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Draft Policies and Proposals

Draft Policy ARIN-2018-4: Clarification on Temporary Sub-Assignments
Status:

Under Discussion - Staff and Legal Review Complete

 
Discussion Tracking
Mailing List:
Formal introduction on PPML on 23 April 2018

Origin - ARIN-prop-254
Draft Policy - 23 April 2018

Public Policy Mailing List
ARIN Public Policy Meeting:
ARIN Advisory Council:

AC Shepherds:
Chris Woodfield, Rob Seastrom

ARIN Board of Trustees:
Revisions Implementation

Revised - 16 July 2018

Revised/Retitled - 13 August 2018
Revised - 30 August 2018

Version Date: 30 August 2018

Problem Statement:

When the policy was drafted, the concept of assignments/sub-assignments did not consider the use of IP addresses in hotspots, or the use of IP addresses by guests or employees in Bring Your Own Device (BYOD) and many other similar cases.

Additionally, the IETF has recently approved the use of a unique IPv6 /64 prefix per interface/host (RFC8273) instead of a unique address. This, for example, allows users to connect to a hotspot, receive a /64 such that they are "isolated" from other users (for reasons of security, regulatory requirements, etc.) and they can also use multiple virtual machines on their devices with a unique address for each one (within the same /64). Section 2.5 (Definitions/Allocate and Assign), explicitly prohibits such assignments, stating that assignments and reassignments are intended “for the exclusive use of the recipient organization”.

This proposal clarifies this situation in this regard by means of additional clarifying language in the Definitions section.

Policy Statement

Actual Text:

2.5. Allocation, Assignment, Reallocation, Reassignment

Allocation - Address space delegated to an organization directly by ARIN for the purpose of subsequent distribution by the recipient organization to other parties.

Assignment - Address space delegated to an organization directly by ARIN for the exclusive use of the recipient organization.

Reallocation - Address space sub-delegated to an organization by an upstream provider for the purpose of subsequent distribution by the recipient organization to other parties.

Reassignment - Address space sub-delegated to an organization by an upstream provider for the exclusive use of the recipient organization.

New Text (Additional language in bold):

2.5. Allocation, Assignment, Reallocation, Reassignment

Allocation - Address space delegated to an organization directly by ARIN for the purpose of subsequent distribution by the recipient organization to other parties.

Assignment - Address space delegated to an organization directly by ARIN for the exclusive use of the recipient organization.

Reallocation - Address space sub-delegated to an organization by an upstream provider for the purpose of subsequent distribution by the recipient organization to other parties.

Reassignment - Address space sub-delegated to an organization by an upstream provider for the exclusive use of the recipient organization.

Note that the incidental or temporary use of address space by third parties shall not be considered a reassignment or a violation of the exclusive use criterion.

Comments

Timetable for implementation: Immediate

Anything else:

Situation in other regions:

This situation, has already been corrected in RIPE, and the policy was updated in a similar way, even if right now there is a small discrepancy between the policy text that reached consensus and the RIPE NCC Impact Analysis. A new policy proposal has been submitted to amend that, and the text is the same as presented by this proposal at ARIN. Same text has also been submitted to AfriNIC, LACNIC and APNIC.

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ARIN STAFF & LEGAL ASSESSMENT

Draft Policy ARIN-2018-04

Clarification on IPv6 Sub-Assignments

https://arin.net/policy/proposals/2018_4.html

 

Date of Assessment:  5 September 2018

1. Summary (Staff Understanding):  It is staff’s understanding that the intent of this policy is to allow an organization that has received a direct assignment from ARIN the ability to temporarily assign portions of that assignment to a third party without considering it a reassignment. As revised the wording is clear and concise.

2. Comments:

A. ARIN Staff Comments 

  • This policy will have negligible (if any) impact on RSD.
  • This policy could be implemented as written.

B.  ARIN General Counsel – Legal Assessment

  • There are no material legal issues regarding this proposal.

