On Jul 11, 2023, at 11:47 AM, Owen DeLong <o...@delong.com> wrote:

Actually, I couldn’t find anything in the NRPM which leads me to believe that 
there is any distinction in the documentation requirements for 
reassignment/reallocation regardless of associated connectivity. None of the 
policies seemed to specify this. As such, I would think that Connectivity 
Independent Leasing (CIL) and Connectivity Related Leasing (CRL) would be 
subject to exactly the same recording/reporting requirements.


Owen –

ARIN NRPM Section 4.2.3.  "Reassigning and Reallocating Address Space to 
Customers" utilizes the term “Downstream” in references to both downstream 
end-users and downstream ISPs documentation requirements.

As the community has historically interpreted the phrase “downstream" to refer 
to connectivity customers (and further that the requirements documented are 
applied in oder to have accurate operational utilization), ARIN continues to 
interpret the policy as applicable to reissuance of resources to connectivity 
customers.

Of course, further policy clarity (whether to make clear that it does apply to 
non-connectivity reassignments or to make clear it does not apply beyond 
downstream customers) would be most welcome; I believe you are already aware of 
the policy proposal submission process if you want to propose updating it 
accordingly.

Thanks!
/John

John Curran
President and CEO
American Registry for Internet Numbers

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