Thanks for this clarification, David!

On Mon, 12 Oct 2020, David Farmer wrote:

You don't have to be an ISP to have an ASN, thousands of end-users have ASNs
assigned to them by ARIN, in ARIN policy the difference between an ISP (AKA
an LIR) and an end-user is the ability to reassign address space to other
entities.  Since an end-user doesn't assign address space to other entities
a /44 or even a /48 assignment directly from ARIN makes sense, such a small
allocation to an ISP makes no sense since they couldn't reassign /48s to a
sufficiently large number of customers. The point of this policy is to allow
extremely small ISPs to receive a /40, providing 256 /48s for reassignment,
which is a viable IPv6 allocation for the very smallest ISPs.

I hope that clarifies things for you.

Thanks.

On Mon, Oct 12, 2020 at 4:30 PM <[email protected]> wrote:
      Andrew,

      On Mon, 12 Oct 2020, Andrew Dul wrote:

      > On 10/12/2020 1:29 PM, [email protected] wrote:
      >> Hi Andrew,
      >>
      >> On Mon, 12 Oct 2020, Andrew Dul wrote:
      >>
      >>> The partial returns language is also intended to promote
      best practices
      >>> for IPv6 addressing, that is giving big blocks to allow ISPs
      to assign
      >>> /48s to all customers.
      >>
      >> True, but not all resource holders are operating ISP's for
      public use.
      >> For example, my local City Government has an ASN, and v4
      address
      >> block. They provide no internet services, neither network, to
      eyes,
      >> nor content other than for their own use.  This is the case
      with many
      >> resource holders not in the primary business of being an ISP.
      >>
      >> Scott
      >>
      > The organization you describe here sounds more like an
      end-user, but I
      > do understand various organizations have switched from being
      an end-user
      > to ISP and vise-versa over the years for various reasons. 

      Unfortunately, the only way to have redundancy in your upstream
      while
      keeping connectivity to your network address is to be an ISP by
      this
      definition, even if you offer no network services to other
      organizations.
      This is because an AS is required to perform BGP, which is
      critical to
      maintaining connectivity to a multi-homed network through outage
      of one
      or more connected circuits.

      >
      > An end-user organization who would be eligible to obtain an
      /48 under
      > 6.5.8 of the NRPM.  
      >
      
>https://www.arin.net/participate/policy/nrpm/#6-5-8-direct-assignments-from
      -arin-to-end-user-organizations
      >
      > This draft policy ARIN-2020-3 is specifically related to ISPs.

      I believe you are making a misclassification here.  Once these
      organizations have AS and/or address resources, they are
      considered an ISP
      for these purposes, despite their end use case.

