I think the main goal (at least from my perspective) is to avoid making the 
policy more restrictive through unintended consequences of new definitions. I 
think clarity is a close second to that.

Owen


> On Sep 16, 2025, at 15:27, Mohibul Mahmud <[email protected]> wrote:
> 
> Hello Team,
> 
> It seems most of us agree that clarity is the main goal. Would it make sense 
> to keep one preferred term in the NRPM, but also add a short note in the 
> definitions section that explains how ISP and LIR are used interchangeably in 
> ARIN policy?  
> 
> Best
> Mohibul Mahmud
> Microsoft
> ARIN Advisory Council Candidate
> 
> 
> 
> On Tue, Sep 16, 2025 at 3:54 PM Owen DeLong via ARIN-PPML <[email protected] 
> <mailto:[email protected]>> wrote:
>> Precisely what David said. I prefer LIR since I think ISP is over-specific 
>> in its vernacular usage and LIR is the more accurate term for what ARIN is 
>> actually doing. However, I can live with either if the NRPM definition of 
>> whichever term is used matches the general meaning of LIR. 
>> 
>> The policy as written would disqualify several, if not many legitimate users 
>> of IP addresses. 
>> 
>> Owen
>> 
>> 
>>> On Sep 16, 2025, at 11:58, David Farmer <[email protected] 
>>> <mailto:[email protected]>> wrote:
>>> 
>>> 
>>> Leif.
>>> 
>>> If the ARIN community wants to use the term "ISP" instead of "LIR", I can 
>>> accept that. However, the definition for "ISP" provided in the draft policy 
>>> focuses on the types of services the ISP provides, which are mostly 
>>> irrelevant from an ARIN Policy perspective. The current definition of LIR 
>>> focuses on the relationship between users/customers and the LIR/ISP. I 
>>> would call your attention to the definition John Seeeting provided or the 
>>> definition of LIR in RFC 7020. They focus on what is important from an ARIN 
>>> Policy perspective: the relationship between the LIR/ISP and its 
>>> users/customers, and the relationship with the RIR. If the definition 
>>> provided focuses on the important aspects of ARIN policy, the term used 
>>> will be unimportant; LIR and ISP can be used interchangeably. But that is 
>>> not the case for the provided definition of ISP in the draft policy.
>>> 
>>> Thanks.
>>> 
>>> On Tue, Sep 16, 2025 at 1:11 PM Leif Sawyer via ARIN-PPML 
>>> <[email protected] <mailto:[email protected]>> wrote:
>>>> Owen –
>>>> 
>>>>  
>>>> 
>>>>    This latest update is a result of the April ARIN meeting, where the 
>>>> overwhelming message was to “remove LIR” and use ISP, since that’s what
>>>> 
>>>> Is used both internally by ARIN, and predominantly within this region.
>>>> 
>>>>  
>>>> 
>>>> Note that the changes proposed are for section 6, to normalize it against 
>>>> the remainder of the NRPM’s use of ISP.
>>>> 
>>>>  
>>>> 
>>>> -L
>>>> 
>>>>  
>>>> 
>>>> Leif Sawyer
>>>> 
>>>> GCI | he/him | Engineer, CNI – Standards and Planning
>>>> 
>>>> t: 907-351-1535 | w: www.gci.com <https://www.gci.com/> | KL5BN
>>>> 
>>>>  
>>>> 
>>>> From: ARIN-PPML <[email protected] 
>>>> <mailto:[email protected]>> On Behalf Of Owen DeLong via ARIN-PPML
>>>> Sent: Saturday, September 13, 2025 7:39 AM
>>>> To: ARIN <[email protected] <mailto:[email protected]>>
>>>> Cc: [email protected] <mailto:[email protected]>
>>>> Subject: Re: [arin-ppml] Revised - Draft Policy ARIN-2025-1: Clarify ISP 
>>>> and LIR Definitions and References to Address Ambiguity in NRPM Text
>>>> 
>>>>  
>>>> 
>>>> [EXTERNAL EMAIL - CAUTION: Do not open unexpected attachments or links.] 
>>>> 
>>>> I think this is the wrong approach. 
>>>> 
>>>> In reality, ARIN cares about LIRs and deals with LIRs and end users. It is 
>>>> generally irrelevant from a policy perspective whether a given LIR is an 
>>>> ISP or not. 
