On Dec 14, 2023, at 4:34 PM, Owen DeLong <o...@delong.com> wrote:

Does this mean that ARIN will issue IPv6 to LIR requests with a stated intent 
to go into the IP resource management business separate from providing 
connectivity services?

Owen -

That may come down to any distinction between “connectivity” versus “network” 
services…   to the extent there is ambiguity in number resource policy, ARIN 
tries to work with the requesters to get their request for resources _approved_ 
to the extent that it can be done within the expressed language and intent of 
the number resource policy as written.

Per NRPM section 2.4, a "Local Internet Registry (LIR)" is an IR that primarily 
assigns IP addresses to the users of the “network services" that it provides.   
It’s also noted that "LIRs are generally Internet Service Providers (ISPs)", 
but that clearly leaves open that possibility that some LIRs are not ISPs.

I am fairly clear what constitutes an ISP and/or a provider of connectivity 
services, but what services constitute network services?

Does that include an IR that provides VPN/tunnel services?  Companies that 
provide network monitoring services?  CDN providers?  Networks providing DDoS 
Mitigation services?  Firms that provide IP address management services, 
including monitoring of one’s routing/IRR/RPKI/geolocation/rDNS status and 
leasing of IP address space?  SAAS operations that provide network 
configuration, monitoring, and IP address management?

Or perhaps “all of the above except for those IR’s that _only_ provide IP 
address management services” to their customers?

Once we step away from ISPs providing connectivity services, things because 
very fluid and rather quickly.

Note - the inherent flexibility of the term “IR” may not be problem what it 
comes to IPv6, but has obviously has some potential for interesting 
consequences for IPv4 administration.

Unless the answer to that question is yes, then I think the correct fix is to 
explicitly add the appropriate limitation to the definition of LIR, which is 
likely editorial since it wouldn’t change staff interpretation of the policy. 
If the answer to that question is yes, then we do, indeed, have an (at least to 
me) unexpected divergence between current IPv4 and IPv6 policy and I think the 
community needs to make a decision on whether we wish to continue to permit 
IPv6 to be handed out to “Address Management Services”.

Indeterminate - see above regarding companies providing “network services” 
(feel free provide any insight based on your understanding of policy intent.)

I care not whether this change ends up editorial or not, my focus is on 
identifying the correct changes to NRPM to get to the desired result (and, for 
that matter, if there is a discrepancy between the interpretation being applied 
to IPv6 policy and IPv4 policy, whether or not the community wishes to continue 
that difference or which direction to go).

In general, I personally favor prohibiting “Address Management Services” 
without connectivity.

Policy proposals are relatively easy to submit if you wish to make NRPM clearer 
in any manner.

Thanks (and Happy Holidays!)
/John

John Curran
President and CEO
American Registry for Internet Numbers






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