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

Andrew Dul andrew.dul at quark.net
Fri Aug 28 13:48:33 EDT 2015 

I believe there is value in allowing end-users to add reassignments for
organizations which they don't wholly control.  Gary, I think we will
have to just agree to disagree on that point.  I think your definition
fits with what you are hoping for, thanks for the text.

Andrew

On 8/28/2015 9:59 AM, Gary T. Giesen wrote:
> 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
>>>>>> ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
>>>>>> Unsubscribe or manage your mailing list subscription at:
>>>>>> http://lists.arin.net/mailman/listinfo/arin-ppml
>>>>>> Please contact info at arin.net if you experience any issues.
>>>>> _______________________________________________
>>>>> PPML
>>>>> You are receiving this message because you are subscribed to the
>>>>> ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
>>>>> Unsubscribe or manage your mailing list subscription at:
>>>>> http://lists.arin.net/mailman/listinfo/arin-ppml
>>>>> Please contact info at arin.net if you experience any issues.
>>>> _______________________________________________
>>>> PPML
>>>> You are receiving this message because you are subscribed to the ARIN
>>>> Public Policy Mailing List (ARIN-PPML at arin.net).
>>>> Unsubscribe or manage your mailing list subscription at:
>>>> http://lists.arin.net/mailman/listinfo/arin-ppml
>>>> Please contact info at arin.net if you experience any issues.
>> _______________________________________________
>> PPML
>> You are receiving this message because you are subscribed to the ARIN
>> Public Policy Mailing List (ARIN-PPML at arin.net).
>> Unsubscribe or manage your mailing list subscription at:
>> http://lists.arin.net/mailman/listinfo/arin-ppml
>> Please contact info at arin.net if you experience any issues.

More information about the ARIN-PPML mailing list