I believe there is value in allowing end-users to add reassignments for organizations which they don't wholly control. Gary, I think we will have to just agree to disagree on that point. I think your definition fits with what you are hoping for, thanks for the text.
Andrew On 8/28/2015 9:59 AM, Gary T. Giesen wrote: > I'd suggest something like this to define which entities reassignments can > be performed to: > > 1) A business department, division or sector which is not legally distinct > from address space holder > 2) A subsidiary of the address space holder, where the parent has a > controlling interest > 3) A sister company of the address space holder, where the parent company of > the address space holder holds a controlling interest in both daughter > companies > > Of course, since I am neither a lawyer nor an expert in corporate structures > this should be reviewed by legal, but my basic intention is that there be a > single, common ownership between the address holder and the reassignees. I > included #3 because there may be a subsidiary which handles IT/network > services for its sister companies. > > Cheers, > > GTG > >> -----Original Message----- >> From: [email protected] [mailto:[email protected]] On >> Behalf Of Andrew Dul >> Sent: August 27, 2015 12:38 PM >> To: Gary T. Giesen; [email protected] >> Subject: Re: [arin-ppml] Draft Policy ARIN-2015-8: Reassignment records > for >> IPv4 End-Users >> >> >> On 8/26/2015 12:08 PM, Gary T. Giesen wrote: >>> Andrew, >>> >>> If that's your approach, why not create policy to create one class of >>> user, and remove the distinction altogether? >> I have contemplated such an approach and even drafted, about 2 years ago, >> a post-IPV4-exhaustion policy rewrite, which collapsed the distinction >> between ISPs and end-users. In discussing this idea within the AC and > other >> community members, they believed at that time that was too much for the >> community to handle. The community in the past has noted that omnibus >> style policy rewrites are generally not accepted by the larger community. >> >> This policy proposal is a way to start the discussion between the ISP / > end- >> user differences. If the wider community support the idea of fully > collapsing >> the two categories, we can continue that direction. If not, that is OK, > too. >> >>> ISPs pay more because they receive >>> more in services, and because they make money "leasing" IPs. If you >>> make it so that ISPs can get the same set of services as end users >>> (and start applying as end-users), then end-user fees will have to >>> increase appropriately, in order to avoid decreasing ARIN's overall >>> revenues. A lot of end-users will not want that, to satisfy the wants >>> of a few very large orgs, for a service which they may even not know >>> exists (and have no desire to use it) >>> >>> All I'm talking about is putting in some language to guard against >>> obvious fraud, and keep costs down for end-users (since they >>> presumably won't have anywhere near the ratio of SWIPs/block). It's >>> not going to stop an ISP determined to go the end-user route, but will >>> hopefully steer the well-meaning ISPs down the correct path and could >>> make it easier to revoke blocks for blatent fraud. >> Do you have any language that you'd like to see added to the draft such > that >> you could support it? >> >>> A lot of what's in the NRPM already is hard to enforce, but that >>> doesn't stop us from trying to create policies for fair >>> allocations/assignments, with reasonable controls. I think some plain >>> language about what is and is not an acceptable SWIP for an end-user >>> is appropriate. What I don't want to see if the ISP/end-user classes >>> merging by being back-doored through a policy with no limits. >> Some of the examples of what I thought were acceptable reassignments I >> put in the problem statement. Would you support those types of >> reassignment records being allowed for end-users? >> >> Andrew >> >>>> -----Original Message----- >>>> From: [email protected] [mailto:[email protected]] >>>> On Behalf Of Andrew Dul >>>> Sent: August 26, 2015 2:34 PM >>>> To: [email protected] >>>> Subject: Re: [arin-ppml] Draft Policy ARIN-2015-8: Reassignment >>>> records >>> for >>>> IPv4 End-Users >>>> >>>> Shouldn't operators get to decide and be responsible for what records >>>> they put in the database? I understand that the potential for >>>> mis-use of >>> additional >>>> reassignments, but there is already that potential for ISPs. Do you >>>> feel >>> that >>>> we need to address mis-use with ISP reassignments too? >>>> >>>> One could create all sorts of "schemes" to limit the ability of ISP >>>> users >>> to >>>> "game" the system as end users. Fee per reassignment record, or 10 >>>> reassignments per end-user w/ additional records costing more... >>>> >>>> Or maybe we just need to think about if the differences between ISPs >>>> and end-users matter as much in a IPv4 depleted world. >>>> >>>> While this policy likely has downstream fee implications, it is not >>> designed to >>>> map to any particular fee structure. I haven't seen any details on >>>> any proposed fee changes so I could not take that into account when >>>> drafting >>> this >>>> policy. >>>> >>>> Andrew >>>> >>>> On 8/26/2015 10:18 AM, Gary T. Giesen wrote: >>>>> I am opposed to the policy as written. >>>>> >>>>> There are few to no controls on who the end user can SWIP to, which >>>>> I think will either result in ISPs applying as end-users to game the >>>>> system, raise the cost for end users, or both. >>>>> >>>>> I assume this is trying to align the NRPM to ARIN's new fee >>>>> structure which I believe is due in September? >>>>> >>>>> Cheers, >>>>> >>>>> GTG >>>>> >>>>>> -----Original Message----- >>>>>> From: [email protected] >>>>>> [mailto:[email protected]] >>>>>> On Behalf Of ARIN >>>>>> Sent: August 25, 2015 3:12 PM >>>>>> To: [email protected] >>>>>> Subject: [arin-ppml] Draft Policy ARIN-2015-8: Reassignment records >>>>>> for >>>>> IPv4 >>>>>> End-Users >>>>>> >>>>>> Draft Policy ARIN-2015-8 >>>>>> Reassignment records for IPv4 End-Users >>>>>> >>>>>> On 20 August 2015 the ARIN Advisory Council (AC) accepted >>>>>> "ARIN-prop-222 Reassignment records for IPv4 End-Users" as a Draft >>>> Policy. >>>>>> Draft Policy ARIN-2015-8 is below and can be found at: >>>>>> https://www.arin.net/policy/proposals/2015_8.html >>>>>> >>>>>> You are encouraged to discuss the merits and your concerns of Draft >>>>>> Policy >>>>>> 2015-8 on the Public Policy Mailing List. >>>>>> >>>>>> The AC will evaluate the discussion in order to assess the >>>>>> conformance of >>>>> this >>>>>> draft policy with ARIN's Principles of Internet Number Resource >>>>>> Policy as stated in the PDP. Specifically, these principles are: >>>>>> >>>>>> * Enabling Fair and Impartial Number Resource Administration >>>>>> * Technically Sound >>>>>> * Supported by the Community >>>>>> >>>>>> The ARIN Policy Development Process (PDP) can be found at: >>>>>> https://www.arin.net/policy/pdp.html >>>>>> >>>>>> Draft Policies and Proposals under discussion can be found at: >>>>>> https://www.arin.net/policy/proposals/index.html >>>>>> >>>>>> Regards, >>>>>> >>>>>> Communications and Member Services >>>>>> American Registry for Internet Numbers (ARIN) >>>>>> >>>>>> >>>>>> ## * ## >>>>>> >>>>>> >>>>>> Draft Policy ARIN-2015-8 >>>>>> Reassignment records for IPv4 End-Users >>>>>> >>>>>> Date: 25 August 2015 >>>>>> >>>>>> Problem statement: >>>>>> >>>>>> End-User Organizations do not have the ability to create >>>>>> reassignment records in the number resource database. >>>>>> >>>>>> Reassignment records can be used for a number of different >>>>>> functions which could benefit the overall desire to increase >>>>>> database accuracy by allowing organizations to add additional details > in >> the database. >>>>>> The following reasons have been noted as positive reasons to allow >>>>>> the creation of additional records. >>>>>> - Geolocation (allows an organization to specify a different >>>>>> location >>>>> within the >>>>>> database which is used by organizations creating geo-location by IP >>>>> address >>>>>> databases) >>>>>> - Subsidiary reassignment (allows an organization to note that a >>>>>> portion >>>>> of >>>>>> their netblock is in use by a different subsidiary entity) >>>>>> - Assignment to contracted parties (some organizations have >>>>>> contracts with other organizations which are operating networks >>>>>> under agreements with the registrant, this allows the top-level >>>>>> organizations to accurately >>>>> specify the >>>>>> organization operating the network in the number resource database) >>>>>> - More specific contact information (some organizations operate >>>>>> large networks which don't necessarily have the same technical or >>>>>> abuse contact >>>>>> information) >>>>>> >>>>>> Policy statement: >>>>>> >>>>>> Create new section 4.3.x >>>>>> >>>>>> End-user organizations which have an active registration services >>>>> agreement >>>>>> shall be permitted to create reassignment records in the number >>>>>> resource database. Organizations shall use the guidelines outlined >>>>>> in section 4.2.3 when creating reassignment records. >>>>>> >>>>>> Comments: >>>>>> a. Timetable for implementation: immediately b. Anything else: >>>>>> >>>>>> It is noted by the author of this policy proposal that one of the >>>>> distinctions in >>>>>> the service between ISPs and End-Users has been the ability for an >>>>>> organization to create reassignment records. >>>>>> >>>>>> This policy proposal stretches across responsibilities areas as it >>>>>> impacts number policy, ARIN operational practice, and fees. >>>>>> >>>>>> Below we have noted the three areas and the different >> responsibilities: >>>>>> A) Providing reassignment support for end-user assignments, for >>>>>> those who wish to use it >>>>>> >>>>>> This is an ARIN Service issue - could be an suggestion/consultation >>>>> process, >>>>>> so long as any implied additional workload/cost can be accommodated >>>>>> in budget and the community supports >>>>>> >>>>>> B) New requirement on end-users to provide reassignment >> information >>>>>> in certain circumstances so that ARIN will treat their usage >>>>>> assertion >>>>> credibly >>>>>> This is a policy issue. These requirements should be vetted through >>>>>> the >>>>> policy >>>>>> development process. >>>>>> >>>>>> C) Fee Implications of ISPs moving to end-user category >>>>>> >>>>>> This is Board issue, but first requires a community discussion or >>>>> consultation >>>>>> to be held to solicit community input on desired outcome. >>>>>> _______________________________________________ >>>>>> 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: >>>>>> http://lists.arin.net/mailman/listinfo/arin-ppml >>>>>> Please contact [email protected] if you experience any issues. >>>>> _______________________________________________ >>>>> 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: >>>>> http://lists.arin.net/mailman/listinfo/arin-ppml >>>>> Please contact [email protected] if you experience any issues. >>>> _______________________________________________ >>>> 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: >>>> http://lists.arin.net/mailman/listinfo/arin-ppml >>>> Please contact [email protected] if you experience any issues. >> _______________________________________________ >> 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: >> http://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact [email protected] if you experience any issues. _______________________________________________ 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: http://lists.arin.net/mailman/listinfo/arin-ppml Please contact [email protected] if you experience any issues.