      Scott

      >
      >
      >>>
      >>> Andrew
      >>>
      >>> On 10/12/2020 12:26 PM, [email protected] wrote:
      >>>> Hi Chris,
      >>>>
      >>>> I wonder what percentage of 2x-small Resource holders have
      a /24 of
      >>>> v4, and would otherwise qualify for 3x-small status but for
      their v6
      >>>> allocations, and what percentage of all ASs registered with
      ARIN that
      >>>> represents.  This represents the the total who could
      "downgrade" to a
      >>>> nano-allocation, were that a option.  It would be easy to
      derive from
      >>>> that the maximum effect on ARIN's finances, if they all
      chose to take
      >>>> that option.
      >>>>
      >>>> Scott
      >>>>
      >>>> On Mon, 12 Oct 2020, Chris Woodfield wrote:
      >>>>
      >>>>> Agreed. To be clear, I did not intend for my question to
      imply that
      >>>>> the goal of keeping the proposal revenue-neutral was in
      any way
      >>>>> dishonorable - ARIN’s financial stability is obviously in
      the
      >>>>> community’s best interests. But we should have informed
      consent as to
      >>>>> how that stability is achieved, and as such, clarifying
      the intention
      >>>>> of the clause is helpful.
      >>>>
      >>>>
      >>>>
      >>>>>
      >>>>> Thanks,
      >>>>>
      >>>>> -C
      >>>>>
      >>>>>> On Oct 12, 2020, at 11:06 AM, [email protected]
      wrote:
      >>>>>>
      >>>>>> Hi Chris,
      >>>>>>
      >>>>>> Indeed.  To be fair, I think the price is fair for value
      received,
      >>>>>> speaking as a 2x-small ISP with a /36.  I was able to
      lower my
      >>>>>> recurring costs and increase my available address pool by
      bringing
      >>>>>> up an AS at the 2x-small rate.  Allowing the smallest
      ISPs to
      >>>>>> implement IPv6 without additional financial cost seems a
      prudent way
      >>>>>> to overcome barriers to adoption.
      >>>>>>
      >>>>>> Scott
      >>>>>>
      >>>>>> On Sun, 11 Oct 2020, Chris Woodfield wrote:
      >>>>>>
      >>>>>>> Thanks Andrew, and good catch - both Scott and I missed
      that
      >>>>>>> clause, obviously. It appears that this is in place in
      order to
      >>>>>>> meet the stated goal of this proposal being
      revenue-neutral for
      >>>>>>> ARIN? If so, it would be great to clarify so that
      community members
      >>>>>>> can make a more informed evaluation as to whether or not
      to support
      >>>>>>> the clause. If there are other justifications for the
      clause’s
      >>>>>>> presence, I’d be interested to hear them.
      >>>>>> 2~>
      >>>>>>> Thanks,
      >>>>>>>
      >>>>>>> -C
      >>>>>>>
      >>>>>>>> On Oct 11, 2020, at 10:24 AM, Andrew Dul
      <[email protected]>
      >>>>>>>> wrote:
      >>>>>>>>
      >>>>>>>> The current draft policy text disallows returns to
      lower than a
      >>>>>>>> /36, so
      >>>>>>>> I would say that organization which took a /36 would
      not be
      >>>>>>>> permitted to
      >>>>>>>> go down to a /40.
      >>>>>>>>
      >>>>>>>> "Partial returns of any IPv6 allocation that results in
      less than
      >>>>>>>> a /36
      >>>>>>>> of holding are not permitted regardless of the ISP’s
      current or
      >>>>>>>> former
      >>>>>>>> IPv4 number resource holdings."
      >>>>>>>>
      >>>>>>>> Andrew
      >>>>>>>>
      >>>>>>>> On 10/9/2020 2:04 PM, Chris Woodfield wrote:
      >>>>>>>>> Hi Scott,
      >>>>>>>>>
      >>>>>>>>> Given that ARIN utilizes a sparse allocation strategy
      for IPv6
      >>>>>>>>> resources (in my organization’s case, we could go from
      a /32 to a
      >>>>>>>>> /25 without renumbering), IMO it would not be
      unreasonable for
      >>>>>>>>> the allocation to be adjusted down simply by changing
      the mask
      >>>>>>>>> and keeping the /36 or /32 unallocated until the
      sparse
      >>>>>>>>> allocations are exhausted. Any resources numbered
      outside the new
      >>>>>>>>> /40 would need to be renumbered, to be sure, but
      that’s most
      >>>>>>>>> likely less work than a complete renumbering.
      >>>>>>>>>
      >>>>>>>>> That said, I’ll leave it up to Registration Services
      to provide a
      >>>>>>>>> definitive answer.
      >>>>>>>>>
      >>>>>>>>> -C
      >>>>>>>>>
      >>>>>>>>>> On Fri, 9 Oct 2020, [email protected] wrote:
      >>>>>>>>>>
      >>>>>>>>>>> Hi All,
      >>>>>>>>>>>
      >>>>>>>>>>> I am in favor of this draft, and am curious as to
      how resource
      >>>>>>>>>>> holders who were not dissuaded by the fee increase
      will be
      >>>>>>>>>>> impacted by the policy change. While they indeed
      have more
      >>>>>>>>>>> address space than /40, they may also not need the
      additional
      >>>>>>>>>>> address space.  Some might prefer the
      nano-allocation given the
      >>>>>>>>>>> lower cost.  Will they be required to change
      allocations, and
      >>>>>>>>>>> renumber, in order to return to 3x-small status and
      associated
      >>>>>>>>>>> rate?
      >>>>>>>>>>>
      >>>>>>>>>>> Scott Johnson
      >>>>>>>>>>> SolarNetOne, Inc.
      >>>>>>>>>>> AS32639
      >>>>>>>>>>> _______________________________________________
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