3.  Resource Impact

Implementation of this policy would have minimal resource impact. It is estimated that implementation could occur within 3 months after ratification by the ARIN Board of Trustees. The following would be needed in order to implement:

  • Update guidelines, documents and internal procedures
  • Staff training
  • There is no engineering work required 

4. Proposal/Draft Policy Text Assessed

Draft Policy 2018-04: Clarification on IPv6 Sub-Assignments

Version Date: 30 August 2018

Problem Statement:

When the policy was drafted, the concept of assignments/sub-assignments did not consider the use of IP addresses in hotspots, or the use of IP addresses by guests or employees in Bring Your Own Device (BYOD) and many other similar cases.

Additionally, the IETF has recently approved the use of a unique IPv6 /64 prefix per interface/host (RFC8273) instead of a unique address. This, for example, allows users to connect to a hotspot, receive a /64 such that they are "isolated" from other users (for reasons of security, regulatory requirements, etc.) and they can also use multiple virtual machines on their devices with a unique address for each one (within the same /64). Section 2.5 (Definitions/Allocate and Assign), explicitly prohibits such assignments, stating that assignments and reassignments are intended “for the exclusive use of the recipient organization”.

This proposal clarifies this situation in this regard by means of additional clarifying language in the Definitions section.

Policy Statement

Actual Text:

2.5. Allocation, Assignment, Reallocation, Reassignment

Allocation - Address space delegated to an organization directly by ARIN for the purpose of subsequent distribution by the recipient organization to other parties.

Assignment - Address space delegated to an organization directly by ARIN for the exclusive use of the recipient organization.

Reallocation - Address space sub-delegated to an organization by an upstream provider for the purpose of subsequent distribution by the recipient organization to other parties.

Reassignment - Address space sub-delegated to an organization by an upstream provider for the exclusive use of the recipient organization.

New Text (Additional language in bold):

2.5. Allocation, Assignment, Reallocation, Reassignment

Allocation - Address space delegated to an organization directly by ARIN for the purpose of subsequent distribution by the recipient organization to other parties.

Assignment - Address space delegated to an organization directly by ARIN for the exclusive use of the recipient organization.

Reallocation - Address space sub-delegated to an organization by an upstream provider for the purpose of subsequent distribution by the recipient organization to other parties.

Reassignment - Address space sub-delegated to an organization by an upstream provider for the exclusive use of the recipient organization.

Note that the incidental or temporary use of address space by third parties shall not be considered a reassignment or a violation of the exclusive use criterion.

Comments

Timetable for implementation: Immediate

Anything else:

Situation in other regions:

This situation, has already been corrected in RIPE, and the policy was updated in a similar way, even if right now there is a small discrepancy between the policy text that reached consensus and the RIPE NCC Impact Analysis. A new policy proposal has been submitted to amend that, and the text is the same as presented by this proposal at ARIN. Same text has also been submitted to AfriNIC, LACNIC and APNIC.

**********

Earlier Version

**********

Version Date: 13 August 2018

Problem Statement:

When the policy was drafted, the concept of assignments/sub-assignments did not consider the use of IP addresses in hotspots, or the use of IP addresses by guests or employees in Bring Your Own Device (BYOD) and many other similar cases.

Additionally, the IETF has recently approved the use of a unique IPv6 /64 prefix per interface/host (RFC8273) instead of a unique address. This, for example, allows users to connect to a hotspot, receive a /64 such that they are "isolated" from other users (for reasons of security, regulatory requirements, etc.) and they can also use multiple virtual machines on their devices with a unique address for each one (within the same /64).

Section 2.5 (Definitions/Allocate and Assign), explicitly prohibits such assignments, stating that "Assignments... are not to be sub-assigned to other parties".

This proposal clarifies this situation in this regard and better define the concept, particularly considering new uses of IPv6 (RFC8273), by means of additional language added to the definition of an Assignment.

Note that the proposal text also incorporates changes made under an Editorial Change currently awaiting Board of Trustees review, available here: https://www.arin.net/policy/proposals/2017_11.html

Policy Statement:

Actual Text, Section 2.5:

• Assign - To assign means to delegate address space to an ISP or end-user, for specific use within the Internet infrastructure they operate. Assignments must only be made for specific purposes documented by specific organizations and are not to be sub-assigned to other parties.

New Text:

• Assignment - Address space delegated to an organization directly by ARIN for the exclusive use of the recipient organization. A temporary assignment of address space provided to third parties shall not be considered an assignment or a violation of the exclusive use criterion.

