[arin-ppml] Draft Policy ARIN-2013-6: Allocation of IPv4 and IPv6 Address Space to Out-of-region Requestors

[Christoph Blecker]

While there may be merits to this policy, I for sure take issue with the
following part of this statement:
"and have a majority of their technical infrastructure and customers in the
designated ARIN region"

There are many organizations who exist in more than one region and request
number resources from more than one RIR. Requiring that an organization
must have the majority of their technical infrastructure or customers
inside this region would be what I would understand to be a major deviation
from current practice, let alone requiring that both be true.

Cheers,
Christoph


On Tue, Jun 25, 2013 at 8:39 AM, ARIN <info at arin.net> wrote:

> Draft Policy ARIN-2013-6
> Allocation of IPv4 and IPv6 Address Space to Out-of-region Requestors
>
> On 20 June 2013 the ARIN Advisory Council (AC) accepted "ARIN-prop-189
> Allocation of IPv4 and IPv6 Address Space to Out-of-region Requestors" as a
> Draft Policy.
>
> Draft Policy ARIN-2013-6 is below and can be found at:
> https://www.arin.net/policy/**proposals/2013_6.html<https://www.arin.net/policy/proposals/2013_6.html>
>
> You are encouraged to discuss the merits and your concerns of Draft Policy
> 2013-6 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<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<https://www.arin.net/policy/proposals/index.html>
>
> Regards,
>
> Communications and Member Services
> American Registry for Internet Numbers (ARIN)
>
>
> ## * ##
>
>
> Draft Policy ARIN-2013-6
> Allocation of IPv4 and IPv6 Address Space to Out-of-region Requestors
>
> Date: 25 June 2013
>
> Problem Statement:
>
> ARIN number resources should be used primarily in the ARIN region, for
> ARIN region organizations. There is currently no explicit policy guiding
> staff in this area, this proposal seeks to correct that.
>
> Policy Statement:
>
> Any entity (individual or organization) requesting ARIN issued IP blocks
> must provide ARIN with proof of an established legal presence in the
> designated ARIN region, and have a majority of their technical
> infrastructure and customers in the designated ARIN region. This
> requirement applies to both IPv4 and IPv6 address space.
>
> Comments:
>
> The proposal originator said, "Although we represent law enforcement, and
> have brought forth this issue based upon our concerns and experience from a
> law enforcement perspective, this is a problem in which the entire ARIN
> community has a stake".
>
> As reported at the last meeting in Barbados, ARIN staff is having
> difficulty verifying organizations out-of-region. In many of the cases,
> particularly in VPS (Virtual Private Service), the only information
> received on these organizations by ARIN is a customer name and IP address.
> This information cannot be properly verified by ARIN. Accuracy of
> registration data is critical to not only law enforcement, but the greater
> ARIN community as it relates to abuse contact and complaints. In fact, most
> issues facing law enforcement are also shared by legitimate companies
> attempting, for instance, to identify an organization that has hijacked
> their IP address space.
>
> The expedited depletion of IPv4 address space in the ARIN region certainly
> seems to negatively impact those organizations currently operating in the
> region that may need to return to ARIN for additional IPv4 address space.
> While law enforcementÂ’s concern is that criminal organizations outside of
> the ARIN region can easily and quickly request large blocks of IPv4 address
> space from ARIN, organizations that are not truly global organizations, but
> specific national companies from the RIPE and APNIC regions, also have this
> capability which is detrimental to true ARIN region organizations.
>
> This policy proposal is re-enforcing practices the ARIN staff currently
> employs to ensure that ARIN IP space is used for and by companies that are
> legitimate and have a legitimate presence in the ARIN region. This policy
> will assist in defining clear criteria that will be helpful to ARIN staff
> and the community.
>
> The primary role of RIRÂ’s is to manage and distribute public Internet
> address space within their respective regions. The problem brought forth
> here clearly undermines the current RIR model; if any organization can
> acquire IP address space from any region, what then is the purpose of the
> geographical breakdown of the five RIRs?
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