[arin-ppml] Revised - Draft Policy ARIN-2025-1: Clarify ISP and LIR definitions and references to address ambiguity in NRPM text

Thu Mar 20 10:29:35 EDT 2025

We have a similar discussion on redlining already with the comms team at
ARIN from the AC and are trying to work on options. This does involve some
additional work by ARIN staff and potentially a suggestion to make
improvements to the policy section. The AC does agree some of these larger
policies can be very difficult to parse through without the redline. We
will continue to work with Hollis and team to see what our path forward is
for this.

Kat Hunter

On Thu, Mar 20, 2025, 12:06 AM Martin Hannigan <hannigan at gmail.com> wrote:

>
> You could put a redline on a variety a clouds and do a referral URL.
>
>
> On Wed, Mar 19, 2025 at 23:51 Kat Hunter <takokat81 at gmail.com> wrote:
>
>> Many in the community have email set to plain text only. For the benefit
>> of the entire community we try to not send email that is unreadable by
>> adding redline.
>>
>> Kat
>>
>> On Wed, Mar 19, 2025, 11:36 PM Martin Hannigan <hannigan at gmail.com>
>> wrote:
>>
>>> Why can’t there be a redline now?
>>>
>>> On Wed, Mar 19, 2025 at 23:15 Douglas Camin <doug at dougcamin.com> wrote:
>>>
>>>> Martin -
>>>>
>>>> To make this readable via plaintext formats, when I originally wrote
>>>> it, I came up with the tactic of adding an underscore character before and
>>>> after every change inline. This seemed easier to see the changes instead of
>>>> making two large text blocks with no easy way to identify what was altered
>>>> when it mostly was adding “LIR” or “ISP” to the various references.
>>>>
>>>> Hope that helps (and as Kat said, there will be a redline at ARN55.)
>>>>
>>>>
>>>> Doug
>>>>
>>>>
>>>>
>>>>
>>>>
>>>> --
>>>>
>>>> Douglas J. Camin
>>>>
>>>> doug at dougcamin.com
>>>> From: ARIN-PPML <arin-ppml-bounces at arin.net> on behalf of Martin
>>>> Hannigan <hannigan at gmail.com>
>>>> Date: Wednesday, March 19, 2025 at 11:04 PM
>>>> To: ARIN <info at arin.net>
>>>> Cc: arin-ppml at arin.net <arin-ppml at arin.net>
>>>> Subject: Re: [arin-ppml] Revised - Draft Policy ARIN-2025-1: Clarify
>>>> ISP and LIR definitions and references to address ambiguity in NRPM text
>>>>
>>>>
>>>> A redline would be useful and easier to understand the ask accompanying
>>>> such a large post.
>>>>
>>>> Warm regards,
>>>>
>>>> -M<
>>>>
>>>>
>>>>
>>>> On Wed, Mar 19, 2025 at 16:22 ARIN <info at arin.net> wrote:
>>>>
>>>>> The following Draft Policy has been revised:
>>>>>
>>>>> *Draft Policy ARIN-2025-1: Clarify ISP and LIR definitions and
>>>>> references to address ambiguity in NRPM text
>>>>>
>>>>> Revised text is below and can be found at:
>>>>>
>>>>> https://www.arin.net/participate/policy/drafts/2025_1/
>>>>>
>>>>> You are encouraged to discuss all Draft Policies on PPML. The AC will
>>>>> evaluate the discussion to assess the conformance of this Draft Policy with
>>>>> ARIN's Principles of Internet number resource policy as stated in the
>>>>> Policy Development Process (PDP). Specifically, these principles are:
>>>>>
>>>>> * Enabling Fair and Impartial Number Resource Administration
>>>>> * Technically Sound
>>>>> * Supported by the Community
>>>>>
>>>>> The PDP can be found at:
>>>>>
>>>>> https://www.arin.net/participate/policy/pdp/
>>>>>
>>>>> Draft Policies and Proposals under discussion can be found at:
>>>>>
>>>>> https://www.arin.net/participate/policy/drafts/
>>>>>
>>>>>
>>>>> Regards,
>>>>>
>>>>> Eddie Diego
>>>>> Policy Analyst
>>>>> American Registry for Internet Numbers (ARIN)
>>>>>
>>>>>
>>>>>
>>>>> Draft Policy 2025-1: Clarify ISP and LIR definitions and references to
>>>>> address ambiguity in NRPM text
>>>>>
>>>>> Problem Statement:
>>>>>
>>>>> Section 2.4 of the NRPM defines an LIR but does not explicitly define
>>>>> an ISP. An ISP is defined in the context of an LIR, but the explicit
>>>>> definition is otherwise assumed.