>>>> 
>>>> Therefore, IMHO, a better approach would be to simply consolidate to the 
>>>> LIR term and eliminate ISP from the NRPM. 
>>>> 
>>>> IPv6 policy already explicitly declares that the terms are interchangeable 
>>>> from a policy perspective. 
>>>> 
>>>> Owen
>>>> 
>>>> 
>>>> > On Sep 12, 2025, at 10:18, ARIN <[email protected] <mailto:[email protected]>> 
>>>> > wrote:
>>>> > 
>>>> > The following Draft Policy has been revised:
>>>> > 
>>>> > *ARIN-2025-1: Clarify ISP and LIR Definitions and References to Address 
>>>> > Ambiguity in NRPM Text
>>>> > 
>>>> > Revised text is below and can be found at:
>>>> > 
>>>> > https://www.arin.net/participate/policy/drafts/2025_1/ 
>>>> > <https://www.arin.net/participate/policy/drafts/2025_1>
>>>> > 
>>>> > A PDF document showing the proposed NRPM edits is available to download 
>>>> > at:
>>>> > 
>>>> > https://arin.net/participate/policy/drafts/pdf/ARIN_2025_1_diff_091225.pdf
>>>> > 
>>>> > You are encouraged to discuss all Draft Policies on PPML. The AC will 
>>>> > evaluate the discussion to assess the conformance of this Draft Policy 
>>>> > with ARIN's Principles of Internet number resource policy as stated in 
>>>> > the Policy Development Process (PDP). Specifically, these principles are:
>>>> > 
>>>> > * Enabling Fair and Impartial Number Resource Administration
>>>> > * Technically Sound
>>>> > * Supported by the Community
>>>> > 
>>>> > The PDP can be found at:
>>>> > 
>>>> > https://www.arin.net/participate/policy/pdp/ 
>>>> > <https://www.arin.net/participate/policy/pdp>
>>>> > 
>>>> > Draft Policies and Proposals under discussion can be found at:
>>>> > 
>>>> > https://www.arin.net/participate/policy/drafts/ 
>>>> > <https://www.arin.net/participate/policy/drafts>
>>>> > 
>>>> > Regards,
>>>> > 
>>>> > Eddie Diego
>>>> > Policy Analyst
>>>> > American Registry for Internet Numbers (ARIN)
>>>> > 
>>>> > 
>>>> > 
>>>> > Draft Policy ARIN-2025-1: Clarify ISP and LIR Definitions and References 
>>>> > to Address Ambiguity in NRPM Text
>>>> > 
>>>> > Problem Statement:
>>>> > 
>>>> > Section 2.4 of the NRPM defines an LIR but does not explicitly define an 
>>>> > ISP. An ISP is defined in the context of an LIR, but the explicit 
>>>> > definition is otherwise assumed.
>>>> > 
>>>> > Through implication and in common business practice, all ISPs are LIRs, 
>>>> > but not all LIRs are ISPs.
>>>> > 
>>>> > This proposal adds clarity by creating an explicit definition for ISP, 
>>>> > clarifying the historical and out-of-region usage for the term LIR, and 
>>>> > replaces LIR with ISP throughout the NRPM as appropriate.
>>>> > 
>>>> > Policy Statement:
>>>> > 
>>>> > Add Internet Service Provider definition:
>>>> > 
>>>> > Remove the word “primarily” from the definition of LIR and add usage 
>>>> > clarification:
>>>> > 
>>>> > FROM:
>>>> > 
>>>> > 2.4. Local Internet Registry (LIR)
>>>> > 
>>>> > A Local Internet Registry (LIR) is primarily an IR that 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.
>>>> > 
>>>> > TO:
>>>> > 
>>>> > 2.4. Local Internet Registry (LIR) 
>>>> > 
>>>> > A Local Internet Registry (LIR) is an IR that 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. _While LIR has been historically 
>>>> > referenced in policies for ease of comparing other region's policies, 
>>>> > LIR is not used in the ARIN service region; ISP is the equivalent term._
>>>> > 
>>>> > 
>>>> > Add definition for ISP:
>>>> > 
>>>> > 2.18 Internet Service Provider (ISP)
>>>> > 
>>>> > An Internet Service Provider (ISP) is a type of organization that 
>>>> > provides Internet services to other organizations, its customers, and\or 
>>>> > individuals other than its employees. Internet services include, but are 
>>>> > not limited to, connectivity services, web services, colocation, 
>>>> > dedicated servers, virtual private servers, and virtual private networks.
