The following Draft Policy has been revised:

*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/

A PDF document showing the proposed NRPM edits is available to download at:

https://arin.net/participate/policy/drafts/pdf/ARIN_2025_1_diff_030526.pdf
 
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 ARIN-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 reframing 
and aligning with the term LIR, and replaces ISP with LIR throughout the NRPM 
as appropriate.

Policy Statement:

Update the Table of Contents, replacing ISP with LIR as follows:

4.2. Allocations to LIRs

4.2.2. Initial Allocation to LIRs

4.2.3.4.2. Downstream LIRs

4.2.4. LIR Additional Requests

6.5.4. Reassignments from LIR

 

Section 2:

Rewrite the LIR definition to provide clarity and relationship to ISP

2.4. Local Internet Registry (LIR) 

A Local Internet Registry (LIR) is an IR that is a member of an RIR, receives 
allocations of internet numbers from that RIR, for allocation to its customers, 
end-users, and infrastructure, at a local level. LIRs include Internet Service 
Providers (ISPs) whose customers are primarily end users and possibly other 
ISPs. Historically in the ARIN service region "ISP" was used as an equivalent, 
albeit incomplete, term.

 

Replace ISP with LIR:

2.15. Provider Assignment Unit (IPv6)

When applied to IPv6 policies, the term “provider assignment unit” shall mean 
the prefix of the smallest block a given LIR assigns to end sites (recommended 
/48).

 

Add new definition for ISP:

2.18 Internet Service Provider (ISP)

An Internet Service Provider (ISP) is a type of 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.

 

Section 3:

Replace only the first instance of ISP with LIR

3.6.3. Organizations Covered by this Policy

This policy applies to every Organization that has Internet number resources 
issued by ARIN (or one of its predecessor registries) or a reallocation from an 
upstream LIR. This includes but is not limited to upstream ISPs and their 
downstream ISP customers (as defined by NRPM 2.5 and 2.6), but not 
reassignments made to their downstream end user customers.

 

Section 4:

Replace ISP with LIR: in the following sections:

4.2. Allocations to LIRs (Requirements for Requesting Initial Address Space)

 

4.2.1.1. Purpose

ARIN allocates blocks of IP addresses to LIRs for the purpose of reassigning 
and reallocating that space to their customers.

 

4.2.1.5. Minimum Allocation

In general, ARIN allocates /24 and larger IP address prefixes to LIRs. If 
allocations smaller than /24 are needed, LIRs should request address space from 
their upstream provider.

 

4.2.2. Initial Allocation to LIRs

All LIR organizations without any IPv4 addresses from ARIN automatically 
qualify for an initial allocation of a /24. LIRs providing a 24-month 
utilization plan for the request size specified may receive up to a /22. LIRs 
holding reallocations and/or reassignments must show the efficient utilization 
of their resources consistent with the requirements in sections 4.2.3 and 4.2.4.

 

4.2.3.1. Efficient Utilization

LIRs are required to apply a utilization efficiency criterion in providing 
address space to their customers. To this end, LIRs should have documented 
justification available for each reassignment and reallocation. ARIN may 
request this justification at any time. If justification is not provided, 
future receipt of allocations may be impacted.

 

4.2.3.2. VLSM

To increase utilization efficiency of IPv4 address space, LIRs reassigning IP 
address space to their customers should require their customers to use variable 
length subnet mask (VLSM) and classless technologies (CIDR) within their 
networks. LIRs should issue blocks smaller than /24 wherever feasible.

 

4.2.3.3. Contiguous Blocks

IP addresses are allocated to LIRs in contiguous blocks, which should remain 
intact. Fragmentation of blocks is discouraged. To avoid fragmentation, LIRs 
are encouraged to require their customers to return address space if they 
change LIRs. Therefore, if a customer moves to another service provider or 
otherwise terminates a contract with an LIR, it is recommended that the 
customer return the network addresses to the LIR and renumber into the new 
provider's address space. The original LIR should allow sufficient time for the 
renumbering process to be completed before requiring the address space to be 
returned.

 

4.2.3.4. Downstream Customer Adherence

LIRs must require their downstream customers to adhere to the following 
criteria:

 

4.2.3.4.1. Utilization

A downstream customer requesting address space from an upstream LIR must 
document a plan to the allocating LIR for their utilization to conform to 
Section 4.3.3. Reassignment and reallocation information for prior allocations 
must show that each customer meets the 80% utilization criteria and must be 
available via SWIP / a distributed service which meets the standards set forth 
in section 3.2 prior to issuing them additional space.

 

4.2.3.4.2. Downstream LIRs

Customers must follow ARIN policy for LIRs.

 

4.2.3.6. Reassignments to Multihomed Downstream Customers

If a downstream customer has a requirement to multihome, that requirement alone 
will serve as justification for a /24 allocation. Downstream customers must 
provide contact information for all of their upstream providers to the LIR from 
whom they are requesting a /24, and utilize a border routing protocol between 
the customer and the ISP. Customers may receive a /24 from only one of their 
upstream providers under this policy without providing additional 
justification. LIRs may demonstrate they have made an assignment to a 
downstream customer under this policy by supplying ARIN with the information 
they collected from the customer, as described above, or by identifying the AS 
number of the customer.

 

4.2.3.7. Registration

LIRs are required to demonstrate efficient use of IP address space allocations 
by providing appropriate documentation, including but not limited to assignment 
histories, showing their efficient use.

 

4.2.3.8. Reassignments for Third Party Internet Access (TPIA) over Cable

IP addresses reassigned by an LIR to an incumbent cable operator for use with 
Third Party Internet Access (TPIA) will be counted as fully used once they are 
assigned to equipment by the underlying cable carrier provided they meet the 
following requirements:

 

4.2.4. LIR Additional Requests

 
4.2.4.1. Utilization Percentage (80%)

LIRs must have efficiently utilized all allocations, in aggregate, to at least 
80% and at least 50% of every allocation in order to receive additional space. 
This includes all space reassigned or reallocated to their customers.

 

4.2.4.3. Request Size

LIRs may request up to a 24-month supply of IPv4 addresses.

 

Section 6:

Update terminology  section to reference how ISP and LIR are used

6.5.1. Terminology

a. The terms ISP and LIR were previously used interchangeably in this section. 
Unless otherwise noted, the term ISP is treated as a subset of LIR.

 

Replace ISP with LIR in the following sections:

6.5.2.1 Size

a. All allocations shall be made on nibble boundaries.

b. In no case shall an LIR receive smaller than a /32 unless they specifically 
request a /36 or /40. In order to be eligible for a /40, an LIR 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 receive more than a /16 initial allocation.

g. An LIR 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’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’s 
current or former IPv4 address holdings.

 

6.5.2.2. Qualifications

An organization qualifies for an allocation under this policy if they meet any 
of the following criteria:

a. Have a previously justified IPv4 allocation from ARIN or one of its 
predecessor registries or can qualify for an IPv4 allocation under current 
criteria.

 

6.5.4. Reassignments from LIRs

6.5.5. Registration

LIRs 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.

 

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 
shall register that assignment as described in section 6.5.5.1.

 

6.5.8.1. Initial Assignment Criteria

f. By providing a reasonable technical justification indicating why IPv6 
addresses from an LIR are unsuitable.




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