Comments

Timetable for implementation:

Immediate

Anything else:

Situation in other regions:

This situation, has already been corrected in RIPE, and the policy was updated in a similar way, even if right now there is a small discrepancy between the policy text that reached consensus and the RIPE NCC Impact Analysis. A new policy proposal has been submitted to amend that, and the text is the same as presented by this proposal at ARIN. Same text has also been submitted to AfriNIC, LACNIC and APNIC.

##########

Earlier Version

##########

Version Date: 16 July 2018

Problem Statement:

When the policy was drafted, the concept of assignments/sub-assignments did not consider the use of IP addresses in hotspots, or the use of IP addresses by guests or employees in Bring Your Own Device (BYOD) and many other similar cases.

Additionally, the IETF has recently approved the use of a unique /64 prefix per interface/host (RFC8273) instead of a unique address. This, for example, allows users to connect to a hotspot, receive a /64 such that they are "isolated" from other users (for reasons of security, regulatory requirements, etc.) and they can also use multiple virtual machines on their devices with a unique address for each one (within the same /64).

Section 2.5 (Definitions/Allocate and Assign), explicitly prohibits such assignments, stating that "Assignments... are not to be sub-assigned to other parties".

This proposal clarifies this situation in this regard and better define the concept, particularly considering new uses of IPv6 (RFC8273), by means of a new paragraph.

Note that the proposal text also incorporates changes made under an Editorial Change currently awaiting Board of Trustees review, available here: https://www.arin.net/policy/proposals/2017_11.html

Policy Statement:

Actual Text, Section 2.5:

•    Assign - To assign means to delegate address space to an ISP or end-user, for specific use within the Internet infrastructure they operate. Assignments must only be made for specific purposes documented by specific organizations and are not to be sub-assigned to other parties.

New Text:

•   Assignment - Address space delegated to an organization directly by ARIN for the exclusive use of the recipient organization. A temporary assignment of address space provided to third parties shall not be considered an assignment.

Comments

Timetable for implementation:    

Immediate

Anything else:

Situation in other regions:

This situation, has already been corrected in RIPE, and the policy was updated in a similar way, even if right now there is a small discrepancy between the policy text that reached consensus and the RIPE NCC Impact Analysis. A new policy proposal has been submitted to amend that, and the text is the same as presented by this proposal at ARIN. Same text has also been submitted to AfriNIC, LACNIC and APNIC.

##########

ARIN STAFF & LEGAL ASSESSMENT

Draft Policy ARIN-2018-04

Clarification on IPv6 Sub-Assignments

https://arin.net/policy/proposals/2018_4.html

Date of Assessment:  31 July 2018

1. Summary (Staff Understanding):  It is staff's understanding that the intent of this policy is to allow an organization that has received a direct assignment from ARIN the ability to temporarily assign portions of that assignment to a third party without considering it a reassignment. As written, the wording is confusing. The additional sentence does not clearly tag the temporary assignment to the exclusivity clause. To avoid confusion, we recommend a wording change:

Assignment - Address space delegated to an organization directly by ARIN for the exclusive use of the recipient organization. A temporary assignment of address space to a third party shall not be considered a reassignment or a violation of the exclusive use criterion.

2. Comments:

A. ARIN Staff Comments 

  • This policy will have negligible (if any) impact on RSD.
  • This policy could be implemented as written.

B.  ARIN General Counsel – Legal Assessment 

  • There are no material legal issues regarding this proposal.

3.  Resource Impact

Implementation of this policy would have minimal resource impact. It is estimated that implementation could occur within 3 months after ratification by the ARIN Board of Trustees. The following would be needed in order to implement:

  • Update guidelines, documents and internal procedures
  • Staff training
  • There is no engineering work required 

4. Proposal/Draft Policy Text Assessed

Draft Policy 2018-04: Clarification on IPv6 Sub-Assignments

Version Date: 16 July 2018

Problem Statement:

When the policy was drafted, the concept of assignments/sub-assignments did not consider the use of IP addresses in hotspots, or the use of IP addresses by guests or employees in Bring Your Own Device (BYOD) and many other similar cases.