>>>> > 
>>>> > 
>>>> > Replace Section 6.5.1a
>>>> > 
>>>> > Original Text: “The terms ISP and LIR are used interchangeably in this 
>>>> > document and any use of either term shall be construed to include both 
>>>> > meanings.”
>>>> > 
>>>> > New Text: “[Retired]”
>>>> > 
>>>> > 
>>>> > Remove all references in section 6.5 of LIR where appropriate:
>>>> > 
>>>> > [Editing note: For the purposes of clarity in plaintext communication 
>>>> > mediums, any changes to the text is denoted with the underscore 
>>>> > character before and after the insertion. The underscore character is 
>>>> > not considered a part of the final text.]
>>>> > 
>>>> > 
>>>> > Amend Section 6.5.2 to replace LIR with ISP, 12 in total
>>>> > 
>>>> > 6.5.2. Initial Allocation to _ISPs_
>>>> > 
>>>> > 6.5.2.1 <http://6.5.2.1/>. Size
>>>> > 
>>>> > 1. All allocations shall be made on nibble boundaries.
>>>> > 
>>>> > 2. In no case shall an _ISP_ receive smaller than a /32 unless they 
>>>> > specifically request a /36 or /40. In order to be eligible for a /40, an 
>>>> > ISP must meet the following requirements:
>>>> > 
>>>> > - Hold IPv4 direct allocations totaling a /24 or less (to include zero)
>>>> > 
>>>> > - Hold IPv4 reassignments/reallocations totaling a /22 or less (to 
>>>> > include zero)
>>>> > 
>>>> > In no case shall an ISP receive more than a /16 initial allocation.
>>>> > 
>>>> > 3. The maximum allowable allocation shall be the smallest 
>>>> > nibble-boundary aligned block that can provide an equally sized 
>>>> > nibble-boundary aligned block to each of the requesters serving sites 
>>>> > large enough to satisfy the needs of the requesters largest single 
>>>> > serving site using no more than 75% of the available addresses.
>>>> > This calculation can be summarized as /N where N = P-(X+Y) and P is the 
>>>> > organization’s Provider Allocation Unit X is a multiple of 4 greater 
>>>> > than 4/3*serving sites and Y is a multiple of 4 greater than 4/3*end 
>>>> > sites served by largest serving site.
>>>> > 
>>>> > 4. For purposes of the calculation in (c), an end site which can justify 
>>>> > more than a /48 under the end-user assignment criteria in 6.5.8 shall 
>>>> > count as the appropriate number of /48s that would be assigned under 
>>>> > that policy.
>>>> > 
>>>> > 5. For purposes of the calculation in (c), an _ISP_ which has 
>>>> > subordinate _ISPs_ shall make such reallocations according to the same 
>>>> > policies and criteria as ARIN. In such a case, the prefixes necessary 
>>>> > for such a reallocation should be treated as fully utilized in 
>>>> > determining the block sizing for the parent _ISP_. _ISPs_ which do not 
>>>> > receive resources directly from ARIN will not be able to make such 
>>>> > reallocations to subordinate _ISPs_ and subordinate _ISPs_ which need 
>>>> > more than a /32 shall apply directly to ARIN.
>>>> > 
>>>> > 6. An _ISP_ is not required to design or deploy their network according 
>>>> > to this structure. It is strictly a mechanism to determine the largest 
>>>> > IP address block to which the _ISP_ is entitled.
>>>> > 
>>>> > 7 An _ISP_ that requests a smaller /36 or /40 allocation is entitled to 
>>>> > expand the allocation to any nibble aligned size up to /32 at any time 
>>>> > without renumbering or additional justification. /40 allocations shall 
>>>> > be automatically upgraded to /36 if at any time said _ISP_’s IPv4 direct 
>>>> > allocations exceed a /24. Expansions up to and including a /32 are not 
>>>> > considered subsequent allocations, however any expansions beyond /32 are 
>>>> > considered subsequent allocations and must conform to section 6.5.3. 
>>>> > 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 address holdings.
>>>> > 
>>>> > 
>>>> > Amend Section 6.5.3 to replace LIR with ISP in 4 locations:
>>>> > 
>>>> > 6.5.3. Subsequent Allocations to _ISPs_
>>>> > 
>>>> > 1. Where possible ARIN will make subsequent allocations by expanding the 
>>>> > existing allocation.
