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

[David Huberman]

Hello -

I fully support this proposal text. 

Quote:

"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."

The internet engineering community purposely designed the RIR system to be regional.  Different regions have different needs, and grow at different rates. Current NRPM text is deficient in the arena of defining who can, and cannot, request number resources from the Registry.  Importantly, staff have (on multiple occasions) presented the ARIN community with the challenge of dealing with requestors who are trying to "game" the RIR system by obtaining space from ARIN when the customers are primarily (and even exclusively) outside the ARIN region. The proposed policy text neatly offers staff a good tool to overcome those challenges.

The proposed policy text is elegant and operational for a few reasons:

1) If a majority of an organization's customers is outside the ARIN region, there organization should be subject to the RIR in which their majority resides.  If that majority is in APAC or EMEA, and those regions are out of space, that challenge is out-of-scope of ARIN policy. (It is the purview of that region's registry and its policy making community.)

2) It does not impede on the ability of global backbone operators to request space from ARIN, so long as the ARIN region is the largest consumer of devices and addresses. 

3) The use of the term "majority" presents no functional challenges to either requestors or staff.  Merriam-Webster has a definition of the word majority stating, "the greater quantity or share".

I have only one recommended edit to the text.  I recommend replacing "IP blocks" with "number resources", so that the text precisely captures the activities of the Registry.

Yours,
David Huberman