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

[Owen DeLong]

> On Dec 13, 2023, at 12:25, John Curran <jcurran at arin.net> wrote:
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>>>> On Dec 13, 2023, at 1:40 PM, Owen DeLong <owen at delong.com> wrote:
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>>>> On Dec 13, 2023, at 09:09, John Curran <jcurran at 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.
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>> I believe I said “primarily concerned about”. Please don’t disregard important words.
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> Owen - 
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> If that’s the case, then my apologies, but our mail server seems to have your email recorded as such – 
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> >   "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). “

Fair enough. I think earlier in the message, I had said “primarily”, but yes, it’s definitely not in that particular paragraph. 

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

I refer you to 6.5.1.a

6.5.1. Terminology
The terms ISP and LIR are used interchangeably in this document and any use of either term shall be construed to include both meanings.
> 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?
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> 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.

I don’t conclude that, I read it in the text of the NRPM quoted above. 

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

It doesn’t in section 2 where it defines LIR, but it does in 6.5.1.a as shown above. 

> 
>>> ...
>>> 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.
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>> 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”. 
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> 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. 

My point was that ARIN doesn’t apply those greater constraints and said assumption is actually problematic in that it may dissuade or confuse legitimate applicants. 

Owen

> 
> Thanks (and Happy Holidays!) 
> /John
> 
> John Curran
> President and CEO
> American Registry for Internet Numbers
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