[arin-ppml] Draft Policy ARIN-2015-8: Reassignment records for IPv4 End-Users

Gary T. Giesen ggiesen+arin-ppml at giesen.me
Fri Aug 28 12:59:24 EDT 2015 

I'd suggest something like this to define which entities reassignments can
be performed to:

1) A business department, division or sector which is not legally distinct
from address space holder
2) A subsidiary of the address space holder, where the parent has a
controlling interest
3) A sister company of the address space holder, where the parent company of
the address space holder holds a controlling interest in both daughter
companies

Of course, since I am neither a lawyer nor an expert in corporate structures
this should be reviewed by legal, but my basic intention is that there be a
single, common ownership between the address holder and the reassignees. I
included #3 because there may be a subsidiary which handles IT/network
services for its sister companies.

Cheers,

GTG

> -----Original Message-----
> From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On
> Behalf Of Andrew Dul
> Sent: August 27, 2015 12:38 PM
> To: Gary T. Giesen; arin-ppml at arin.net
> Subject: Re: [arin-ppml] Draft Policy ARIN-2015-8: Reassignment records
for
> IPv4 End-Users
> 
> 
> On 8/26/2015 12:08 PM, Gary T. Giesen wrote:
> > Andrew,
> >
> > If that's your approach, why not create policy to create one class of
> > user, and remove the distinction altogether?
> I have contemplated such an approach and even drafted, about 2 years ago,
> a post-IPV4-exhaustion policy rewrite, which collapsed the distinction
> between ISPs and end-users.  In discussing this idea within the AC and
other
> community members, they believed at that time that was too much for the
> community to handle.  The community in the past has noted that omnibus
> style policy rewrites are generally not accepted by the larger community.
> 
> This policy proposal is a way to start the discussion between the ISP /
end-
> user differences.  If the wider community support the idea of fully
collapsing
> the two categories, we can continue that direction.  If not, that is OK,
too.
> 
> 
> > ISPs pay more because they receive
> > more in services, and because they make money "leasing" IPs. If you
> > make it so that ISPs can get the same set of services as end users
> > (and start applying as end-users), then end-user fees will have to
> > increase appropriately, in order to avoid decreasing ARIN's overall
> > revenues. A lot of end-users will not want that, to satisfy the wants
> > of a few very large orgs, for a service which they may even not know
> > exists (and have no desire to use it)
> >
> > All I'm talking about is putting in some language to guard against
> > obvious fraud, and keep costs down for end-users (since they
> > presumably won't have anywhere near the ratio of SWIPs/block). It's
> > not going to stop an ISP determined to go the end-user route, but will
> > hopefully steer the well-meaning ISPs down the correct path and could
> > make it easier to revoke blocks for blatent fraud.
> 
> Do you have any language that you'd like to see added to the draft such
that
> you could support it?
> 
> > A lot of what's in the NRPM already is hard to enforce, but that
> > doesn't stop us from trying to create policies for fair
> > allocations/assignments, with reasonable controls. I think some plain
> > language about what is and is not an acceptable SWIP for an end-user
> > is appropriate. What I don't want to see if the ISP/end-user classes
> > merging by being back-doored through a policy with no limits.
> 
> Some of the examples of what I thought were acceptable reassignments I
> put in the problem statement.  Would you support those types of
> reassignment records being allowed for end-users?
> 
> Andrew
> 
> >> -----Original Message-----
> >> From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net]
> >> On Behalf Of Andrew Dul
> >> Sent: August 26, 2015 2:34 PM
> >> To: arin-ppml at arin.net
> >> Subject: Re: [arin-ppml] Draft Policy ARIN-2015-8: Reassignment
> >> records
> > for
> >> IPv4 End-Users
> >>
> >> Shouldn't operators get to decide and be responsible for what records
> >> they put in the database?  I understand that the potential for
> >> mis-use of
> > additional
> >> reassignments, but there is already that potential for ISPs.  Do you
> >> feel
> > that
> >> we need to address mis-use with ISP reassignments too?
> >>
> >> One could create all sorts of "schemes" to limit the ability of ISP
> >> users
> > to
> >> "game" the system as end users.  Fee per reassignment record, or 10
> >> reassignments per end-user w/ additional records costing more...
> >>
> >> Or maybe we just need to think about if the differences between ISPs
> >> and end-users matter as much in a IPv4 depleted world.
> >>
> >> While this policy likely has downstream fee implications, it is not
> > designed to
> >> map to any particular fee structure.  I haven't seen any details on
> >> any proposed fee changes so I could not take that into account when
> >> drafting
> > this
> >> policy.
> >>
> >> Andrew
> >>
> >> On 8/26/2015 10:18 AM, Gary T. Giesen wrote:
> >>> I am opposed to the policy as written.
> >>>
> >>> There are few to no controls on who the end user can SWIP to, which
> >>> I think will either result in ISPs applying as end-users to game the
> >>> system, raise the cost for end users, or both.
> >>>
> >>> I assume this is trying to align the NRPM to ARIN's new fee
> >>> structure which I believe is due in September?
> >>>
> >>> Cheers,
> >>>
> >>> GTG
> >>>
