Editorial Change ARIN-edit-2020-9

Section 8 Editorial Clean-up

Version Reviewed: 23 March 2021

Staff Understanding:

ARIN-edit-2020-9 is intended as an editorial change spanning 38 NRPM sections and including, in some cases, removal or rewording of entire sections. In general, staff suggests splitting such intensive, comprehensive edits to the NRPM into Proposals more easily reviewed by the community, especially when intended and classified as an Editorial Change. Editorial changes have a far more limited timeframe for community visibility and such a path should be reserved for minor, purely editorial changes that are easily contained within a Proposal template, as opposed to being accessed via a URL, which many list users may be wary of following to access the full scope of the Proposal.

Some of these major changes, in practice, are substantial enough to warrant a full PDP cycle of community review and some introduce text specifically removed/revised by policies adopted since early 2020. For example:

4.1.2. ARIN Waitlist:

“ARIN will only accept and approve requests from organizations holding a /20 or less.”

This text differs from the previous language introduced by Editorial Change ARIN-edit-2020-1: “Organizations which hold more than a /20 equivalent of IPv4 space in aggregate are not eligible to apply.”

Removing “in aggregate” reintroduces the issue of customers holding a /24 and 2 /21s not being eligible, which has caused concern in the past.

4.2.2. Initial Allocations to ISPs

The text introduced by ARIN-2019-20, “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,” has been removed. This may reintroduce the confusion ARIN-2019-20 sought to eliminate. Adding “the maximum address space in aggregate for which an organization may qualify at any one time is a /22,” may help, but staff feels this update alone is beyond the scope of an Editorial Change. Reassignments to Multihomed Downstream Customers

This section has been rewritten to introduce text removed by ARIN-2020-5 referencing RFC2050.

4.1.7. Reserved Pool Replenishment

This section, and both subsections, have been removed, undoing the implementation of ARIN-2019-21. Slow Start

This section has also been retired in its entirety. While this section is not currently in use by staff, removal of it completely, in staff’s view, constitutes a substantive policy change.

Implementable as Written?: Yes

Impact on ARIN Registry Operations and Services:

There are many potential ripple effects to RSD’s daily operations, as noted in the Staff Understanding.

Legal Review:

ARIN-edit-2020-9 contains a significant number of modifications and edits to the NRPM. Historically, editorial changes to policy have been very focused and clearly non-substantial in nature. The current policy proposal contains proposed edits to the NRPM that arguably may be considered substantial and non-editorial. For example, adding to the Principles and Goals contained in Section 1 of the NRPM by moving text from another section does not appear to be editorial.

Further, there are significant rewrites of sections and text that again call into question whether such changes are purely editorial and non-substantial. One example is modification of language from “may” to “shall” constitutes a substantial change as it changes the interpretation of an obligation.

Therefore, this policy proposal contains material legal concerns, namely if certain proposed edits do not go through the standard community review of the non-editorial policy development process. The specific changes proposed may ultimately not carry a material legal concern, but conducting the changes with limited community review outside of the non-editorial policy development process causes concern.

Implementation Timeframe Estimate: Six months

Implementation Requirements:

  • Staff training
  • Significant updates to public documentation
  • Significant updates to internal procedures and guidelines