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ARIN-prop-246: Reallocation and Reassignment Language Cleanup

Date: 10/11/2017

Problem Statement:

The current text of NRPM uses the terms 'reallocate' and 'reassign' in ways that are both internally inconsistent within NRPM and inconsistent with the definitions of Reassignments and Reallocations as fields within the ARIN database. Frequently the term 'reassignment' or 'reassign' is used in NRPM as an umbrella term for both reallocations and reassignments. As a result, someone familiar with the ARIN Whois database, but unfamiliar with history of particular portions of NRPM and their intended meaning may interpret certain NRPM requirements as applying only to reassignments and not to reallocations. This is particularly problematic when it comes to SWIP requirements and the requirement to record reallocations and reassignments with ARIN, which under current text could be read to only apply to reassignments.

Policy Statement:

Proposed Revisions:

I. Add the following definitions to section 2.5 beneath the current text:

· Reallocate - To reallocate means to distribute address space that has already been allocated to an organization directly from ARIN to that organization's downstream customer for the purpose of subsequent distribution by that customer.

· Reassign – To reassign means to delegate address space that has already been allocated to an organization directly from ARIN to that organization's downstream customer for that customer's own exclusive use within the Internet infrastructure they operate.

II. Make the following editorial changes to section 4.2:

Current text:

4.2.1.1. Purpose

ARIN allocates blocks of IP addresses to ISPs for the purpose of reassigning that space to their customers.

Proposed Editorial Change:

4.2.1.1. Purpose

ARIN allocates blocks of IP addresses to ISPs for the purpose of reassigning and reallocating that space to their customers.

Current text:

4.2.3. Reassigning Address Space to Customers

Proposed Editorial Change:

4.2.3. Reassigning and Reallocating Address Space to Customers

Current Text:

4.2.3.1. Efficient utilization

ISPs are required to apply a utilization efficiency criterion in providing address space to their customers. To this end, ISPs should have documented justification available for each reassignment. ARIN may request this justification at any time. If justification is not provided, future receipt of allocations may be impacted.

Proposed Editorial Change:

4.2.3.1. Efficient utilization

ISPs are required to apply a utilization efficiency criterion in providing address space to their customers. To this end, ISPs should have documented justification available for each reassignment and reallocation. ARIN may request this justification at any time. If justification is not provided, future receipt of allocations may be impacted.

Current text:

4.2.3.4. Downstream customer adherence

ISPs must require their downstream customers to adhere to the following criteria:

4.2.3.4.1. Utilization

Reassignment information for prior allocations must show that each customer meets the 80% utilization criteria and must be available via SWIP / RWhois prior to your issuing them additional space.

Proposed Editorial Changes:

4.2.3.4. Downstream customer adherence

ISPs must require their downstream customers to adhere to the following criteria:

4.2.3.4.1. Utilization

Reassignment and reallocation information for prior allocations must show that each customer meets the 80% utilization criteria and must be available via SWIP / RWhois prior to your issuing them additional space.

Current text:

4.2.3.5. ARIN approval of reassignments/reallocations

4.2.3.5.1. /18

All extra-large ISPs making reassignments of a /18 or larger to a customer must first have these reassignments reviewed and approved by ARIN.

4.2.3.5.2. /19

Small to large ISPs making customer reassignments of a /19 or larger must first seek ARIN's approval.

Proposed Editorial Changes:

4.2.3.5. ARIN approval of reassignments/reallocations

4.2.3.5.1. /18

All extra-large ISPs making reassignments or reallocations of a /18 or larger to a customer must first have these reassignments or reallocations reviewed and approved by ARIN.

4.2.3.5.2. /19

Small to large ISPs making customer reassignments or reallocations of a /19 or larger must first seek ARIN's approval.

Current text:

4.2.3.7.1. Reassignment Information

Each IPv4 assignment containing a /29 or more addresses shall be registered in the WHOIS directory via SWIP or a distributed service which meets the standards set forth in section 3.2. Reassignment registrations shall include each client's organizational information, except where specifically exempted by this policy.

Proposed Editorial Changes:

4.2.3.7.1. Reassignment and Reallocation Information

Each IPv4 reassignment or reallocation containing a /29 or more addresses shall be registered in the WHOIS directory via SWIP or a distributed service which meets the standards set forth in section 3.2. Reassignment and reallocation registrations shall include each client's organizational information, except where specifically exempted by this policy.

Current text:

4.2.3.7.2.Assignments visible within 7 days

All assignments shall be made visible as required in section 4.2.3.7.1 within seven calendar days of assignment.

Proposed Editorial Changes:

4.2.3.7.2.Reassignments and Reallocations visible within 7 days

All reassignments and reallocations shall be made visible as required in section 4.2.3.7.1 within seven calendar days of reassignment or reallocation.

Current text:

4.2.4. ISP Additional Requests

4.2.4.1. Utilization percentage (80%)

ISPs must have efficiently utilized all allocations, in aggregate, to at least 80% and at least 50% of every allocation in order to receive additional space. This includes all space reassigned to their customers.

