[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

[John Santos]

On Fri, 13 Sep 2013, William Herrin wrote:

> On Thu, Sep 12, 2013 at 10:37 PM, Owen DeLong <owen at delong.com> wrote:
> > Majority is certainly more problematic than plurality. Plurality might not be
> > the best possible choice, either, but nobody, including myself, has yet proposed
> > a better alternative. The AC would certainly welcome any improved language
> > from the community if anyone has a better idea.
> 
> Hi Owen,
> 
> The intent of the policy proposal is to keep the use of ARIN addresses
> in-region. I say this with the utmost respect: A 20% rule doesn't do
> that. It does, however, create a new and potentially onerous
> documentary burden on every registrant requesting addresses.
> 
> More, "plurality" makes the 20% rule needlessly complicated. I have to
> keep 20% in the ARIN region... unless I have 23% in the RIPE region
> and then I need to keep 24% in the ARIN region unless I have 30% in
> the APNIC region in which case I need 31% in the ARIN region, but if
> that drops the RIPE region down to 27% I can reduce the ARIN region
> holdings to 28%.
> 
> Yuck!

I'm not sure if I'm in favor or against the this proposal, but I think
your argument is not valid.

You are making the process needlessly complicated.  You don't need to
"keep" anything anywhere.  Only when you need more resources do you need
to evaluate what region has the most systems (presumably with in-use
addresses as a proxy for "systems", and probably with total subnet space
as a proxy for addresses), and request the address space from that RIR (or
any other RIR that has not adopted this or a similar policy.)

You have to know how much of your address space allocation is in use
before you can request more space.  This just requires that you have
some (extremely vague due to the extremely coarse granuality) idea of
*where* you are using the addresses.

> 
> I'm for keeping ARIN addresses in region. I'm against creating new and
> potentially onerous documentary burdens. I'm doubly against creating
> new and potentially onerous documentary burdens which fail to
> plausibly achieve their defined goal.

I'm not sure I'm in favor of keeping addresses in region.  Certainly, with
inter-RIR transfers, they won't *stay* in region!

I agree with your doubts about this acheiving its intended goal, but I
don't think the documentation burdens are particularly onerous.  At worst
case, less than 3 bits per IP address, but almost certainly knowing where
a particular subnet is would suffice.  Businesses with multiple locations
need to know where their hosts are for management purposes anyway.  Mobile
devices are generally with in a few hundred feet of their Wifi hotspot or
within a few miles of their current cell tower, and someone running such
a network has to know how much load their is on each location for planning
and problem resolution anyway.

> 
> If there is no community consensus for a "should be in region" number
> in the 80% to 90% range then I think the draft should be abandoned. A
> plurality rule combines the worst elements of the notion, not the
> best.
> 

What if the business is international, with sites all over the world?
Should they be forced to run at least 5 separate networks instead of a
single integrated network?

In your original example, if you have 23% in RIPE and 20% in ARIN, then
you should go to RIPE for more addresses.  (Or the transfer market, if
RIPE is exhausted.)

All this stuff about plurality vs. majority vs. 80-90% vs. "most of" (for
some very vague definition of "most of") is moot with IPv6 anyway, since
(at least in theory), a single IPv6 allocation should suffice forever.

The lack of a definition of what constitutes a "legal business", the lack
of recognition of the international nature of many businesses and 
organizations, and what seems to me an implicit assumption that US law
applies to everyone all worry me more than the documentation requirements.


> Regards,
> Bill Herrin
> 
> 
> -- 
> William D. Herrin ................ herrin at dirtside.com  bill at herrin.us
> 3005 Crane Dr. ...................... Web: <http://bill.herrin.us/>
> Falls Church, VA 22042-3004
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> 

-- 
John Santos
Evans Griffiths & Hart, Inc.
781-861-0670 ext 539