On Dec 13, 2023, at 1:40 PM, Owen DeLong <o...@delong.com> wrote:

On Dec 13, 2023, at 09:09, John Curran <jcur...@arin.net> wrote:
...
I note that that you make a strong presumption about "what ARIN is actually 
concerned about”, and while registration aspects may frequently be the main 
focus, it is not necessarily always the case that ARIN’s concerns are limited 
to "the local registration of addresses to other entities” – ARIN’s remit is 
set by the member-elected Board per the policies developed by this community, 
so “what ARIN is actually concerned about” may extend a bit beyond your 
asserted viewpoint – again, depending on the policies established by the this 
community.

I believe I said “primarily concerned about”. Please don’t disregard important 
words.

Owen -

If that’s the case, then my apologies, but our mail server seems to have your 
email recorded as such –

>   "Best to avoid the quagmire of ambiguity and talk in terms of what ARIN is 
> actually concerned about, which is the local registration of addresses to 
> other entities (whether internal, external, or both). “

So you’re saying that using the term LIR there would bring in unintended 
recipients? Given that we have already stated in the NRPM that the terms are 
interchangeable and have the same meaning for policies, this statement is 
confusing to me.

The portion of the NRPM that defines LIR is as follows –

A Local Internet Registry (LIR) is an IR that primarily 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.

As such, the question of interchangeability of the ”LIR” and “ISP” terms 
requires considering whether there is alignment in "the network services” that 
each provides.

Certainly in many cases an LIR is an ISP (and the NRPM LIR definition makes 
that plain in its second clause), but to draw an example:  would an 
organization that only provides address management services for its users be 
considered an ISP?

It is not appropriate to conclude that NRPM equates the terms, but rather that 
it only notes that "LIRS are generally ISPs.” –– i.e. the definition clearly 
envisions the possibility that some LIRs may not be ISPs; they may provide IP 
addresses to users, but that does not necessarily and automatically equate with 
"the provision of network services” such as the term Internet Service Providers 
encompasses.

That does not mean that “LIR” is not a suitable replacement for ISP in the 
NRPM, but rather that the community will need to be clear if there are any 
additional assumptions or constraints applicable to portions of the policy that 
may have traditionally been assumed due to usage of the term “ISP”.   
Extracting and making explicit such conditions makes for clearer policy, and as 
such, moving to “LIR” as the more general term may actually facilitate clearer 
ARIN number resource policy over the long term – so long as appropriate care is 
taken in the update.

I’m all for due diligence in the process,  it given that the NRPM already calls 
out the terms as equivalent for policy purposes, the idea that it would change 
the meaning of the current policy is confusing to me.

See above - alas, the NRPM does not presently call out the terms as equivalent 
but rather only notes that LIRs "are generally ISPs."

...
As noted, such a change may be more _or less_ descriptive to actual policy 
intent of particular sections of NRPM , but the community certainly has the 
ability to consider such cases and clarify as needed.

I believe that as implemented currently, the section you cite is used to issue 
addresses to a number of entity types that many would assume are not “ISPs”.

Thank you – you nicely make my point that there may be usage of the term ISP 
that people believe is more constrained that the term LIR – again, this doesn’t 
argue against moving to using LIR as the consistent term throughout NRPM, but 
simply notes that care should be taken to make sure the resulting NRPM policy 
is unambiguous within the community regarding its policy intent – particular 
when it comes to policy that is presently references and it utilized by ISPs.

Thanks (and Happy Holidays!)
/John

John Curran
President and CEO
American Registry for Internet Numbers








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