[arin-ppml] "Re: Contents of ARIN-PPML digest, Vol 99, Issue 10..."

Sat Sep 14 13:58:28 EDT 2013

How about if each company would have to make their case, based on the greatest number of attachment points to a particular area? They could show they have a plurality of elements linking them to ARIN's region rather than to any other region (such as a majority of their end-users being present in that region and/or it makes sense operationally to submit the request to ARIN because of the presence of a majority of its equipment located in that region, and/or other attachment elements to be defined).   

Nathalie Coupet
ARIN Member

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Sent: Friday, September 13, 2013 5:45 PM
Subject: ARIN-PPML Digest, Vol 99, Issue 9

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Today's Topics:

   1. Re: Draft Policy ARIN-2013-6: Allocation of IPv4 and IPv6
      Address Space to Out-of-region Requestors - Revised Problem
      Statement and Policy Text (William Herrin)
   2. Re: Draft Policy ARIN-2013-6: Allocation of IPv4 and IPv6
      Address Space to Out-of-region Requestors - Revised Problem
      Statement and Policy Text (William Herrin)
   3. Re: Draft Policy ARIN-2013-6: Allocation of IPv4 and IPv6
      Address Space to Out-of-region Requestors - Revised Problem
      Statement and Policy Text (William Herrin)
   4. Re: Draft Policy ARIN-2013-6: Allocation of IPv4 and IPv6
      Address Space to Out-of-region Requestors - Revised Problem
      Statement and Policy Text (John Curran)
   5. Re: Draft Policy ARIN-2013-6: Allocation of IPv4 and    IPv6
      Address Space to Out-of-region Requestors - Revised    Problem
      Statement and Policy Text (David Conrad)
   6. Re: 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)
   7. Re: Draft Policy ARIN-2013-6: Allocation of IPv4 and    IPv6
      Address Space to Out-of-region Requestors - Revised    Problem
      Statement and Policy Text (David Conrad)

----------------------------------------------------------------------

Message: 1
Date: Fri, 13 Sep 2013 15:54:37 -0400
From: William Herrin <bill at herrin.us>
To: John Curran <jcurran at arin.net>
Cc: "arin-ppml at arin.net" <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
Message-ID:
    <CAP-guGWHiFfyHSzgRVghqK+cSNwhoD+S_G-H_AgBs+Nn6he2QQ at mail.gmail.com>
Content-Type: text/plain; charset=ISO-8859-1

On Fri, Sep 13, 2013 at 3:26 PM, John Curran <jcurran at arin.net> wrote:
> It is ARIN's practice to assign number resources to organizations,
> not individuals.

That's me, Mr. Outlier.

>> On Sep 13, 2013, at 11:59 AM, William Herrin <bill at herrin.us> wrote:
>>> More importantly: why not?
>
> At a minimum, NRPM 2.6 ("End-user" definition) would need to be
> changed to recognize IP address assignments to individuals -
>
> "2.6 An end-user is an organization receiving assignments of IP
>      addresses exclusively for use in its operational networks."

An organization is some number of people acting on concert towards a
common goal. One is an acceptable number. Given Citizens United and
the history of similar rulings, I'm pretty sure I can make that claim
stick.

Besides which, I presume ARIN doesn't refuse to do business with sole
proprietorships. A sole proprietorship has no legal existence separate
from the single individual who owns it. With minor exceptions (Bob's
Bait and Tackle can't get married or adopt children) a proprietorship
is legally synonymous with its owner.

What else ya got? :)

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

------------------------------

Message: 2
Date: Fri, 13 Sep 2013 16:41:42 -0400
From: William Herrin <bill at herrin.us>
To: John Santos <JOHN at egh.com>
Cc: "arin-ppml at arin.net" <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
Message-ID:
    <CAP-guGUe5kebTSQNgD_jsNznMv3=2bjm_gqQAd7BbfxER-uLKQ at mail.gmail.com>
Content-Type: text/plain; charset=ISO-8859-1

On Fri, Sep 13, 2013 at 12:52 PM, John Santos <JOHN at egh.com> wrote:
> 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?

Hi John,

That's a fair question. I hope I don't mischaracterize the ITU's
position when I say they think a strictly regionalized registry system
is detrimental to business in exactly this manner.  They would have
themselves designated as a registry with worldwide scope in order to
serve these interests among others.

I'd offer this answer: if we want to continue as a system of regional
registries then it's generally appropriate for a multinational
organization get acquire the number resources it deploys in each
region from that region's registry. One network. Five suppliers, whose
goods have geographical constraints on their use.

If a system of regional registries is no longer indicated, that's a
much bigger topic of discussion which we shouldn't back-door by having
ARIN unilaterally act as registry to the world.

