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

[owen@Delong.com]

> On Dec 13, 2023, at 14:52, John Curran <jcurran at arin.net> wrote:
> 
> 
> 
>> On Dec 13, 2023, at 5:09 PM, Owen DeLong <owen at delong.com> wrote:
>> 
>>> 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. 
>> 
>> I refer you to 6.5.1.a
> 
> I referred to the NRPM general definitions, rather than language of a specific policy section, ie Section 6 which defines IPv6 Policies for Allocations and Assignments”    The general applicability outside of that context is uncertain.

While I will agree it would probably have been better to put this in section 2, I would say that the words “used interchangeably in this document” seem fairly definitive as to applying to the document and not merely the section.

>>> 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. 
> 
> Certainly applicable policy language if you’re making an IPv6 request, otherwise indeterminate.

OK, riddle me this… Is there any definition of LIR that applies in section 6 who would be eligible under current policy for an IPv6 allocation that would be rendered ineligible for IPv4 under the section 4 usage of the term ISP instead?

> 
>>> 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. 
> 
> Indeed - alas NRPM has to apply to more than IPv6, so at a minimum that definition should move to the general definitions, if the community intends such to be more widely applicable.

Agreed that 6.5.1.a is poorly placed, but it does refer to “in this document” rather than “in this section”.

I can assure you that the author’s intent at the time was global.

>> 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. 
> 
> Incorrect - As I indicated earlier, ARIN does consider the term “ISP” and provision of network services in its traditional context; ie, it “ remains applicable to issuance of IPv4 address space under NRPM 4.2 (Allocations to ISPs) as limited by 4.1.8 (ARIN Waitlist).  “

Are you saying that ARIN would allocate IPv6 to an LIR that was not providing network services?

Unless that’s what you are saying, then I would argue that ARIN’s implementation of the term LIR and ARIN’s implementation of the term ISP are homogenous.

> If the community wishes it to be otherwise (e.g. taking your IPv6 term definition language into consideration), that change should be made explicitly, and not as an incidental consequence of language cleanup.

TBH, at the time I wrote 6.5.1.a, the intention was for the definition to more precisely represent the broad definition of ISP that ARIN uses (well beyond what many in industry consider ISP, e.g. including cloud providers, government agencies that issue addresses to subordinate departments, Colo facilities, etc.). At the time, the concept of address registration without network services by other than RIR had not occurred to me, TBH, and if you believe the IPv6 definition includes that, IMHO, that’s errata, not intentional.

I have yet to see an example where ARIN has issued IPv6 to an entity for distribution divorced from connectivity services, but you would have better visibility into that than I.

Owen

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