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

[David Farmer]

There has been only one comment on this revised text, the AC needs more 
input from the community regarding this revised text.  Next Thursday the 
AC must voting if it should promote this Draft Policy to Recommended 
Draft Policy status before the October ARIN meeting.  A Draft Policy 
cannot go to Last Call until it has gone to a Public Consultation as a 
Recommended Draft Policy.

Please provide your feedback, even if its as simple as you support the 
policy or not.

Thank you.

On 9/4/13 16:25 , ARIN wrote:
> Revised text for ARIN-2013-6 is below and can be found at:
>
> https://www.arin.net/policy/proposals/2013_6.html
>
> 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)
>
>
> ## * ##
>
> Draft Policy ARIN-2013-6 Allocation of IPv4 and IPv6 Address Space to
> Out-of-region Requestors - Revised Text (V2)
>
> Date: 4 September 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:
> Create new policy Section X.
>
> X. Resource Justification within ARIN Region
> Organizations requesting Internet number resources from ARIN must
> provide proof that they (1) are an active business entity legally
> operating within the ARIN service region, and (2) are operating a
> network located within the ARIN service region. In addition to meeting
> all other applicable policy requirements, a plurality of resources
> requested from ARIN must be justified by technical infrastructure and
> customers located within the ARIN service region, and any located
> outside the region must be interconnected to the ARIN service region.
> The same technical infrastructure or customers cannot be used to justify
> resources in more than one RIR.
> ###
>
> Authors Comments:
>
> 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 enforcement¹s 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 RIRs 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?
>
> Advisory Council Comments:
>
> The term "Internet number resources" or more simply "resources" should
> be used instead of "IP Blocks" to more accurately reflect the totality
> of the Registry. This implies both IPv4 and IPv6, as well as ASNs.
> While Internet registries are organized on a regional basis, policy must
> recognize that many networks, services and operations are trans-regional
> and it would be burdensome and impractical to attempt to strictly
> enforce territorially exclusive allocations. Therefore, policy should
> seek to balance the regional structure of address allocation with
> flexibility of service provision, by ensuring that ARIN¹s resources are
> primarily aligned with the ARIN service region but facilitate
> flexibility and efficiency of use by applicants from any region.
> There are concerns that out of region organizations should be able to
> request resources for use within the ARIN service region. The proposed
> text accommodates this issue by requiring only proof that an
> organization is "legally operating within the ARIN Service Region". This
> includes business entities formed in the region, or other business
> entities with legal branch offices within the region. So, as long as an
> out of region organization is "legally operating within the ARIN Service
> Region" they can request resources from ARIN.
>
> Current operational practice is to require an organization be formed
> within the ARIN service region. However, if this were applied by all the
> RIRs, a global network would be required to have a minimum of five
> subsidiaries, one formed in each of the five RIR regions, this seems
> overly burdensome. Good resource policy should consider the consequences
> of all RIRs adopting the same policy.
>
> Previous discussions of the topic indicated that it is difficult to
> enforce and undesirable for many in the community to dictate where
> resources are to be used once they are allocated. A strategy to deal
> with this is to focus the policy on the technical infrastructure and
> customers used to justify the requested number resources from ARIN, as
> opposed to where resources are actually used once allocated. This is a
> subtle but important distinction.
>
> While resources received from ARIN may be used outside the ARIN region,
> a common technical infrastructure must interconnect the use of these
> resources to the ARIN region. This provides a necessary nexus with the
> ARIN service region for such out of region use. Therefore, if a discrete
> network is operating within another region, not interconnected to the
> ARIN region, then resources for that discrete network should be
> requested from that region's RIR.
>
> A concern was raised that this policy shouldn't limit or interfere with
> outbound inter-RIR transfers. If we focus on what justifies a request
> for resources from ARIN, outbound inter-RIR transfers shouldn't be
> affected, as they are clearly based on the receiving RIR's policies.
>
>  From previous discussions of the topic, "double dipping" should not be
> allowed, that is using the same technical infrastructure or customers to
> justify resources from ARIN and another RIR at the same time.
> The legal jurisdiction an organization is formed in doesn¹t necessarily
> reflect the jurisdictions in which it operates, or even that it operates
> a network in a jurisdiction. This implies that we should have both
> technical and legal requirements regarding operating within the ARIN
> service region in order to receive resources.
>
> The original text used the term "majority", seeming to describe a
> "simple," "absolute" or "overall" majority, which means greater than
> 50%. Many organizations don't have greater than 50% of their users or
> customers in any one region. A "plurality", "relative majority",
> "largest of", or more specifically "more than any other RIR's service
> region" seems to be the intended and appropriate meaning of the term
> "majority" in this context. Let's clarify that intent by using the term
> "plurality".
>
> The intent is not to require an organization to have an overall
> plurality of its technical infrastructure and customers within the ARIN
> service region. Rather, it is to ensure that the plurality of currently
> requested resources is justified from within the ARIN region. If an
> organization¹s primary, or largest, demand for resources is in another
> region then the organization should request resources from that region's
> RIR.
> --
>
> ## * ##

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David Farmer               Email: farmer at umn.edu
Office of Information Technology
University of Minnesota
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