[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

[Kevin Kargel]

I still don't see how this is going to be enforceable.  To my eye it would entail getting geo-data for all last mile routers that service IP's under ARIN control and having someone or a sophisticated AI bot continuously scanning the BGP tables to enumerate and verify the geo-locations of the endpoints.  
This sounds like a project that I suspect the ARIN community is going to be hesitant to fund.
If the idea is just to ask people if they are in the ARIN governance area and make them promise to never move offshore (knowing it will not be subsequently policed) then I submit that the algorithm is way too easy to game by unscrupulous operators and will end up being a token policy that creates more bureaucracy and trouble for legitimate operators.  
Unenforceable policy is a waste of time and money.
If you can figure out a way to enforce *and* implement it I would support the policy, but until that time I have to vote "nay".  I suspect that even if it were implemented enforcement would only be possible if it were written with an anti-grandfather clause.
Kevin

-----Original Message-----
From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On Behalf Of Stumme, Terri L.
Sent: Friday, September 13, 2013 1:10 PM
To: Jeffrey Lyon; William Herrin
Cc: robert.flaim at ic.fbi.gov; Kellum, Andre W.; arin-ppml at arin.net
Subject: Re: [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

As the author of the original DRAFT policy proposal, I'd like to reiterate the original intent of the policy:  to enable ARIN staff to validate/verify requestors of address space who establish a "shell company" in the US for the sole purpose of acquiring ARIN resources.  ARIN has historically required legal incorporation within the region.  Due to the depletion of IPv4 there has been a significant increase in out-of-region requestors, and they are returning often (every three weeks) to request larger blocks.  ARIN staff does not have the capability or mechanisms in place to verify customer usage, nor to verify/validate physical contact information for these out-of-region entities.
If ARIN staff is unable to validate/verify requestors contact information or customer usage, enforcement of ARIN contractual obligations is significantly impeded.
Law enforcement simply wants to ensure that mechanisms are in place for verification/validation of ARIN's customers to avoid allocation to organizations/individuals who may intend to utilize IP address space for nefarious purposes, and that should this occur, accurate pointers (requested via subpoena) are available from ARIN for law enforcement to proceed with a criminal investigation.

-----Original Message-----
From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On Behalf Of Jeffrey Lyon
Sent: Friday, September 13, 2013 12:02 PM
To: William Herrin
Cc: arin-ppml at arin.net
Subject: Re: [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

On Fri, Sep 13, 2013 at 11:53 AM, William Herrin <bill at herrin.us> 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 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.
>
> 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.
>
> 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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I agree that ARIN IP's must be reserved for in region use.

--
Jeffrey A. Lyon, CISSP
President, Black Lotus Communications
mobile: (757) 304-0668 | gtalk: jeffrey.lyon at gmail.com | skype: blacklotus.net _______________________________________________
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