[arin-ppml] Draft Policy ARIN-2014-1: Out of Region Use

[ARIN]

On 24 January 2014 the ARIN Advisory Council (AC) accepted 
"ARIN-prop-192 Out of Region Use" as a Draft Policy.

Draft Policy ARIN-2014-1 is below and can be found at:
https://www.arin.net/policy/proposals/2014_1.html

You are encouraged to discuss the merits and your concerns of Draft 
Policy 2014-1 on the Public Policy Mailing List.

The AC will evaluate the discussion in order to assess the conformance 
of this draft policy with ARIN's Principles of Internet Number Resource 
Policy as stated in the PDP. Specifically, these principles are:

  * Enabling Fair and Impartial Number Resource Administration
  * Technically Sound
  * Supported by the Community

The ARIN Policy Development Process (PDP) can be found at:
https://www.arin.net/policy/pdp.html

Draft Policies and Proposals under discussion can be found at:
https://www.arin.net/policy/proposals/index.html

Regards,

Communications and Member Services
American Registry for Internet Numbers (ARIN)


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Draft Policy ARIN-2014-1
Out of Region Use

Date: 29 January 2014

Problem statement:

Current policy neither clearly forbids nor clearly permits out of region 
use of ARIN registered resources. This has created confusion and 
controversy within the ARIN community for some time. Earlier work on 
this issue has explored several options to restrict or otherwise limit 
out of region use. None of these options have gained consensus within 
the community. The next logical option is to discuss a proposal that 
clearly permits out of region use without limits, beyond those already 
existing in policy.

Permitting out of region use, however, poses issues that have to be 
addressed by policy and adjustments to operational practice. Out of 
region use needs a clear definition and any operational practices based 
on that definition must not be unnecessarily burdensome. It is 
significantly more difficult and costly for ARIN Staff to independently 
verify the justification and utilization of resources that are 
reassigned or otherwise used outside of the ARIN service region. There 
needs to be recognition of this difference in policy and associated 
operational practices, especially the cost differential when there is 
more than an incidental amount of out of region use.

Policy statement:

Create new Section X;

X. Out of Region Use

ARIN registered resources may be used outside the ARIN service region 
and such use is valid justification for additional resources. Resources 
are considered to be used outside the region if any of the following are 
located outside the region.

A. The user or customer billing address
B. The user or customer service address
C. The technical infrastructure address, such as the point of presence 
(POP), data center, or other similar location

X.1 Verification of Out of Region Use

The utilization of ARIN registered resources must be verified when 
evaluating a request for additional resources or during a resource 
review, including any resources used outside the ARIN service region. 
Resources used outside the region must be verified to no less than an 
equivalent standard as resources used within the region. To this end 
ARIN, in its sole discretion, may engage independent external entities 
to assist it in the verification of information related to any resources 
used outside the region.

X.2 Incidental Use

Out of region use of ARIN registered resources by an organization that 
totals less than an equivalent of a /20 of IPv4, a /36 of IPv6, and 10 
ASNs are considered incidental use and as such are accounted for as if 
used within the ARIN service region.

X.3 Critical Infrastructure

Resources justified through critical infrastructure policies are 
accounted for as if used within the ARIN service region, regardless of 
their actual location of use.

X.4 Multi-Instance Use

Any resources used simultaneously in multiple locations, such as an 
anycast prefix or ASN, are accounted for as used outside the region, 
only if they are exclusively used outside the region.

6. Comments:
a. Timetable for implementation: Immediate

b. Anything else

Current policy is ambiguous on the issue of out of region use of ARIN 
registered resources. The only guidance on the issue in current policy 
is in Section 2.2, that defines the term RIR; “... The primary role of 
RIRs is to manage and distribute public Internet address space within 
their respective regions.” Some in the community believe this means out 
of region use should be at least limited or restricted while others 
believe this is only intended to focus efforts within the region and not 
define where resources may be used.

Several other policy proposals have explored restricting or otherwise 
limiting out of region use. None of these proposals gained consensus 
within the ARIN community. During the latest of these proposals, 
ARIN-2013-6, several standards were explored, a majority of use within 
region, a plurality of use within region, and some discussion of a 
minimum of 20 percent use within region. It was felt that each of these 
standards would interfered, to one extent or another, with the 
legitimate operations of multi- or trans-regional networks.

Section 2.2 tells us, the primary purpose of the RIRs are to manage and 
distribute resources within their regions. None the less, there have 
always been networks that donÂ’t neatly fit within the regions created 
by the RIR system. These legitimate trans-regional networks are operated 
by international businesses or global service providers, many of which 
are based within the ARIN region. Prior to IPv4 run-out, these 
trans-regional networks requested resources from ARIN for use both 
inside or outside the region, as long as the requests were justified by 
need.

