[arin-ppml] Clean up definition of LIR/ISP vs. end-user

[Owen DeLong]

There are some relatively large ISPs in the residential world that could fit that definition. I don't think we necessarily want to allow that to make them end-users for the following reasons:

1.	It seems inequitable from a fee perspective vs. their competitors that provide more than one address to their
	customers.

2.	It creates a negative incentive on IPv6 because they certainly shouldn't be doing that when they start moving
	their customers to IPv6, so they would be faced with the following possible outcomes:

		1.	Substantially larger annual fees.
		2.	Force their IPv6 users into IPv6 address poverty (single IPv6 address, not good.)
		3.	Do not deploy IPv6 or use some other IPv6 translational technology to avoid
			assigning IPv6 addresses to their customers.

As a general rule, I think 1 is sufficient reason to avoid this change. However, even if you are not convinced by 1, I think the second set of tradeoffs is more than adequate.

Owen

On Apr 29, 2013, at 2:25 PM, Randy Carpenter <rcarpen at network1.net> wrote:

> 
> One clarification that would be nice is for an org who is providing transit and a single IP address to customer(s') router(s) for purposes of routing. That sounds "ISP" at first glance, but if the org in question does not actually reassign "blocks" of addresses that need to be SWIPed/WHOISed, then I would think they would be an end-user with regard to number policy.
> 
> 
> thanks,
> -Randy
> 
> 
> ----- Original Message -----
>> At ARIN 31 last week, Leslie's Policy Experience Report (slides at
>> https://www.arin.net/participate/meetings/reports/ARIN_31/PDF/monday/nobile_policy.pdf
>> or
>> https://www.arin.net/participate/meetings/reports/ARIN_31/PPT/monday/nobile_policy.pptx
>> ) reported that, in ARIN staff's experience, the NRPM does not adequately
>> define ISP/LIR vs. end-user. For example, by literally applying the existing
>> definitions as currently written, my employer would be neither an ISP nor
>> and end-user, because while they do not *primarily* assign address space to
>> users, neither do they *exclusively* use it in their own networks. So I
>> think those definitions need a few tweaks.
>> 
>> I would propose that the primary difference between ISPs/LIRs vs. end-users,
>> for purposes of the NRPM, is whether an organization reassigns address
>> blocks to third parties. If an organization maintains full control of all of
>> the equipment on its network, and doesn't need to make any reassignments to
>> other organizations, then it can qualify as an end-user. In particular, an
>> end user organization must be able to supply a full list of all the IP
>> addresses in use on its network, and know what devices are using those
>> addresses.
>> 
>> An ISP/LIR, on the other hand, should be defined by whether they delegate
>> that responsibility to another organization. In that case, they need to
>> reassign the network space via SWIP/rwhois, which makes them an LIR.
>> 
>> I understand that there are other considerations, such as the expectation in
>> the security community that addresses within an ISP allocation are generally
>> controlled by third parties, whereas addresses in an end-user assignment are
>> generally controlled by the end-user organization. However, I don't believe
>> it's practical to try to draw a distinction there: rather, organizations can
>> decide for themselves whether they need to make reassignments (for that or
>> several other reasons), and that decision can drive whether they are
>> considered an ISP/LIR or end-user for purposes of ARIN policy.
>> 
>> In light of the above, I would propose the following revised definitions:
>> 
>> 2.4. Local Internet Registry (LIR)
>> The terms Internet Service Provider (ISP) and LIR are used interchangeably in
>> this document. A Local Internet Registry (LIR) is an IR that assigns address
>> space to the users of the network services that it provides. Therefore, LIRs
>> / ISPs are organizations that reassign addresses to end users and/or
>> reallocate addresses to other ISPs/LIRs.
>> 
>> 2.6. End-user
>> An end-user is an organization receiving assignments of IP addresses
>> exclusively for use in its operational networks, and does not register any
>> reassignments of that space.
>> 
>> Thoughts? Should I submit this as a policy proposal?
>> 
>> -Scott
>> 
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