>>>> > 
>>>> > 2. An _ISP_ qualifies for a subsequent allocation if they meet any of 
>>>> > the following criteria:
>>>> > 
>>>> > - Shows utilization of 75% or more of their total address space
>>>> > 
>>>> > - Shows utilization of more than 90% of any serving site
>>>> > 
>>>> > - Has allocated more than 90% of their total address space to serving 
>>>> > sites, with the block size allocated to each serving site being 
>>>> > justified based on the criteria specified in section 6.5.2
>>>> > 
>>>> > 3. If ARIN can not expand one or more existing allocations, ARIN shall 
>>>> > make a new allocation based on the initial allocation criteria above. 
>>>> > The _ISP_ is encouraged, but not required to renumber into the new 
>>>> > allocation over time and return any allocations no longer in use.
>>>> > 
>>>> > 4. If an _ISP_ has already reached a /12 or more, ARIN will allocate a 
>>>> > single additional /12 rather than continue expanding nibble boundaries.
>>>> > 
>>>> > 
>>>> > Amend Section 6.5.4.1 <http://6.5.4.1/> to replace LIR with ISP in 1 
>>>> > location:
>>>> > 
>>>> > 6.5.4.1 <http://6.5.4.1/>. Reassignment to Operator’s Infrastructure
>>>> > 
>>>> > An _ISP_ may reassign up to a /48 per PoP as well as up to an additional 
>>>> > /48 globally for its own infrastructure.
>>>> > 
>>>> > 
>>>> > Amend Section 6.5.7 to replace LIR with ISP in 1 location:
>>>> > 
>>>> > 6.5.7. Existing IPv6 Address Space Holders
>>>> > 
>>>> > _ISPs_ which received an allocation under previous policies which is 
>>>> > smaller than what they are entitled to under this policy may receive a 
>>>> > new initial allocation under this policy. If possible, ARIN will expand 
>>>> > their existing allocation.
>>>> > 
>>>> > 
>>>> > Amend Section 6.5.8 to remove “or other LIR” in 2 locations
>>>> > 
>>>> > 6.5.8.1 <http://6.5.8.1/>. Initial Assignment Criteria
>>>> > 
>>>> > FROM:
>>>> > 
>>>> > f. By providing a reasonable technical justification indicating why IPv6 
>>>> > addresses from an ISP or other LIR are unsuitable.
>>>> > 
>>>> > TO:
>>>> > 
>>>> > f. By providing a reasonable technical justification indicating why IPv6
>>>> > addresses from an ISP are unsuitable.
>>>> > 
>>>> > 
>>>> > FROM: 
>>>> > 
>>>> > Examples of justifications for why addresses from an ISP or other LIR 
>>>> > may be unsuitable include, but are not limited to:
>>>> > 
>>>> > TO:
>>>> > 
>>>> > Examples of justifications for why addresses from an ISP may be 
>>>> > unsuitable include, but are not limited to:
>>>> > 
>>>> > Timetable for Implementation: Immediate
>>>> > 
>>>> > 
>>>> > 
>>>> > 
>>>> > _______________________________________________
>>>> > ARIN-PPML
>>>> > You are receiving this message because you are subscribed to
>>>> > the ARIN Public Policy Mailing List ([email protected] 
>>>> > <mailto:[email protected]>).
>>>> > Unsubscribe or manage your mailing list subscription at:
>>>> > https://lists.arin.net/mailman/listinfo/arin-ppml
>>>> > Please contact [email protected] <mailto:[email protected]> if you experience 
>>>> > any issues.
>>>> 
>>>> _______________________________________________
>>>> ARIN-PPML
>>>> You are receiving this message because you are subscribed to
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>>>> issues.
>>>> 
>>>> _______________________________________________
>>>> ARIN-PPML
>>>> You are receiving this message because you are subscribed to
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>>>> issues.
>>> 
>>> 
>>> 
>>> --
>>> ===============================================
>>> David Farmer               Email:[email protected] 
>>> <mailto:email%[email protected]>
>>> Networking & Telecommunication Services
>>> Office of Information Technology
>>> University of Minnesota   
>>> 2218 University Ave SE        Phone: 612-626-0815
>>> Minneapolis, MN 55414-3029   Cell: 612-812-9952
>>> ===============================================
>> _______________________________________________
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