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

Tue Apr 30 21:45:20 EDT 2013

Bill thanks for your question!

It means that allocations should be made by a combination of the size of the organization and the size of their network and maybe the total size of their current allocations.  There should never be a time when the allocation by Arin is zero.  Arin’s mission is to allocate - and it isn’t to not allocate.

We run a small data center and we run BGP and should easily be able to qualify for a /22 (which I believe is the current minimum block size Arin allocates per current policy) and maybe even qualify for a /21. We would never and should never qualify for a /17 or a /18 as that is way too big for our size.   T-Mobile got something like three quarters of a /8 a while back and of course their company and network size certainly could have justified that.  We were denied a /22 allocation – the minimum size this “community” has decided to allocate - because of “policy” and T-Mobile was not denied. That isn’t a level playing field, adjusted for size of course, and all organizations should be able to get right sized allocations without having to meet some arbitrary needs test (and the current needs based allocation policies are very arbitrary) - even if this community wants a needs test for whatever reason.  I’ve said many times that Arin’s mission is to allocate first and conserve second - and the conserve part should never override the allocate part of the mission for any reason including IPv4 depletion. I don’t believe this community should be able to override Arin’s mission statement without changing the mission statement first.

I used to think that the current needs based policies were put in place to slow IPv4 depletion but now I’m not so sure.  I was shocked to see some recent opinions in this forum that actual live installations of IPv6 should not be able to be used to help justify an IPv4 allocation.  Wow!  I don’t know how wide spread that opinion is in this community but I sure hope it doesn’t prevail.  It just shows how crazy any needs based policy really is and that all needs based policies are arbitrary.  It cements my belief that the whole Arin Community very much needs and very much would benefit from a major rewrite of all of the needs based policies a la https://www.ripe.net/ripe/policies/proposals/2013-03

I will keep on advocating this as long as I can breathe until sanity prevails. For those who argue that there is no other way to fix IPv4 depletion, I would suggest that the free market will take care of that problem for us.  Either IPv6 will get adopted and depletion will be fixed that way - or - the free market will find more IPv4 resources as needed a la http://www.hilcobid.net/auction/listOffers.htm?auction_id=13186&elementsPerPage=25#barranavegacaoleilao

I for one prefer that the allocation process work within the charter of Arin - but then I tried that route and was denied.  Does this community really want me and many others to go outside because of the arbitrary needs based policies.  I guess that is for this community to ultimately decide.

From: Bill Darte [mailto:billdarte at gmail.com]
Sent: Tuesday, April 30, 2013 7:53 PM
To: Steven Ryerse
Cc: Alexander, Daniel; Owen DeLong; ARIN-PPML List
Subject: Re: [arin-ppml] Clean up definition of LIR/ISP vs. end-user

Steven Ryerse wrote:
I believe that Arin and this community need to adopt a similar set of policies like have been proposed in Europe https://www.ripe.net/ripe/policies/proposals/2013-03  This would require a wholesale rewrite of a lot of policies which I am not capable of doing - but removing the needs requirements in all policies and just instituting right-sizing policies would be in line with Arin’s mission and be best for all.  I would support anyone willing to take the time to submit a proposal to Arin similar to the one above that has been proposed for RIPE.
Steven, please tell what right-sizing means to you and how that differs from assigning addresses according to an explicit need...
Thanks,
bd

On Tue, Apr 30, 2013 at 3:34 PM, Steven Ryerse <SRyerse at eclipse-networks.com<mailto:SRyerse at eclipse-networks.com>> wrote:
I agree with Daniel.  I strongly believe it is Arin’s charter and mission to further the Internet and not impede access to it.  Debating about what an organization is doing on the Internet or what they are called is really a discussion on how to limit access to the Internet.  I don’t believe that Arin should be trying to deny or limit an organization’s access to the Internet.  I believe Arin should be trying to expand the Internet for good of everyone as was done before Arin’s existence.  I’m all for right sizing an organizations access with reasonable polices but I am not in favor of policies that have the sole purpose of denying or restricting access to the Internet.

I believe that Arin and this community need to adopt a similar set of policies like have been proposed in Europe https://www.ripe.net/ripe/policies/proposals/2013-03  This would require a wholesale rewrite of a lot of policies which I am not capable of doing - but removing the needs requirements in all policies and just instituting right-sizing policies would be in line with Arin’s mission and be best for all.  I would support anyone willing to take the time to submit a proposal to Arin similar to the one above that has been proposed for RIPE.

Steven L Ryerse
President
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From: arin-ppml-bounces at arin.net<mailto:arin-ppml-bounces at arin.net> [mailto:arin-ppml-bounces at arin.net<mailto:arin-ppml-bounces at arin.net>] On Behalf Of Alexander, Daniel
Sent: Tuesday, April 30, 2013 3:54 PM
To: Owen DeLong; ARIN-PPML List
Subject: Re: [arin-ppml] Clean up definition of LIR/ISP vs. end-user

I suggest it is a worthwhile conversation to explore why they will be necessary?

If the Internet is a network of networks, why does ARIN, an RIR, need to make the distinctions in how it allocates or assigns resources? Why shouldn't ARIN simply allocate resources to networks, regardless of how they operate simply based on what they need?

Are we over complicating things, not only for the Registry, but for those who don't do this for a living who are struggling to understand what all this means and why?

This goes back to the original PI/PA debate. There are End User networks that dwarf many ISP/LIR networks and vise versa. Why should we maintain multiple layers of requirements to justify IPv4 transfers and an exceedingly large pool of IPv6 space?

-Dan

From: Owen DeLong <owen at delong.com<mailto:owen at delong.com>>
Date: Tue, 30 Apr 2013 11:36:30 -0700
To: Microsoft Office User <daniel_alexander at cable.comcast.com<mailto:daniel_alexander at cable.comcast.com>>
Cc: ARIN-PPML List <arin-ppml at arin.net<mailto:arin-ppml at arin.net>>
Subject: Re: [arin-ppml] Clean up definition of LIR/ISP vs. end-user

Dan,

The definitions apply to IPv6 as well.

I believe they are still necessary.

Owen

On Apr 29, 2013, at 20:37 , "Alexander, Daniel" <Daniel_Alexander at Cable.Comcast.com<mailto:Daniel_Alexander at Cable.Comcast.com>> wrote:

Hello All,

I would be curious to hear people's opinions of whether the distinctions are still necessary within ARIN policy. Once the IPv4 free pool is depleted, and the policies become focused on processing transfers, do we need to distinguish between End Users, non-End Users, and PA vs PI within ARIN policy?

What are the criteria in which these distinctions matter, and will they still apply next year?

Dan
ARIN AC

From: Scott Leibrand <scottleibrand at gmail.com<mailto:scottleibrand at gmail.com>>
Date: Mon, 29 Apr 2013 13:41:56 -0700
To: ARIN-PPML List <arin-ppml at arin.net<mailto:arin-ppml at arin.net>>
Subject: [arin-ppml] Clean up definition of LIR/ISP vs. end-user

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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