>>>>>
>>>>> Through implication and in common business practice, all ISPs are
>>>>> LIRs, but not all LIRs are ISPs.
>>>>>
>>>>> This proposal adds clarity by creating an explicit definition for ISP,
>>>>> removing an ambiguous word and clarification on usage for the term LIR,
>>>>> removing an ambiguous terminology statement in Section 6.5.1a, and changing
>>>>> terms in Section 6.5 to explicitly state it applies to “LIR/ISP,” thus
>>>>> fulfilling the original intent of 6.5.1a, in all appropriate locations.
>>>>>
>>>>> Policy Statement:
>>>>>
>>>>> Add Internet Service Provider definition:
>>>>>
>>>>> Remove the word “primarily” from the definition of LIR and add usage
>>>>> clarification:
>>>>>
>>>>> FROM: 2.4. Local Internet Registry (LIR)
>>>>>
>>>>> A Local Internet Registry (LIR) is primarily an IR that assigns IP
>>>>> addresses to the users of the network services that it provides. LIRs are
>>>>> generally Internet Service Providers (ISPs) whose customers are primarily
>>>>> end users and possibly other ISPs.
>>>>>
>>>>> TO: 2.4. Local Internet Registry (LIR)
>>>>>
>>>>> A Local Internet Registry (LIR) is an IR that assigns IP addresses to
>>>>> the users of the network services that it provides. LIRs are generally
>>>>> Internet Service Providers (ISPs) whose customers are primarily end users
>>>>> and possibly other ISPs.
>>>>>
>>>>> Add definition for ISP:
>>>>>
>>>>> 2.18 Internet Service Provider
>>>>>
>>>>> An Internet Service Provider (ISP) is a type of LIR organization that
>>>>> provides Internet services to other organizations, its customers, and\or
>>>>> individuals other than its employees. Internet services include, but are
>>>>> not limited to, connectivity services, web services, colocation, dedicated
>>>>> servers, virtual private servers, and virtual private networks.
>>>>>
>>>>> Replace Section 6.5.1a
>>>>>
>>>>> Original Text: “The terms ISP and LIR are used interchangeably in this
>>>>> document and any use of either term shall be construed to include both
>>>>> meanings.”
>>>>>
>>>>> New Text: “[Retired]”
>>>>>
>>>>> Change all references in section 6.5 to use LIR/ISP, where appropriate:
>>>>>
>>>>> [Editing note: For the purposes of clarity in plaintext communication
>>>>> mediums, any addition of LIR or ISP to the text is denoted with the
>>>>> underscore character before and after the insertion. The underscore
>>>>> character is not considered a part of the final text.]
>>>>>
>>>>> Amend Section 6.5.2 to add ISP and LIR in 15 locations
>>>>>
>>>>> 6.5.2. Initial Allocation to LIRs_/ISPs_
>>>>>
>>>>> 6.5.2.1. Size
>>>>>
>>>>> 1. All allocations shall be made on nibble boundaries.
>>>>>
>>>>> 2. In no case shall an LIR_/ISP_ receive smaller than a /32 unless
>>>>> they specifically request a /36 or /40. In order to be eligible for a /40,
>>>>> an _LIR/_ISP must meet the following requirements:
>>>>>
>>>>> * Hold IPv4 direct allocations totaling a /24 or less (to include
>>>>> zero)
>>>>> * Hold IPv4 reassignments/reallocations totaling a /22 or less (to
>>>>> include zero)
>>>>>
>>>>> In no case shall an _LIR/_ISP receive more than a /16 initial
>>>>> allocation.
>>>>>
>>>>> 3. The maximum allowable allocation shall be the smallest
>>>>> nibble-boundary aligned block that can provide an equally sized
>>>>> nibble-boundary aligned block to each of the requesters serving sites large
>>>>> enough to satisfy the needs of the requesters largest single serving site
>>>>> using no more than 75% of the available addresses.
