst
American Registry for Internet Numbers (ARIN)



Draft Policy ARIN-2022-12: Direct Assignment Language Update

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.


Policy Statement:

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 registered with ARIN"​

RESULT: “This policy applies to every Organization that has Internet number 
resources registered with 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:​

Reorganize and adjust text as follows

FROM:​

4.2.2. Initial Allocation to ISPs​

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 spec

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

[Douglas Camin]

Owen –

Thanks for the input, looking to clarify.

In the proposal, it suggests breaking Section 4.2.2 into multiple subsections. 
Scott’s suggestion was for new subsection 4.2.2.2 “ISPs with Existing 
Addresses.”

Your language looks like it may apply to new subsection 4.2.2.1 “ISPs without 
existing IPv4 addresses” where the first sentence is “All ISPs without any IPv4 
addresses automatically qualify for a /24.”

Reading it I think you’re suggesting a change to 4.2.2.1, but I wasn’t fully 
sure since you replied to the comment about 4.2.2.2.

Just wanted to confirm we’re on the same page for your suggestion (which is an 
excellent one providing more clarity.)

Thanks!



Doug



--
Douglas J. Camin
ARIN Advisory Council
d...@dougcamin.com

From: ARIN-PPML  on behalf of Owen DeLong via 
ARIN-PPML 
Date: Friday, August 4, 2023 at 3:23 PM
To: Scott Leibrand 
Cc: arin-ppml@arin.net 
Subject: Re: [arin-ppml] Revised - Draft Policy ARIN-2022-12: Direct Assignment 
Language Update
As long as we are wordsmithing this, may I humbly suggest:

“All ISP organizations who have no IPv4 resources directly issued to them by an 
RIR qualify for an initial allocation of up to a /22”.

Owen



On Aug 3, 2023, at 22:35, Scott Leibrand  wrote:

The placement of "only" in "All ISP organizations with only IPv4 addresses from 
an upstream provider qualify for an initial allocation of up to a /22..." would 
have a presumably unintended effect of excluding ISP organizations that have 
both IPv4 and IPv6 addresses from an upstream provider. I think you want it to 
say something like "All ISP organizations with IPv4 addresses solely from 
upstream provider(s) qualify..."

-Scott

On Wed, Aug 2, 2023 at 3:06 PM ARIN mailto:i...@arin.net>> wrote:
The following Draft Policy has been revised:

* ARIN-2022-12: Direct Assignment Language Update

Revised text is below and can be found at:

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://www.arin.net/participate/policy/pdp/

Draft Policies and Proposals under discussion can be found at:

https://www.arin.net/participate/policy/drafts/


Regards,

Eddie Diego
Policy Analyst
American Registry for Internet Numbers (ARIN)



Draft Policy ARIN-2022-12: Direct Assignment Language Update

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.


Policy Statement:

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 registered with ARIN"​

RESULT: “This policy applies to every Organization that has Internet number 
resources registered with 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:​

Reorganize and adjust text as follows

FROM:​

4.2.2. Initial Allocation to ISPs​

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:​

4.2.2. Initial Allocation to ISPs​

4.2.2.1 ISPs without existing IPv4 addresses​

All ISPs without any IPv4 addresses 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.

4.2.2.2 ISPs with existing IPv4 addresses​

All ISP organizations with only IPv4 addresses from an upstream provider 
qualify 

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

[Douglas Camin]

Scott –

Great catch, thank you. Leif is correct that was an unintended transcription 
error when editing the sections out. I’ll get it updated.


Doug



--
Douglas J. Camin
ARIN Advisory Council
d...@dougcamin.com

From: ARIN-PPML  on behalf of Leif Sawyer via 
ARIN-PPML 
Date: Friday, August 4, 2023 at 1:08 PM
To: Scott Leibrand 
Cc: arin-ppml@arin.net 
Subject: Re: [arin-ppml] Revised - Draft Policy ARIN-2022-12: Direct Assignment 
Language Update
Indeed  -

I think that ‘only’  a transcription error, and your “solely”  is where it was 
supposed to have been.  Solely does read better as well.

I’ll note that for the shepherd to correct.

Thanks Scott,
   Leif

Leif Sawyer
GCI | he/him | Engineer, Network & Systems Delivery Engineering
t: 907-351-1535 | w: www.gci.com

From: ARIN-PPML  On Behalf Of Scott Leibrand
Sent: Thursday, August 3, 2023 9:35 PM
To: ARIN 
Cc: arin-ppml@arin.net
Subject: Re: [arin-ppml] Revised - Draft Policy ARIN-2022-12: Direct Assignment 
Language Update

[EXTERNAL EMAIL - CAUTION: Do not open unexpected attachments or links.]
The placement of "only" in "All ISP organizations with only IPv4 addresses from 
an upstream provider qualify for an initial allocation of up to a /22..." would 
have a presumably unintended effect of excluding ISP organizations that have 
both IPv4 and IPv6 addresses from an upstream provider. I think you want it to 
say something like "All ISP organizations with IPv4 addresses solely from 
upstream provider(s) qualify..."

