Staff and Legal Review for Draft Policy ARIN-2022-2
Remove Barrier to BGP Uptake in ASN Policy
Staff and Legal Review (1 July 2022)
ARIN-2022-2 would add language to Autonomous System Numbers policy, specifying that organizations may be issued a single 32-bit ASN upon request, and intends to apply the existing ASN assignment verification thresholds to to 16-bit ASN requests and subsequent ASN requests.
However, staff feels the policy statement language could be further clarified and should be written against language in Recommended Draft Policy ARIN-2021-3 as that has been recommended to the Board for adoption.
Staff offers the following recommendations with the sole intent of making the resulting policy text as clear and understandable as possible for ARIN’s customers, and as actionable and unambiguous as possible for ARIN staff.
First, it is worth noting that specifying in policy that single 32-bit ASNs may be issued upon request would not preclude staff practice of issuing 16-bit ASNs by default unless a 32-bit ASN is specifically requested.
Rather than stating “Issuance of ASNs outside of the scope outlined above is subject to the following constraints,” staff recommends removing that statement and modifying the qualifying statement already in place later in the section, as it reduces the overall size of Section 5 without losing the spirit or letter of the language ARIN-2022-2 suggests.
Specifically, “In order to be assigned an AS Number, each requesting organization must provide ARIN with verification that it requires a unique routing policy, such as a plan:”
could be changed to:
“Additional ASN requests should include proof of the requestor’s need for a unique routing policy, such as a plan:”
Additionally, staff suggests that “AS Numbers are issued based on current need, as set out in this section 5” appears to be overarching language for the section as a whole. As such, staff recommends that it may serve better as the first sentence in the section and “as set out in this section 5” may not be needed.
Lastly, staff recommends standardizing to “ASN” rather than “AS Number” throughout the section to reduce confusion for the reader. This excludes the first instance, which should remain spelled out as “Autonomous System Number (ASN).
Implementable as Written?
As written, the Draft Policy does not provide clear, non-conflicting guidance for customers and staff, but it would be implementable with the staff-recommended language.
Impact on ARIN Registry Operations and Services:
None. The Draft Policy deals with issuance and manually vetted request documentation requirements, which have no significant registry impacts as a result of implementation.
No material legal issue.
Implementation Timeframe Estimate: Three months
- Staff training
- Updates to public documentation
- Updates to internal procedures and guidelines
Proposal/Draft Policy Text Assessed: 2 May 2022