[arin-ppml] Are we an ISP or an End-User? Can our designation change at a later time?

[Jamie Nelson]

ARIN newbie here.  I apologize in advance if these issues have already
been covered somewhere.  I also apologize if this list isn't the ideal
venue for these questions, but I suppose that some of them could point
to a need for clarification in the NRPM or elsewhere.  My organization
is not yet an ARIN member and there don't appear to be any
public-access listservs that are more appropriate.  (I see that a
public discussion list is in the works.)

The terms "ISP" and "LIR" are used interchangeably in this email, in
the spirit of section 6.5.1 of the NRPM.


Backstory:
I work for a company that is preparing to become multi-homed later
this month.  We currently use provider-reassigned address space, so we
are getting ready to request resources from ARIN and therefore need to
determine if we should classify ourselves as an ISP/LIR or as an
end-user.

If I were only to mention our primary business activity,
manufacturing, it would be pretty clear cut that we are an end-user.
Where it gets complicated, however, is that we are also running a
small-time colocation operation at our headquarters.  This began as an
accident, with us giving free hosting to a local nonprofit, but then
some other people asked if they could pay to keep their equipment
here.  We only have a handful of tenants, and they are mostly friends
of the company.  The rates we charge are only slightly higher than
break-even because we're not multihomed and we're not pretending to be
a proper colocation facility (yet).  Our "ISP" business has no
public-facing website and service is currently only offered by word of
mouth.  To date, the growth of this side-hustle has been severely
limited by our current upstream provider, which still hasn't
implemented IPv6 and charges exorbitant fees for IPv4 address space,
but things could change once we are multihomed and have our own direct
allocations.

Eventually, we will have to choose from one of two paths forward:
commit to providing a higher level of service and expand the ISP
operation so that it's worth our time, or shut it down and only
service our primary business (which, either way, needs IPv6 and robust
connectivity).  We would prefer to take the former path, as it will
give our technology operations greater scale, but it won't be clear
for at least another year which way we're headed. (once we've
addressed our current connectivity shortcomings and can better gauge
what existing and prospective customers are willing to pay)

Basically, in one to two years, we'll have either fully embraced our
role as an ISP, or we'll have exited that business and will be firmly
in the end-user camp.


Questions:
1.) From our reading of the NRPM, it seems like we currently fall
within the definition of an ISP, but what happens if this changes
subsequent to our initial allocation? (*)  Likewise, what happens if
an organization that was directly assigned resources as an end-user
begins offering Internet services to other organizations?  The NRPM
does not appear to address these scenarios.

3.) Is conversion from ISP to End User (and vice versa) possible if
the nature of an organization's business changes?  Is it necessary?

4.) Is ISP/end-user status recorded in ARIN's database on a per-prefix
basis, or is it per-organization?  How does one currently determine
this status from Whois?  I tried to find examples of organizations
that would typically be seen as end-users, but there were no clues in
their organizational Whois results, and Whois queries on their
prefixes all indicate "NetType: Direct Allocation", just like ISPs, as
opposed to "NetType: Direct Assignment".  This would be consistent
with a clue I found in the problem statement of Draft Policy
ARIN-2022-12, which indicates that "direct assignments are no longer
being utilized in ARIN databases", but does this then imply that the
ISP/end-user distinction has been eliminated entirely?

5.) Now that ISPs and end-users share the same fee schedule and voting
privileges, what distinctions remain, other than differences in
allocation rules and the obligation for ISPs to register
reassignments/reallocations?

* It can be assumed for the above questions that our organization type
(whether ISP or end-user) will not impact the size of the IPv6 prefix
that we qualify for and request, which we anticipate being /40.  In
the hypothetical scenario where we would want to convert from ISP to
end-user (assuming it's even possible), we wouldn't face the issue of
not qualifying for an IPv6 block as large as the one that we were
initially allocated as an ISP.  We have > 13 sites in our WAN.  I
would be curious, however, to understand what might happen if an ISP
were to have a larger allocation than that which it would qualify for
once becoming an end user.


Thanks in advance for any insight.