On Dec 13, 2023, at 5:52 PM, John Curran <[email protected]> wrote:

On Dec 13, 2023, at 5:09 PM, Owen DeLong <[email protected]> wrote:
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).  “

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.

To be quite explicit (with the goal of more expeditious improving overall 
understanding) – let me reference back to my previous point regarding "would an 
organization that _only_ provides address management services for its users be 
considered an ISP?”   There’s little doubt that they would be considered an 
“LIR”, but if they are not doing the registry services for the provision of any 
network services, then they are not considered an ISP and do not qualify for 
IPv4 address space under NRPM section 4.2 & 4.1.8 ARIN Waitlist policy.

If the goal is to change this to allow an LIR absent any form of network 
service provision to obtain IP number resources solely for provision of local 
registry services, then it would be best if such is done via a policy proposal 
with a very clear intent section.  Absent such a change, ARIN will continue to 
provide maximum flexibility to organizations that need IP addresses for 
purposes of provision of network services in wide variety of forms, but that it 
not the same thing as any “LIR” given that the LIR definition can encompass 
entities that might obtain addresses solely to provide address management 
services.

Thanks,
/John

John Curran
President and CEO
American Registry for Internet Numbers


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