Additionally, the IETF has recently approved the use of a unique /64 prefix per interface/host (RFC8273) instead of a unique address. This, for example, allows users to connect to a hotspot, receive a /64 such that they are "isolated" from other users (for reasons of security, regulatory requirements, etc.) and they can also use multiple virtual machines on their devices with a unique address for each one (within the same /64).

Section 2.5 (Definitions/Allocate and Assign), explicitly prohibits such assignments, stating that "Assignments... are not to be sub-assigned to other parties".

This proposal clarifies this situation in this regard and better define the concept, particularly considering new uses of IPv6 (RFC8273), by means of a new paragraph.

Note that the proposal text also incorporates changes made under an Editorial Change currently awaiting Board of Trustees review, available here: https://www.arin.net/policy/proposals/2017_11.html

Policy Statement:

Actual Text, Section 2.5:

•    Assign - To assign means to delegate address space to an ISP or end-user, for specific use within the Internet infrastructure they operate. Assignments must only be made for specific purposes documented by specific organizations and are not to be sub-assigned to other parties.

New Text:

•   Assignment - Address space delegated to an organization directly by ARIN for the exclusive use of the recipient organization. A temporary assignment of address space provided to third parties shall not be considered an assignment.

Comments

Timetable for implementation:    

Immediate

Anything else:

Situation in other regions:

This situation, has already been corrected in RIPE, and the policy was updated in a similar way, even if right now there is a small discrepancy between the policy text that reached consensus and the RIPE NCC Impact Analysis. A new policy proposal has been submitted to amend that, and the text is the same as presented by this proposal at ARIN. Same text has also been submitted to AfriNIC, LACNIC and APNIC. 

##########

Earlier Version

##########

Version Date: 23 April 2018

Problem Statement:

When the policy was drafted, the concept of assignments/sub-assignments did not consider a practice very common in IPv4 which is replicated and even amplified in IPv6: the use of IP addresses for point-to-point links or VPNs.

In the case of IPv6, instead of unique addresses, the use of unique prefixes (/64) is increasingly common.

Likewise, the policy failed to consider the use of IP addresses in hotspots, or the use of IP addresses by guests or employees in Bring Your Own Device (BYOD) and many other similar cases.

Finally, the IETF has recently approved the use of a unique /64 prefix per interface/host (RFC8273) instead of a unique address. This, for example, allows users to connect to a hotspot, receive a /64 such that they are "isolated" from other users (for reasons of security, regulatory requirements, etc.) and they can also use multiple virtual machines on their devices with a unique address for each one (within the same /64).

Section 2.5 (Definitions/Allocate and Assign), explicitly prohibits such assignments, stating that "Assignments... are not to be sub-assigned to other parties".

This proposal clarifies this situation in this regard and better define the concept, particularly considering new uses of IPv6 (RFC8273), by means of a new paragraph.

Policy Statement

Actual Text

•    Assign - To assign means to delegate address space to an ISP or end-user, for specific use within the Internet infrastructure they operate. Assignments must only be made for specific purposes documented by specific organizations and are not to be sub-assigned to other parties.

New Text

•    Assign - To assign means to delegate address space to an ISP or end-user, for specific use within the Internet infrastructure they operate. Assignments must only be made for specific purposes documented by specific organizations and are not to be sub-assigned to other parties.

The fact that a unique address or even a unique /64 prefix is non-permanently provided to third parties, on a link operated by the original receiver of the assignment, shall not be considered a sub-assignment. This includes, for example, guests or employees (devices or servers), hotspots, and point-to-point links or VPNs. The provision of addressing for permanent connectivity or broadband services is still considered a sub-assignment. Only the addressing of the point-to-point link itself can be permanent and that addressing can't be used (neither directly or indirectly) for the actual communication.

Comments:

Timetable for implementation:

Immediate

Anything else:

Situation in other regions:

This situation, has already been corrected in RIPE, and the policy was updated in a similar way, even if right now there is a small discrepancy between the policy text that reached consensus and the RIPE NCC Impact Analysis. A new policy proposal has been submitted to amend that, and the text is the same as presented by this proposal at ARIN. Same text has also been submitted to AfriNIC, LACNIC and APNIC.

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