[arin-ppml] ARIN-prop-155 IPv4 Number Resources for Use Within Region

[Owen DeLong]

I oppose this proposal. There are a number of ARIN-Region-Based ISPs
and other organizations that have international networks and prefer to
get all of their number resources from one RIR and have been doing so
for many years.

There is no justification to suddenly discontinue this practice.

I am not opposed to the apparent primary intent of this policy which is to
prevent registry shopping by organizations not primarily within the ARIN
region, but, suddenly blocking the legitimate use of ARIN resources to
number global networks would have significant negative impacts on
a number of organizations.

Owen

Full disclosure: I work for an ISP that has allocations from ARIN and
from APNIC. The vast majority of our space comes from ARIN and we
have operations in the RIPE, ARIN, and APNIC regions as well as
numbering customers in the APNIC, AfriNIC, ARIN,
RIPE, and LACNIC regions. Some historical customers in APNIC region
are numbered from ARIN space prior to our getting space from APNIC.
We now use the APNIC space to number our customers in that region.
All other regions we are using ARIN space at this time. As such,
my employer is one such organization that would be negatively impacted
by this policy.


On Jul 1, 2011, at 12:24 PM, ARIN wrote:

> ARIN-prop-155 IPv4 Number Resources for Use Within Region
> 
> ARIN received the following policy proposal and is posting it to the
> Public Policy Mailing List (PPML) in accordance with the Policy
> Development Process.
> 
> The ARIN Advisory Council (AC) will review the proposal at their next
> regularly scheduled meeting (if the period before the next regularly
> scheduled meeting is less than 10 days, then the period may be extended
> to the subsequent regularly scheduled meeting). The AC will decide how
> to utilize the proposal and announce the decision to the PPML.
> 
> The AC invites everyone to comment on the proposal on the PPML,
> particularly their support or non-support and the reasoning
> behind their opinion. Such participation contributes to a thorough
> vetting and provides important guidance to the AC in their deliberations.
> 
> Draft Policies and Proposals under discussion can be found at:
> https://www.arin.net/policy/proposals/index.html
> 
> The ARIN Policy Development Process can be found at:
> https://www.arin.net/policy/pdp.html
> 
> Mailing list subscription information can be found
> at: https://www.arin.net/mailing_lists/
> 
> Regards,
> 
> Communications and Member Services
> American Registry for Internet Numbers (ARIN)
> 
> ## * ##
> 
> Policy Proposal Name: IPv4 Number Resources for Use Within Region
> 
> Proposal Originator: Robert Seastrom
> 
> Proposal Version: 1.0
> 
> Date: 2011-07-01
> 
> Proposal type:  NEW
> 
> Policy term: PERMANENT
> 
> Policy statement:
> 
> Insert the following text in the NRPM:
> 
> 4.2.1.7 - Presence within the ARIN region
> 
> These IPv4 addresses are issued solely for use in networks within the
> ARIN region. Organizations requesting IPv4 addresses from ARIN must
> provide documentation to demonstrate the addresses will be used to
> number customers/devices within the ARIN region and must agree to use
> the addresses solely for that purpose.  This requirement shall be
> binding only on number resources requested after its ratification by
> the ARIN Board of Trustees.
> 
> 
> 4.3.7 - Presence within the ARIN region
> 
> These IPv4 addresses are issued solely for use in networks within the
> ARIN region. Organizations requesting IPv4 addresses from ARIN must
> provide documentation to demonstrate the addresses will be used to
> number customers/devices within the ARIN region and must agree to use
> the addresses solely for that purpose.  This requirement shall be
> binding only on number resources requested after its ratification by
> the ARIN Board of Trustees.
> 
> Rationale:
> 
> ICANN's ICP-2 document established a framework for _regional_
> Internet registries, each to serve a well-defined geographically
> scoped constituency.
> 
> The various RIRs will exhaust their free-pools at different times.
> This creates a situation in which requesting organizations attempt an
> end-run on ICP-2 and the RIR framework by coming directly to ARIN for
> space to use outside the ARIN region.  In other cases, subsidiaries,
> sister organizations located within the ARIN region, or global
> organizations headquartered within the ARIN region have requested
> space that is ultimately destined for use outside the ARIN region.
> 
> Failure to address this situation in a timely fashion will grant an
> unfair advantage to large multinationals who will be able to "shop
> around"  requests for space and hasten RIR free pool runout in the ARIN region.
> 
> Leaving this loophole unaddressed is incompatible with ARIN's
> principle of stewardship.
> 
> This problem is not unique to ARIN.  Similar proposals are under
> consideration in the LACNIC and AfriNIC regions.
> 
> Timetable for implementation:  Immediate
> 
> 
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