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

Fri Aug 28 13:56:30 EDT 2015

Andrew,

Not to beat a dead horse, but I think if an org wants to (or is required to)
make assignments to entities that don't fit that definition, then they
should apply for an ISP block (or have their existing block converted) and
pay the appropriate fees, and allow the rest of us to keep end-user fees
low.

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 28, 2015 1:49 PM
> To: arin-ppml at arin.net
> Subject: Re: [arin-ppml] Draft Policy ARIN-2015-8: Reassignment records
for
> IPv4 End-Users
> 
> 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
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> >>>>>> 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.
> >>>>> _______________________________________________
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> >>>> _______________________________________________
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> >> _______________________________________________
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