Proposed Editorial Changes:

4.2.4. ISP Additional Requests

4.2.4.1. Utilization percentage (80%)

ISPs must have efficiently utilized all allocations, in aggregate, to at least 80% and at least 50% of every allocation in order to receive additional space. This includes all space reassigned or reallocated to their customers.

III. Make the following editorial changes to section 6 to clarify language regarding current practices and requirements for reallocations and reassignments, and specifically to clarify that recording reallocation information is required where current language is ambiguous:

Current text:

6.5.2.1(e) Initial Allocations to LIRs, Size

For purposes of the calculation in (c), an LIR which has subordinate LIRs shall make such allocations according to the same policies and criteria as ARIN. In such a case, the prefixes necessary for such an allocation should be treated as fully utilized in determining the block sizing for the parent LIR. LIRs which do not receive resources directly from ARIN will not be able to make such allocations to subordinate LIRs and subordinate LIRs which need more than a /32 shall apply directly to ARIN.

Proposed Editorial Changes:

6.5.2.1(e) Initial Allocations to LIRs, Size

For purposes of the calculation in (c), an LIR which has subordinate LIRs shall make such reallocations according to the same policies and criteria as ARIN. In such a case, the prefixes necessary for such a reallocation should be treated as fully utilized in determining the block sizing for the parent LIR. LIRs which do not receive resources directly from ARIN will not be able to make such reallocations to subordinate LIRs and subordinate LIRs which need more than a /32 shall apply directly to ARIN.

Current text:

6.5.2.2. Qualifications

An organization qualifies for an allocation under this policy if they meet any of the following criteria:

a. Have a previously justified IPv4 ISP allocation from ARIN or one of its predecessor registries or can qualify for an IPv4 ISP allocation under current criteria.

b. Are currently multihomed for IPv6 or will immediately become multihomed for IPv6 using a valid assigned global AS number.

In either case, they will be making reassignments from allocation(s) under this policy to other organizations.

c. Provide ARIN a reasonable technical justification indicating why an allocation is necessary. Justification must include the intended purposes for the allocation and describe the network infrastructure the allocation will be used to support. Justification must also include a plan detailing anticipated assignments to other organizations or customers for one, two and five year periods, with a minimum of 50 assignments within 5 years.

Proposed Editorial Changes:

6.5.2.2. Qualifications

An organization qualifies for an allocation under this policy if they meet any of the following criteria:

a. Have a previously justified IPv4 ISP allocation from ARIN or one of its predecessor registries or can qualify for an IPv4 ISP allocation under current criteria.

b. Are currently multihomed for IPv6 or will immediately become multihomed for IPv6 using a valid assigned global AS number.

In either case, they will be making reassignments or reallocations from allocation(s) under this policy to other organizations.

c. Provide ARIN a reasonable technical justification indicating why an allocation is necessary. Justification must include the intended purposes for the allocation and describe the network infrastructure the allocation will be used to support. Justification must also include a plan detailing anticipated reassignments and reallocations to other organizations or customers for one, two and five year periods, with a minimum of 50 assignments within 5 years.

Current text:

6.5.4. Assignments from LIRs/ISPs

Assignments to end users shall be governed by the same practices adopted by the community in section 6.5.8 except that the requirements in 6.5.8.1 do not apply.

Proposed Editorial Changes:

6.5.4. Reassignments from LIRs/ISPs
Reassignments to end users shall be governed by the same practices adopted by the community in section 6.5.8 except that the requirements in 6.5.8.1 do not apply.

Current text:

6.5.4.1. Assignment to operator's infrastructure
An LIR may assign up to a /48 per PoP as well as up to an additional /48 globally for its own infrastructure.

Proposed Editorial Changes:

6.5.4.1. Reassignment to operator's infrastructure
An LIR may reassign up to a /48 per PoP as well as up to an additional /48 globally for its own infrastructure.

Current text:

6.5.5. Registration

ISPs are required to demonstrate efficient use of IP address space allocations by providing appropriate documentation, including but not limited to assignment histories, showing their efficient use.

Proposed Editorial Changes:

6.5.5. Registration

ISPs are required to demonstrate efficient use of IP address space allocations by providing appropriate documentation, including but not limited to reassignment and reallocation histories, showing their efficient use.

Current text:

6.5.5.1. Reassignment information

Each static IPv6 assignment containing a /64 or more addresses shall be registered in the WHOIS directory via SWIP or a distributed service which meets the standards set forth in section 3.2. Reassignment registrations shall include each client's organizational information, except where specifically exempted by this policy.

Proposed Editorial Changes:

6.5.5.1. Reassignment information

Each static IPv6 reassignment or reallocation containing a /64 or more addresses shall be registered in the WHOIS directory via SWIP or a distributed service which meets the standards set forth in section 3.2. Reassignment and reallocation registrations shall include each client's organizational information, except where specifically exempted by this policy.

Current text:

6.5.5.2. Assignments visible within 7 days

All assignments shall be made visible as required in section 4.2.3.7.1 within seven calendar days of assignment

Proposed Editorial Changes:

6.5.5.2. Reassignments and Reallocations visible within 7 days

All reassignments and reallocations shall be made visible as required in section 4.2.3.7.1 within seven calendar days of reassignment or reallocation.

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