> >>>> -----Original Message-----
> >>>> From: arin-ppml-bounces at arin.net
> >>>> [mailto:arin-ppml-bounces at arin.net]
> >>>> On Behalf Of ARIN
> >>>> Sent: August 25, 2015 3:12 PM
> >>>> To: arin-ppml at arin.net
> >>>> Subject: [arin-ppml] Draft Policy ARIN-2015-8: Reassignment records
> >>>> for
> >>> IPv4
> >>>> End-Users
> >>>>
> >>>> Draft Policy ARIN-2015-8
> >>>> Reassignment records for IPv4 End-Users
> >>>>
> >>>> On 20 August 2015 the ARIN Advisory Council (AC) accepted
> >>>> "ARIN-prop-222 Reassignment records for IPv4 End-Users" as a Draft
> >> Policy.
> >>>> Draft Policy ARIN-2015-8 is below and can be found at:
> >>>> https://www.arin.net/policy/proposals/2015_8.html
> >>>>
> >>>> You are encouraged to discuss the merits and your concerns of Draft
> >>>> Policy
> >>>> 2015-8 on the Public Policy Mailing List.
> >>>>
> >>>> The AC will evaluate the discussion in order to assess the
> >>>> conformance of
> >>> this
> >>>> draft policy with ARIN's Principles of Internet Number Resource
> >>>> Policy as stated in the PDP. Specifically, these principles are:
> >>>>
> >>>>      * Enabling Fair and Impartial Number Resource Administration
> >>>>      * Technically Sound
> >>>>      * Supported by the Community
> >>>>
> >>>> The ARIN Policy Development Process (PDP) can be found at:
> >>>> https://www.arin.net/policy/pdp.html
> >>>>
> >>>> Draft Policies and Proposals under discussion can be found at:
> >>>> https://www.arin.net/policy/proposals/index.html
> >>>>
> >>>> Regards,
> >>>>
> >>>> Communications and Member Services
> >>>> American Registry for Internet Numbers (ARIN)
> >>>>
> >>>>
> >>>> ## * ##
> >>>>
> >>>>
> >>>> Draft Policy ARIN-2015-8
> >>>> Reassignment records for IPv4 End-Users
> >>>>
> >>>> Date: 25 August 2015
> >>>>
> >>>> Problem statement:
> >>>>
> >>>> End-User Organizations do not have the ability to create
> >>>> reassignment records in the number resource database.
> >>>>
> >>>> Reassignment records can be used for a number of different
> >>>> functions which could benefit the overall desire to increase
> >>>> database accuracy by allowing organizations to add additional details
in
> the database.
> >>>>
> >>>> The following reasons have been noted as positive reasons to allow
> >>>> the creation of additional records.
> >>>> - Geolocation (allows an organization to specify a different
> >>>> location
> >>> within the
> >>>> database which is used by organizations creating geo-location by IP
> >>> address
> >>>> databases)
> >>>> - Subsidiary reassignment (allows an organization to note that a
> >>>> portion
> >>> of
> >>>> their netblock is in use by a different subsidiary entity)
> >>>> - Assignment to contracted parties (some organizations have
> >>>> contracts with other organizations which are operating networks
> >>>> under agreements with the registrant, this allows the top-level
> >>>> organizations to accurately
> >>> specify the
> >>>> organization operating the network in the number resource database)
> >>>> - More specific contact information (some organizations operate
> >>>> large networks which don't necessarily have the same technical or
> >>>> abuse contact
> >>>> information)
> >>>>
> >>>> Policy statement:
> >>>>
> >>>> Create new section 4.3.x
> >>>>
> >>>> End-user organizations which have an active registration services
> >>> agreement
> >>>> shall be permitted to create reassignment records in the number
> >>>> resource database. Organizations shall use the guidelines outlined
> >>>> in section 4.2.3 when creating reassignment records.
> >>>>
> >>>> Comments:
> >>>> a. Timetable for implementation: immediately b. Anything else:
> >>>>
> >>>> It is noted by the author of this policy proposal that one of the
> >>> distinctions in
> >>>> the service between ISPs and End-Users has been the ability for an
> >>>> organization to create reassignment records.
> >>>>
> >>>> This policy proposal stretches across responsibilities areas as it
> >>>> impacts number policy, ARIN operational practice, and fees.
> >>>>
> >>>> Below we have noted the three areas and the different
> responsibilities:
> >>>>
> >>>> A) Providing reassignment support for end-user assignments, for
> >>>> those who wish to use it
> >>>>
> >>>> This is an ARIN Service issue - could be an suggestion/consultation
> >>> process,
> >>>> so long as any implied additional workload/cost can be accommodated
> >>>> in budget and the community supports
> >>>>
> >>>> B) New requirement on end-users to provide reassignment
> information
> >>>> in certain circumstances so that ARIN will treat their usage
> >>>> assertion
> >>> credibly
> >>>> This is a policy issue. These requirements should be vetted through
> >>>> the
> >>> policy
> >>>> development process.
> >>>>
> >>>> C) Fee Implications of ISPs moving to end-user category
> >>>>
> >>>> This is Board issue, but first requires a community discussion or
> >>> consultation
> >>>> to be held to solicit community input on desired outcome.
> >>>> _______________________________________________
> >>>> PPML
> >>>> You are receiving this message because you are subscribed to the
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> >>>> Unsubscribe or manage your mailing list subscription at:
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> >>>> Please contact info at arin.net if you experience any issues.
> >>> _______________________________________________
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> >> _______________________________________________
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