LACNIC Staff's Interpretation of the Proposal
Author: Jordi Palet Martínez
Applicability:
This proposal introduces changes to the Policy Manual.
Modifications to the current text:
This proposal would modify the following sections of the Policy Manual:
- 1.7. End Site or End User (EU)
- 4.4.2.4. LIR-to-ISP Allocation.
- 4.4.4.1. Direct assignment of portable IPv6 addresses to End Users having portable IPv4 addresses previously assigned by LACNIC.
- 4.4.4.2. Direct assignment of portable IPv6 addresses to End Users not having portable IPv4 addresses previously assigned by LACNIC.
and would add a new section, 1.8. End-User (EU).
Proposed Text:
1.7 End-Site (ES)
An End-Site is defined as the location of an End-User who has a relationship with a service provider that involves:
• that service provider assigning address space to the End-User location,
• that service provider providing transit service for the End-User location to other sites,
• that service provider carrying the End-User's location traffic,
• that service provider advertising an aggregate prefix route that contains the End-User's location assignment.
(Renumber the following sections)
1.8 End-User (EU)
An End-User is a subscriber or customer of an LIR. Similarly, an End-User is one who receives direct assignments from LACNIC.
(Eliminated)
4.4.4.1 Direct assignment of portable IPv6 addresses to End-Users having portable IPv4 addresses previously assigned by LACNIC
…
Assignments will always be made in blocks greater than or equal to a /48.
…
4.4.4.2 Direct assignment of portable IPv6 addresses to End-Users not having portable IPv4 addresses previously assigned by LACNIC
…
Assignments will always be made in blocks greater than or equal to a /48.
…
LACNIC Staff Comments:
1) In our opinion, it is not appropriate to eliminate the need for a business (commercial) or legal relationship.
2) In our opinion, it is not appropriate to eliminate the term "Internet" before “service providers", as this would make it possible for any intermediary (regardless of whether they have a role in the Internet service) to sub-assign to third parties (governments, brokers, or any other business in general).
3) We reiterate that, by allowing the consolidation and management of the resources of multiple different legal entities, this proposal implicitly favors the creation of new NIRs without the proper and explicit discussion by the community.
4) In addition, the definition of End-User introduced in the proposal is not clear.
5) When the first version of this proposal was presented, we called for the community to comment on this to determine whether it was a broader issue. Now, even though this second version has been submitted, we have still not received any comments.
6) After this version, we will not comment on this proposal or on any potential new versions until it is discussed by the community.
Recommendations:
1) Do not include terminology that is not used in this community (“LIR” and “client”).
2) We request that the author pay special attention to comment No. 5.
Impact of the policy on the registry and/or other systems:
It is impossible to identify any impacts based on the proposal's current level of detail.
This proposal seeks to implement the improvement suggested by the community and listed under the title “Clarify the wording used regarding the terms ISP and End-User.” It also takes advantage of this opportunity to confirm that certain end users may have multiple locations, each of them requiring their own prefixes. This is especially noticeable in the case of direct (portable) IPv6 assignments by LACNIC.
The proposal eliminates the section on LIR-to-ISP IPv6 allocations, the first reason being that the section's wording is contradictory (it specifies that there is no specific policy for this), the second being that this is not recommended in the case of IPv6 (although it was recommended for IPv4 using NAT). Furthermore, Section 4.5.6 specifies that IPv6 address block assignments must be registered.
Rationale (Describe the problem you intend to solve)Right now, the definitions of “end-user” and “end-site” are not clearly differentiated, possibly because they were introduced with an IPv4 mind-set. The reality, however, is that they are different concepts —a fact that is increasingly evident in IPv6— and that even the same end user may have several end sites that require prefixes which will not necessarily be announced as aggregate space (even though this would be the ideal scenario), and that this circumstance may even vary depending on those sites’ provider(s).
An organization —for example, a bank— may have an MPLS network which aggregates the /48s assigned to each office. However, in some cases —such as offices that are outside the area covered by the MPLS network— they are different providers or means of access which may require separate /48s, yet these cannot even be aggregated to the global prefix assigned by LACNIC.
Therefore, the policy should clearly differentiate between end users and end sites.
Current text1.7 End Site or End User (EU)
An end site is defined as an end user (subscriber) that has a legal or commercial relationship (the same or associated entities) with an Internet service provider which involves:
• the service provider assigning address space to the end user
• the service provider offering transit services for the end user towards other sites
• the service provider transporting the end user’s traffic
• the service provider announcing an aggregated route prefix which contains the address space assigned by LACNIC to the end user
4.5.2.4 LIR-to-ISP Allocation
There is no specific policy for an organization (LIR) to allocate address space to subordinate ISPs. Each LIR organization may develop its own policy for subordinate ISPs to encourage optimum utilization of the total address block allocated to the LIR. However, all /48 assignments to End User sites are required to be registered either by the LIR or its subordinate ISPs in such a way that the RIR/NIR can properly evaluate the HD-Ratio when a subsequent allocation becomes necessary.
4.5.4.1 Direct assignment of portable IPv6 addresses to End Sites having portable IPv4 addresses previously assigned by LACNIC
…
Assignments will be made in blocks always greater than or equal to a /48.
