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 <arin-ppml-boun...@arin.net> on behalf of Delong.com via ARIN-PPML <arin-ppml@arin.net> Date: Tuesday, July 18, 2023 at 1:16 PM To: ARIN <i...@arin.net> Cc: arin-ppml@arin.net <arin-ppml@arin.net> Subject: Re: [arin-ppml] Revised - Draft Policy ARIN-2022-12: Direct Assignment On Jul 18, 2023, at 08:27, ARIN <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.” 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 organizations without IPv4 resources directly registered with ARIN qualify for an initial allocation of ARIN’s minimum allocation size.” (It seems to me that the purpose of this policy is to harmonize to allocation and eliminate assignment given the new fee structure eliminates the distinction between assignment and allocation. We should pick one term and eliminate the other rather than leave two terms where the meaning of one has been changed.) Section 6.5.8: Change section title FROM: “Direct Assignments from ARIN to End-user Organizations” TO: “End-user Allocations” Section 8.5.4: Change section text FROM: “Organizations without direct assignments or allocations from ARIN” TO: “Organizations without IPv4 allocations issued by or transferred to ARIN” RESULT: “Organizations without IPv4 allocations issued by or transferred to ARIN qualify for transfer of an initial IPv4 block of ARIN’s minimum transfer size.” Suggest: Organizations without IPv4 resources directly registered with ARIN qualify for transfer of an initial IPv4 block of ARIN’s minimum transfer size.” Section 8.5.6: Change section text FROM: “Organizations with direct assignments or allocations from ARIN…” TO: “Organizations with IPv4 allocations issued by or transferred to ARIN…” RESULT: “Organizations with IPv4 allocations issued by or transferred ARIN must have efficiently utilized at least 50% of their cumulative IPv4 address blocks in order to receive additional IPv4 addresses. This includes all IPv4 space reassigned to their customers.” Suggest: Organizations with IPv4 resources directly registered with ARIN must have efficiently utilized… Otherwise, this looks reasonable. Owen
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