[arin-ppml] 2013-5 LIR/ISP and End-user Definitions

[John Santos]

On 15 Aug 2013 David.Huberman at microsoft.com wrote:
[...]

> 2) I think the proposal's solution ("if the customer and ARIN can't
> decide whether the customer is an ISP or an EU, then ARIN shall choose
> ISP") is actually harmful.  For a policy construct like 2013-5's text, I
> think the correct prescription would be selecting EU.  Current ISP policy
> (for both initial and additional requests) is much more punitive than the
> EU policy.  Off the top of my head, the major differences are: 
> 
> - ISPs have to be using upstream space already before qualifying for an
> initial allocation.  EUs do not. 
> - ISPs only get a three month supply of addresses.  EUs get twelve months.
> - ISPs have to SWIP.  EUs cannot SWIP.

- IIRC, ISPs must become ARIN members (IIRC, $500/year, applicable to their 
registration fees.)  For EUs, ARIN membership is optional.

$500/year is not much in the scheme of things if you are spreading it 
over thousands or millions of customers, especially if it can be deducted
from the registration fee, but for a small EU (with a legacy Class C), it 
is 10-20 times what we are paying for our domain name and 2-3 months worth
of connectivity.  It wouldn't be a deal-breaker, but it is significant.  (I
know we can't set fees with policy here, but we should be cognizant of them.)

If we needed more address space (or IPv6; we currently have ULA through 
SixXS, and are waiting on one or more of our ISPs to offer it to customers),
we would need to sign an RSA and start paying registration fees, so the
$500/year would become even less significant, but I think we are way too
small to qualify for direct allocation under current rules, so this is a
moot point.

On the other differences:

1) Prior upstream:  Is the point of this policy to ensure the potential
registrant has a history of use and hasn't been created from whole cloth?
Most EUs have a current ISP and at least a small block allocated to them.
Wouldn't or couldn't this meet the ISP requirement of having upstram
space?

2) Doesn't the 3-month supply of addresses apply only to IPv4, and is 
a result of incipient depletion?  In other words, it is a temporary
situation that will go away either on total exhaustion of IPv4 or
when IPv6 so takes over the world that v4 addresses are no longer
in demand.

3) Finally, ISPs must use some of their address space for infrastructure. 
Do they SWIP those addresses (to themselves) or does all the address space
default to the holder of it?  (I.E. no SWIP is required for infrastructure
or for currently unallocated addresses.)

Does the the infrastructure at ARIN to support SWIP constitute a
significant incremental cost to ARIN if all EUs were to start using it, or
is the cost to ARIN basically nothing, if like most EUs, an EU just
statically set all its addresses to the default state ("belongs to EU
foobar corp.) and left them that way for ever? 

Universities could decide whether to SWIP everything, nothing or some
subset (e.g. keep all the offices, labs, servers, infrastructure in the
default state of belonging to the .edu, but SWIP the dorm rooms and common
area WiFi to whoever is allocated the addresses.)

If this is the complete set of differences between ISPs (LIRs) and EUs,
they all seem resolvable and would basically let the user decide how it 
wants to interact with ARIN, based on its needs.


-- 
John Santos
Evans Griffiths & Hart, Inc.
781-861-0670 ext 539