…
4.5.4.2 Direct assignment of portable IPv6 addresses to End sites not having portable IPv4 addresses previously assigned by LACNIC
…
Assignments will be made in blocks always greater than or equal to a /48.
…
1.7 End-Site
An End-Site is defined as the location of an End-User who has a business or legal relationship (same or associated entities) with a service provider that involves:
• that service provider assigning address space to the End-User location,
• that service provider providing transit service for the End-User location to other sites,
• that service provider carrying the End-User's location traffic,
• that service provider advertising an aggregate prefix route that contains the End-User's location assignment.
(Renumber the following sections)
1.8 End User
LIR subscriber or customer.
(Eliminated)
4.5.4.1 Direct assignment of portable IPv6 addresses to End Users having portable IPv4 addresses previously assigned by LACNIC
…
The minimum size of the assignment is a /48 per End-Site.
…
4.5.4.1 Direct assignment of portable IPv6 addresses to End sites not having portable IPv4 addresses previously assigned by LACNIC
…
The minimum size of the assignment is a /48 per End-Site.
…
Several RIRs have already modified these aspects or are in the process of doing so through similar policy proposals.
Timetable-
References-
Presented at:LACNIC 36 (11/10/2021)
This proposal seeks to implement the improvement suggested by the community and listed under the title “Clarify the wording used regarding the terms ISP and End-User.” It also takes advantage of the opportunity to confirm that certain end-users may have multiple locations, each of them requiring their own prefixes. This is especially noticeable in the case of direct (portable) IPv6 assignments by LACNIC.
The proposal eliminates the section on LIR-to-ISP IPv6 allocations, first, because the section's wording is contradictory (it specifies that there is no specific policy for this); second, because in the case of IPv6 this is not recommended from an operational point of view (although it was recommended for IPv4 with NAT). Furthermore, Section 4.4.6 specifies that IPv6 address block assignments must be registered.
Rationale (Describe the problem you intend to solve)Right now, the definitions of end “end-user” and “end-site” are not clearly differentiated, possibly because they are based on concepts that apply to IPv4. The reality, however, is that they are different concepts —a fact that is increasingly evident in IPv6— and that even the same end-user may have several end-sites that require prefixes which will not necessarily be announced as aggregate space (even though this would be the ideal scenario), and that this circumstance may even vary depending on the provider(s) of those sites.
An organization, for example a bank, may have an MPLS network that aggregates the /48s assigned to each office. However, in some cases, for example, offices that are outside the area covered by the MPLS network, they are different providers or means of access which may require separate /48s, yet these cannot even be aggregated to the global prefix assigned by LACNIC.
Therefore, the policy should clearly differentiate between end-users and end-sites.
Current text1.7 End Site or End User (EU)
An end site is defined as an end user (subscriber) that has a legal or commercial relationship (the same or associated entities) with an Internet service provider which involves:
• the service provider assigning address space to the end user
• the service provider offering transit services for the end user towards other sites
• the service provider transporting the end user’s traffic
• the service provider announcing an aggregated route prefix which contains the address space assigned by LACNIC to the end user
4.4.2.4 LIR-to-ISP Allocation:
There is no specific policy for an organization (LIR) to allocate address space to subordinate ISPs. Each LIR organization may develop its own policy for subordinate ISPs to encourage optimum utilization of the total address block allocated to the LIR. However, all /48 assignments to End User sites are required to be registered either by the LIR or by its subordinate ISPs in such a way that the RIR/NIR can properly evaluate the HD-Ratio when a subsequent allocation becomes necessary.
4.4.4.1 Direct assignment of portable IPv6 addresses to End Users having portable IPv4 addresses previously assigned by LACNIC
…
Assignments will always be made in blocks greater than or equal to a /48.
…
4.4.4.2 Direct assignment of portable IPv6 addresses to End Users not having portable IPv4 addresses previously assigned by LACNIC
…
Assignments will always be made in blocks greater than or equal to a /48.
…
1.7 End-Site (ES)
An End-Site is defined as the location of an End-User who has a relationship with a service provider that involves:
• that service provider assigning address space to the End-User location,
• that service provider providing transit service for the End-User location to other sites,
• that service provider carrying the End-User's location traffic,
• that service provider advertising an aggregate prefix route that contains the End-User's location assignment.
(Renumber the following sections)
1.8 End-User (EU)
An End-User is a subscriber or customer of an LIR. Similarly, an End-User is one who receives direct assignments from LACNIC.
(Eliminated)
4.4.4.1 Direct assignment of portable IPv6 addresses to End-Users having portable IPv4 addresses previously assigned by LACNIC
…
Assignments will always be made in blocks greater than or equal to a /48 per End-Site.
…
4.4.4.2 Direct assignment of portable IPv6 addresses to End-Users not having portable IPv4 addresses previously assigned by LACNIC
…
Assignments will always be made in blocks greater than or equal to a /48 per End-Site.
…
These aspects have already been modified or are in the process of being modified through similar proposals in several RIRs.
Timetable-
References-
Presented at:LACNIC 38 (04/10/2022)