-Scott

On Wed, Aug 2, 2023 at 3:06 PM ARIN mailto:i...@arin.net>> wrote:
The following Draft Policy has been revised:

* ARIN-2022-12: Direct Assignment Language Update

Revised text is below and can be found at:

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://www.arin.net/participate/policy/pdp/

Draft Policies and Proposals under discussion can be found at:

https://www.arin.net/participate/policy/drafts/


Regards,

Eddie Diego
Policy Analyst
American Registry for Internet Numbers (ARIN)



Draft Policy ARIN-2022-12: Direct Assignment Language Update

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.


Policy Statement:

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 registered with ARIN"​

RESULT: “This policy applies to every Organization that has Internet number 
resources registered with 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:​

Reorganize and adjust text as follows

FROM:​

4.2.2. Initial Allocation to ISPs​

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:​

4.2.2. Initial Allocation to ISPs​

4.2.2.1 ISPs without existing IPv4 addresses

All ISPs without any IPv4 addresses 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.

4.2.2.2 ISPs with existing IPv4 addresses

All ISP organizations with only IPv4 addresses from an upstream provider 
qualify for an initial allocation of up to a /22, subject to ARIN’s minimum 
assignment size.​

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

[Douglas Camin]

Owen –

Thanks for the feedback, much appreciated. Will review and incorporate as 
appropriate.

Regards –


Doug


--
Douglas J. Camin
ARIN Advisory Council
d...@dougcamin.com

From: ARIN-PPML  on behalf of Delong.com via 
ARIN-PPML 
Date: Tuesday, July 18, 2023 at 1:16 PM
To: ARIN 
Cc: arin-ppml@arin.net 
Subject: Re: [arin-ppml] Revised - Draft Policy ARIN-2022-12: Direct Assignment



On Jul 18, 2023, at 08:27, ARIN  wrote:

The following Draft Policy has been revised:

* ARIN-2022-12: Direct Assignment Language Update

Revised text is below and can be found at:

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://www.arin.net/participate/policy/pdp/

Draft Policies and Proposals under discussion can be found at:
https://www.arin.net/participate/policy/drafts/

Regards,

Eddie Diego
Policy Analyst
American Registry for Internet Numbers (ARIN)



Draft Policy ARIN-2022-12: Direct Assignment Language Update

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.

Policy Statement:
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 registered with ARIN"​

RESULT: “This policy applies to every Organization that has Internet number 
resources registered with ARIN (or one of its predecessor registries) or a 
reallocation from an upstream ISP.”​


I believe as worded, this has the unintended consequence of adding effect to 
registered reassignments.

If that is the intent (significant change of actual policy) vs. adopting 
existing policy language to match existing behavior in new circumstances (as 
stated in the problem statement), then that’s fine, but it should be clearly 
stated as the intent.

If that is not the intent (and I suspect it is not), some wordsmithing is in 
order.


Section 4.2.2:​

Reorganize and adjust text as follows

FROM:​
4.2.2. Initial Allocation to ISPs​

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:​
4.2.2. Initial Allocation to ISPs​

4.2.2.1 ISPs without existing IPv4 addresses​

All ISPs without any IPv4 addresses 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.

4.2.2.2 ISPs with existing IPv4 addresses​

All ISP organizations with only IPv4 addresses from an upstream provider 
qualify for an initial allocation of up to a /22, subject to ARIN’s minimum 
assignment size.​

4.2.2.3 Qualifying for increased initial assignments​

All ISP organizations are exempt from requirements of showing the efficient 
utilization of previously held IPv4 addresses. 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.​

Section 4.3.2:​

Change paragraph 1 text​

FROM: "End-user organizations without direct assignments or allocations from 
ARIN"​

TO: “End-user organizations without IPv4 allocations issued by or transferred 
to ARIN”​

RESULT: “End-user organizations without IPv4 allocations issued by or 
transferred to ARIN qualify for an initial assignment of ARIN’s minimum 
assignment size.”​

This feels awkward and worthy of some wordsmithing… Perhaps:

End-user 

[arin-ppml] Policy Experience Workgroup - 8.3/8.4 12-Month Waiting Rule Question

[Douglas Camin]

Hello –

The Advisory Council’s Policy Experience Workgroup is looking for feedback 
regarding the 12-month waiting rule outlined in Sections 8.3 and 8.4 of the 
Number Policy Resource Manual.

Currently, the text for both is identical and reads as follows:
With the exception of M transfers under section 8.2, the source entity must 
not have received a transfer, allocation, or assignment from ARIN for the past 
12 months. This requirement may be waived by ARIN for transfers made in 
connection with a renumbering exercise designed to more efficiently utilize 
number resources under section 8.5.5.1.
Do you feel it is still necessary and\or serves a useful purpose? If not, 
should it be removed or modified?

Thank you in advance for your input –


Doug


--
Douglas J. Camin
Member, ARIN Advisory Council
d...@dougcamin.com
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