[arin-ppml] Sections 6.5.1.a and 6.5.1.b - More section 6 Potential simplifications from the NRPM Working Group

[John Curran]

> On Dec 12, 2023, at 2:18 PM, owen--- via ARIN-PPML <arin-ppml at arin.net> wrote:
> 
> ISP is a very ambiguous term which carries a lot of different connotations to different people, most of which don’t describe the full range of ARIN member LIRs.
> 
> LIRs include cloud providers, CDNs, certain government entities, colocation facilities, “eyeball” providers, backbone providers, tunnel/vpn service providers, SDWAN providers, SAAS providers, etc.

Owen - 

It is indeed the case that “ISP” incorporates connections that traditionally have included the provision of Internet connectivity services to “customers” (often commercial, but not always.) 

> Sure, most of those could be called an ISP under some definition of the term, but would be excluded from the term in many other people’s minds.

Indeed. 

> 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).

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. 

There are certainly cases where the term ISP is used in its traditional context –  for example, NRPM "4.2.1. Principles / 4.2.1.1. Purpose” reads "ARIN allocates blocks of IP addresses to ISPs for the purpose of reassigning and reallocating that space to their customers”, and this section remains applicable to issuance of IPv4 address space under NRPM 4.2 (Allocations to ISPs) as limited by 4.1.8 (ARIN Waitlist).   To the extent that a more general term LIR gets used rather than “ISP”, it would represent a change to policy intent unless additional verbiage was added noting the intention of NRPM 4.2 to apply to particular type of LIR… 

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. 

> As such, yes, I have a strong belief that LIR is a term better suited to ARIN policy as it is both more descriptive of the bodies being described and more relatable to the policy intent.

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.

Thanks (and Happy Holidays!) 
/John

John Curran
President and CEO
American Registry for Internet Numbers