>>>>>
>>>>> This calculation can be summarized as /N where N = P-(X+Y) and P is
>>>>> the organization’s Provider Allocation Unit X is a multiple of 4 greater
>>>>> than 4/3serving sites and Y is a multiple of 4 greater than 4/3end sites
>>>>> served by largest serving site.
>>>>>
>>>>> 4. For purposes of the calculation in (c), an end site which can
>>>>> justify more than a /48 under the end-user assignment criteria in 6.5.8
>>>>> shall count as the appropriate number of /48s that would be assigned under
>>>>> that policy.
>>>>>
>>>>> 5. For purposes of the calculation in (c), an LIR_/ISP_ which has
>>>>> subordinate LIRs_/ISPs_ shall make such reallocations according to the same
>>>>> policies and criteria as ARIN. In such a case, the prefixes necessary for
>>>>> such a reallocation should be treated as fully utilized in determining the
>>>>> block sizing for the parent LIR_/ISP_. LIRs_/ISPs_ which do not receive
>>>>> resources directly from ARIN will not be able to make such reallocations to
>>>>> subordinate LIRs_/ISPs_ and subordinate LIRs_/ISPs_ which need more than a
>>>>> /32 shall apply directly to ARIN.
>>>>>
>>>>> 6. An LIR_/ISP_ is not required to design or deploy their network
>>>>> according to this structure. It is strictly a mechanism to determine the
>>>>> largest IP address block to which the LIR_/ISP_ is entitled.
>>>>>
>>>>> 7. An LIR_/ISP_ that requests a smaller /36 or /40 allocation is
>>>>> entitled to expand the allocation to any nibble aligned size up to /32 at
>>>>> any time without renumbering or additional justification. /40 allocations
>>>>> shall be automatically upgraded to /36 if at any time said LIR_/ISP_’s IPv4
>>>>> direct allocations exceed a /24. Expansions up to and including a /32 are
>>>>> not considered subsequent allocations, however any expansions beyond /32
>>>>> are considered subsequent allocations and must conform to section 6.5.3.
>>>>> Partial returns of any IPv6 allocation that results in less than a /36 of
>>>>> holding are not permitted regardless of the _LIR/_ISP’s current or former
>>>>> IPv4 address holdings.
>>>>>
>>>>> Amend Section 6.5.2.2 to add LIR in 2 locations:
>>>>>
>>>>> 6.5.2.2. Qualifications
>>>>>
>>>>> An organization qualifies for an allocation under this policy if they
>>>>> meet any of the following criteria:
>>>>>
>>>>> 1. Have a previously justified IPv4 _LIR/_ISP allocation from ARIN or
>>>>> one of its predecessor registries or can qualify for an IPv4 _LIR/_ISP
>>>>> allocation under current criteria.
>>>>>
>>>>> 2. Are currently multihomed for IPv6 or will immediately become
>>>>> multihomed for IPv6 using a valid assigned global AS number. In either
>>>>> case, they will be making reassignments or reallocations from allocation(s)
>>>>> under this policy to other organizations.
>>>>>
>>>>> 3. Provide ARIN a reasonable technical justification indicating why an
>>>>> allocation is necessary. Justification must include the intended purposes
>>>>> for the allocation and describe the network infrastructure the allocation
>>>>> will be used to support. Justification must also include a plan detailing
>>>>> anticipated reassignments and reallocations to other organizations or
>>>>> customers for one, two and five year periods, with a minimum of 50
>>>>> assignments within 5 years.
>>>>>
>>>>> Amend Section 6.5.3 to add ISP in 4 locations:
>>>>>
>>>>> 6.5.3. Subsequent Allocations to LIRs_/ISPs_
>>>>>
>>>>> 1. Where possible ARIN will make subsequent allocations by expanding
>>>>> the existing allocation.
>>>>>
>>>>> 2. An LIR_/ISP_ qualifies for a subsequent allocation if they meet any
>>>>> of the following criteria:
>>>>>
>>>>> * Shows utilization of 75% or more of their total address space
>>>>> * Shows utilization of more than 90% of any serving site
>>>>> * Has allocated more than 90% of their total address space to serving
>>>>> sites, with the block size allocated to each serving site being justified
>>>>> based on the criteria specified in section 6.5.2
>>>>>
>>>>> 3. If ARIN can not expand one or more existing allocations, ARIN shall
>>>>> make a new allocation based on the initial allocation criteria above. The
>>>>> LIR_/ISP_ is encouraged, but not required to renumber into the new
>>>>> allocation over time and return any allocations no longer in use.