As a result of IPv4 run-out, many in the community want to restrict out 
of region use to prevent ARIN resources from going to networks without a 
real technical presence in the ARIN region. However, any attempt to 
limit or restrict such out of region use inevitably will affect these 
legitimate trans-regional networks. Further, even the most restrictive 
regional use requirements will not significantly prolong the 
availability of IPv4 resources within the ARIN region. Therefore, 
attempting to restrict or limit out of region use of resources, even if 
it were for IPv4 only, is ineffective, inefficient, and overly 
burdensome to important elements of the global Internet.

The major concept behind this proposal is to allow out of region use 
without any limits, other than those already in policy, but bring an 
economic factor to play on the issue. It requires ARIN to verify out of 
region use to no less than an equivalent standard as in region use, and 
enables ARIN to engage external entities to assist in this verification. 
It is expected ARIN will have agreements with all such external entities 
to ensure the confidentiality of all supporting documentation is preserved.

ARIN engaging external entities to assist in verification of out of 
region use is mostly an ARIN business issue, and not primarily a policy 
issue. However, today there is a general assumption that such 
verification for in region use is done almost exclusively in house at 
ARIN. Making this issue clear in policy follows a principle of least 
surprise, as the use of such external entities is likely to be 
frequently necessary to verify out of region use, especially in parts of 
the world where English is not the primary language. Or put another way, 
use of an external entity when verifying out of region use is more 
likely to be the rule rather than an exception.

There are additional expenses and complexity involved in verifying out 
of region use, as a result of language and logistical barriers that the 
regionality of the RIR system was originally conceived to mitigate. In 
addition, section 2.2 is clear that providing resources for out of 
region use is, at best, only a secondary role for ARIN. As a result, out 
of region use should not significantly burden the primary role of 
providing resources for use within the region. These factors justify a 
recommendation to the Board of Trusties to create a separate fee 
structure for out of region use, creating the aforementioned economic 
factor.

This economic factor and the recommendation for a separate fee 
structure, are again mostly ARIN business issues, and not part of policy 
in general. However, this is one of those instances where policies and 
fees are intertwined.

It seems reasonable that this economic factor should be applied only to 
those that make substantial use of ARIN registered resources outside the 
region, and not to those that primarily use resources within the region. 
This proposal defines incidental out of region use, to ensure that 
trivial, insignificant or otherwise incidental use are exempt from the 
discussed economic factor, and are accounted for as if used within the 
region.

Some amount of out of region use should be considered normal even for a 
network primarily based within the ARIN region. For example, numbering a 
global backbone that provides global access necessary for in region 
customers. Also, the other RIRs have minimum requirements to justify an 
initial allocation or assignment, similar to ARIN. These and other 
examples and issues, justify allowing some minimal amount of out of 
region use to be accounted for as if it were in region use. The 
currently proposed policy statement, X.2, defines incidental use in 
terms of an absolute thresholds for each type of resource.

Another option would be a percentage based threshold, say 20%. However, 
a percentage based threshold has the disadvantage that even a minimal 
change in usage can cause the ratio between in region and out of region 
use to change, potentially causing an oscillation around this threshold. 
This creates significant uncertainty for organizations as to if the 
discussed economic factor will apply to them, or not. Where as once an 
absolute threshold has been crossed by a significant amount, it is 
highly unlikely that any additional changes in usage will cause an 
oscillation around the threshold, providing much more certainty for most 
organizations.

Additionally, the proposal deals with a couple special cases in X.3 and 
X.4. Due to the relatively small resource impact and high importance to 
overall Internet stability; resources for critical infrastructure are 
also exempt from the discussed economic factors, and are accounted for 
as if used within the region. Anycast prefixes, and other resources used 
simultaneously in multiple locations, are considered as used outside the 
region only when they are exclusively used outside the region. Or put 
another way, as long as at least one instance is located within the 
region, they are considered used within the region, regardless of how 
many other instances are located outside the region. Both of these 
special cases have an overall positive impact on the Internet and should 
not be discouraged in anyway by this policy, lumping them in with 
general out of region use could be a disservice to the Internet and 
unnecessarily burdensome.

In summary, this proposal ensures that global organizations or global 
service providers base within the ARIN region may receive resources to 
operate their global network solely from ARIN, if they wish to do so. As 
long as the utilization of the out of region resources are verified to 
no less than an equivalent standard as in region resources. This is 
particularly important for IPv6; requiring organizations get IPv6 
resources from multiple RIRs, or even making it appear that they should, 
will result in additional unique non-aggregatable prefixes within the 
IPv6 route table, rather than minimizing them, which one of the policy 
objectives for IPv6.

Finally, a separate but somewhat related issue; regardless of where ARIN 
registered resources are used, inside or outside of the ARIN service 
region, organizations must first qualify to receive resources from ARIN. 
ARINÂ’s current operational practice is that an organization must be 
formed within the ARIN service region in order to qualify to receive any 
resources from ARIN. The issue of who should be eligible to receive 
resources was commingled with out of region use in ARIN-2013-6. It was 
felt these issues should be considered separately. Therefore, the issue 
of who should be eligible to receive resources is purposefully not dealt 
with by this proposal, and if any changes are necessary there should be 
separate policy proposals to deal with this issue independently.