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 <[email protected]> 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 > the ARIN Public Policy Mailing List ([email protected]). > Unsubscribe or manage your mailing list subscription at: > https://lists.arin.net/mailman/listinfo/arin-ppml > Please contact [email protected] if you experience any issues. >
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