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

[Matthew Petach]

Hi Jamie,

As someone who faced a similar challenge many years ago, I'll chime in with
my thoughts on the matter...


On Mon, Jan 2, 2023 at 11:32 PM Jamie Nelson <nelsonjamie508 at gmail.com>
wrote:

> ARIN newbie here.
>
[...]

>
> 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.
>

You're providing services to people who are not directly employees,
contractors, or otherwise immediately affiliated with your organization.
I was in a similar boat, and after looking carefully at how law enforcement
approached ISPs for information versus end-users, we made a decision
to apply for resources as an ISP, as we provided services to people who
were not directly under our umbrella.

Once your resources are granted under the ISP rules, they remain that
way, even if your ISP business ceases to exist--though, the idea of an
ISP 'ceasing to exist' is a questionable one, since in almost every case,
a successor entity takes over the business, and the number resources
that go with the ISP business follow the customers to the new owner.
See for example the Sprint wireline ISP network being sold to Cogent;
the number resources don't stay with T-mobile, they go with the Sprint
customers currently using them over to Cogent.  If you eventually sell the
colocation business to someone else, you'll have to wrestle with how the
number resources are to be handled.  As such, I would strongly recommend
you allocate your number resources accordingly; if you think the ISP
business
may continue to grow, it may be worth registering 2 different ORG-IDs, one
for your (end-user-like) corporate network, and a separate one for the
(isp-like)
colocation business, so that if in the future you decide to divest the ISP
side
of the business, you can do so without having to perform massive surgery
on your network.  Just a thought on saving some potential renumbering
pain down the road.   ^_^;

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

Lisa already answered this; I would note that there's no secret police that
come after you if your business changes form down the road, it's really
your decision if you feel a better set of policies would apply if you were
to
reclassify your business.


> 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?
>

Functionally, the distinction is really about checking to see which
policies
your organization falls under when looking at your utilization to see if you
qualify for additional blocks; you should definitely read through
https://www.arin.net/resources/registry/reassignments/
to get a good understanding of the distinction.  So, it's not that a
specific
block is a direct assignment versus a direct allocation, it's that your
ORG-ID falls under utilization requirements for ISPs versus end users;
and because that can change all at once if you request a reclassification
of your organization, trying to identify block-by-block which rules they
fall
under becomes a nearly pointless exercise.


> 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?
>

As noted in the URL above, even end users aren't immune to the requirement
to track assignment of number resources.  As an ISP, you can punt the
tracking requirement for the number resources to your downstream customer,
or do it yourself; as an end-user, there's nobody else to punt the tracking
to,
it's all in your hands.  But either way, the number resources have to be
tracked,
either through your own Rwhois server, or through the SWIP system.

* 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.
>

To my point above--to simplify the situation, if it were me, I would
create two different ORG-IDs; one for your corporate network environment,
and one for your ISP business.  I would request number resources
appropriate to each.  I would make the corporate network a downstream
customer of the ISP network, but also get a second backup link so that
your corporate network stays functional even if the colocation side of the
business has a spectacular meltdown.  Thus, you would end up with two
different entities; a multihomed ISP network providing colocation services
to customers, and a multihomed end-user corporate network, which happens
to buy services from the ISP network as one of its upstreams.
That way, in the future, if you grow the ISP business, your number resource
utilization will be based on the customer growth, and not be hampered by
the
relatively unchanging corporate network side.  You can request and add
additional
number resources to the ISP ORG-ID unimpeded by the corporate network.
And,
if you eventually decide you want to divest the ISP side of the business,
you can
transfer the ORG-ID and associated number resources to the purchaser of the
business with relatively little impact to your end-user corporate network.

It's a little more initial work, setting up the two different ORG-IDs for
the two
different portions of the business, but it will simplify tracking number
resources,
requesting additional resources, and potentially selling off the ISP
business in
the future should you decide to do so.


> Thanks in advance for any insight.
>

Best of luck!

Thanks!

Matt
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