On Dec 14, 2023, at 7:49 PM, Owen DeLong <[email protected]> wrote:

On Dec 14, 2023, at 14:45, John Curran <[email protected]> wrote:
….
I am fairly clear what constitutes an ISP and/or a provider of connectivity 
services, but what services constitute network services?

Does that include an IR that provides VPN/tunnel services?  Companies that 
provide network monitoring services?  CDN providers?  Networks providing DDoS 
Mitigation services?  Firms that provide IP address management services, 
including monitoring of one’s routing/IRR/RPKI/geolocation/rDNS status and 
leasing of IP address space?  SAAS operations that provide network 
configuration, monitoring, and IP address management?

Or perhaps “all of the above except for those IR’s that _only_ provide IP 
address management services” to their customers?

Once we step away from ISPs providing connectivity services, things because 
very fluid and rather quickly.

Note - the inherent flexibility of the term “IR” may not be problem what it 
comes to IPv6, but has obviously has some potential for interesting 
consequences for IPv4 administration.

Right, so in terms of staff interpretation, what would be done with a request 
for IPv6 resources in each of those scenarios if it arrived today?

Owen – I believe that they would all be issued IPv6 resources if they requested 
such.

Note in particular the rather thin difference between "Firms that provide IP 
address management services, including monitoring of one’s 
routing/IRR/RPKI/geolocation/rDNS status and leasing of IP address space” when 
compared to “Firms that provide address block management only” –– this is a 
very fine distinction indeed for ARIN staff to attempt to assert absent clear 
policy language and intent.

Unless the answer to that question is yes, then I think the correct fix is to 
explicitly add the appropriate limitation to the definition of LIR, which is 
likely editorial since it wouldn’t change staff interpretation of the policy. 
If the answer to that question is yes, then we do, indeed, have an (at least to 
me) unexpected divergence between current IPv4 and IPv6 policy and I think the 
community needs to make a decision on whether we wish to continue to permit 
IPv6 to be handed out to “Address Management Services”.

Indeterminate - see above regarding companies providing “network services” 
(feel free provide any insight based on your understanding of policy intent.)

The policy intent was definitely to cover all of the above except address 
management only. (i.e. all infrastructure based forms of network services). (At 
least that was the author’s intent when I wrote the policy).

Understood and thanks for providing that answer – would it be correct to derive 
from your answer that you consider VPN, virtual hosting, and "SAAS operations 
that provide network configuration, monitoring, and IP address management” all 
to be “infrastructure-based forms of network services”?

I care not whether this change ends up editorial or not, my focus is on 
identifying the correct changes to NRPM to get to the desired result (and, for 
that matter, if there is a discrepancy between the interpretation being applied 
to IPv6 policy and IPv4 policy, whether or not the community wishes to continue 
that difference or which direction to go).

In general, I personally favor prohibiting “Address Management Services” 
without connectivity.

Policy proposals are relatively easy to submit if you wish to make NRPM clearer 
in any manner.

I’m sure you are well aware that I am quite familiar with the PDP and how to 
submit a proposal. ;-)

Nonetheless, I’d like to see clearer answers to the questions you keep 
side-stepping and further community comment on which way the community as a 
whole wants to go on the issue.

No intention of side-stepping, but providing answers to hypothetical requests 
requires a bit of care (and in cases of ambiguity of policy language it also 
necessitates review of the policy development.)

I don’t mind writing a policy proposal, it certainly won’t be my first, but I 
think it’s reasonable to first try to get a sense of what is likely to achieve 
support from the community and to get a firm stake in the ground as to where 
current policy actually stands.

The present policy language in NRPM doesn’t require that an LIR’s “network 
services” be for provision of connectivity, nor that they be “infrastructure 
based” – the staff implementation is faithful to the policy language, and if 
your intention was otherwise, then it is worth considering potential policy 
changes with respect to IPv6 policy language given the definition of the term 
LIR.

( and to the extent that community moves from the term “ISP” to “LIR” for IPv4 
policy language, a similar condition would be created. )

Thanks,
/John

John Curran
President and CEO
American Registry for Internet Numbers



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