>>>>>
>>>>> 4. If an LIR_/ISP_ has already reached a /12 or more, ARIN will
>>>>> allocate a single additional /12 rather than continue expanding nibble
>>>>> boundaries.
>>>>>
>>>>> Amend Section 6.5.4.1 to add ISP in 1 location:
>>>>>
>>>>> 6.5.4.1. Reassignment to Operator’s Infrastructure
>>>>>
>>>>> An LIR_/ISP_ may reassign up to a /48 per PoP as well as up to an
>>>>> additional /48 globally for its own infrastructure.
>>>>>
>>>>> Amend Section 6.5.5 to add LIR in 1 location:
>>>>>
>>>>> 6.5.5. Registration
>>>>>
>>>>> _LIRs/_ISPs are required to demonstrate efficient use of IP address
>>>>> space allocations by providing appropriate documentation, including but not
>>>>> limited to reassignment and reallocation histories, showing their efficient
>>>>> use.
>>>>>
>>>>> Amend Section 6.5.5.4 to add LIR in 1 location:
>>>>>
>>>>> 6.5.5.4. Registration Requested by Recipient
>>>>>
>>>>> If the downstream recipient of a static assignment of /64 or more
>>>>> addresses requests publishing of that assignment in ARIN’s registration
>>>>> database, the _LIR/_ISP shall register that assignment as described in
>>>>> section 6.5.5.1.
>>>>>
>>>>> Amend Section 6.5.7 to add ISP in 1 location:
>>>>>
>>>>> 6.5.7. Existing IPv6 Address Space Holders
>>>>>
>>>>> LIRs_/ISPs_ which received an allocation under previous policies which
>>>>> is smaller than what they are entitled to under this policy may receive a
>>>>> new initial allocation under this policy. If possible, ARIN will expand
>>>>> their existing allocation.
>>>>>
>>>>> Amend Section 6.5.9 to add LIR and ISP in 2 locations:
>>>>>
>>>>> 6.5.9. Community Network Allocations
>>>>>
>>>>> While community networks would normally be considered to be LIR/ISP
>>>>> type organizations under existing ARIN criteria, they tend to operate on
>>>>> much tighter budgets and often depend on volunteer labor. As a result, they
>>>>> tend to be much smaller and more communal in their organization rather than
>>>>> provider/customer relationships of commercial ISPs. This section seeks to
>>>>> provide a policy that is more friendly to those environments by allowing
>>>>> community network to receive a smaller allocation than other LIRs or
>>>>> commercial ISPs. Community networks may also qualify under section 6.5.2 as
>>>>> a regular LIR/ISP.
>>>>>
>>>>> Amend Section 6.5.9.2 to add ISP in 1 location:
>>>>>
>>>>> 6.5.9.2. Allocation Size
>>>>>
>>>>> Community networks are eligible only to receive an allocation of /40
>>>>> of IPv6 resources under this section. Community networks that wish to
>>>>> receive a larger initial allocation or any subsequent allocations must
>>>>> qualify as a regular LIR_/ISP_, see sections 6.5.2 or 6.5.3 respectively.
>>>>>
>>>>> Amend Section 6.5.9.3 to add ISP in 1 location:
>>>>>
>>>>> 6.5.9.3. Reassignments by Community Networks
>>>>>
>>>>> Similar to other LIRs_/ISPs_, Community networks shall make
>>>>> reassignments to end-users in accordance with applicable policies, in
>>>>> particular, but not limited to sections 6.5.4 and 6.5.5. However, they
>>>>> shall not reallocate resources under this section.
>>>>>
>>>>> Timetable for Implementation: Immediate.
>>>>>
>>>>>
>>>>> _______________________________________________
>>>>> ARIN-PPML
>>>>> You are receiving this message because you are subscribed to
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>>>>> Unsubscribe or manage your mailing list subscription at:
>>>>> https://lists.arin.net/mailman/listinfo/arin-ppml
>>>>> Please contact info at arin.net if you experience any issues.
>>>>>
>>>> _______________________________________________
>>>> ARIN-PPML
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>>>> Please contact info at arin.net if you experience any issues.
>>>>
>>> _______________________________________________
>>> ARIN-PPML
>>> You are receiving this message because you are subscribed to
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>>
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