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

------------------------------

Message: 3
Date: Fri, 13 Sep 2013 16:30:36 -0400
From: William Herrin <bill at herrin.us>
To: Gary Buhrmaster <gary.buhrmaster at gmail.com>
Cc: "arin-ppml at arin.net" <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
Message-ID:
    <CAP-guGWPfrSPJbsvc2ZTshWgyQ-KzXF-+Zjhq0aoBq3=3Z=m1g at mail.gmail.com>
Content-Type: text/plain; charset=ISO-8859-1

On Fri, Sep 13, 2013 at 1:06 PM, Gary Buhrmaster
<gary.buhrmaster at gmail.com> wrote:
> On Fri, Sep 13, 2013 at 3:53 PM, William Herrin <bill at herrin.us> wrote:
>> Yuck!
>
> Unless I am misreading this, this proposal deals with the initial
> (or additional) allocation/assignments, and not on-going activities.
> Once you get the numbers, you could then move the numbers
> to other regions.

Hi Gary,

Did I miss the text which exempts this draft from the exercise of NRPM
section 12.2.c and d?

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

------------------------------

Message: 4
Date: Fri, 13 Sep 2013 21:13:39 +0000
From: John Curran <jcurran at arin.net>
To: William Herrin <bill at herrin.us>
Cc: "arin-ppml at arin.net" <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
Message-ID: <0336F44F-01C1-4724-83D2-DA4AF763D225 at arin.net>
Content-Type: text/plain; charset="us-ascii"

On Sep 13, 2013, at 3:54 PM, William Herrin <bill at herrin.us> wrote:

> On Fri, Sep 13, 2013 at 3:26 PM, John Curran <jcurran at arin.net> wrote:
>> It is ARIN's practice to assign number resources to organizations,
>> not individuals.
> 
> That's me, Mr. Outlier.
> 
>>> On Sep 13, 2013, at 11:59 AM, William Herrin <bill at herrin.us> wrote:
>>>> More importantly: why not?
>> 
>> At a minimum, NRPM 2.6 ("End-user" definition) would need to be
>> changed to recognize IP address assignments to individuals -
>> 
>> "2.6 An end-user is an organization receiving assignments of IP
>>     addresses exclusively for use in its operational networks."
> 
> An organization is some number of people acting on concert towards a
> common goal. One is an acceptable number. Given Citizens United and
> the history of similar rulings, I'm pretty sure I can make that claim
> stick.
> 
> Besides which, I presume ARIN doesn't refuse to do business with sole
> proprietorships. A sole proprietorship has no legal existence separate
> from the single individual who owns it. With minor exceptions (Bob's
> Bait and Tackle can't get married or adopt children) a proprietorship
> is legally synonymous with its owner.
> 
> What else ya got? :)

Bill - 

We have no problem dealing with sole proprietorships; they are
organizations and can receive assignments.  Note that the number
resources are still assigned in such cases to the organization
(i.e. in the name of the sole proprietorship) not the individual.

FYI,
/John

John Curran
President and CEO
ARIN

------------------------------

Message: 5
Date: Fri, 13 Sep 2013 17:12:58 -0400
From: David Conrad <drc at virtualized.org>
To: Kevin Kargel <kkargel at polartel.com>
Cc: "arin-ppml at arin.net" <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
Message-ID: <B4388CB9-5E8B-4071-B438-C74D35AA780E at virtualized.org>
Content-Type: text/plain; charset="us-ascii"

Kevin,

On Sep 13, 2013, at 2:42 PM, Kevin Kargel <kkargel at polartel.com> wrote:
> 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.

Why wouldn't an assertion by the applicant that they run a network in the ARIN region and perhaps a traceroute or two be sufficient to meet the "operating a network located in the ARIN service region" requirement?

> 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.  

I don't see this being significantly different than gaming the "operational needs" requirement. I think the issue here is establishing a policy basis upon which violations, when detected, can be addressed. If it is discovered that someone is getting addresses to stockpile them for later sale, ARIN policy exists to allow ARIN to revoke those addresses.  This draft policy is saying that if someone is getting addresses for use outside ARIN's region, there would be a policy to allow ARIN to address that issue.

And, FWIW, I'll note that both AfriNIC and LACNIC (the remaining RIRs that have not gone into "last /8" policy) require companies to demonstrate in-region legal status and network usage. 

> 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.

Wait, I liked my grandfather... :) (sorry, not sure what an 'anti-grandfather clause is)

Regards,
-drc

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Message: 6
Date: Fri, 13 Sep 2013 16:20:22 -0500
From: Kevin Kargel <kkargel at polartel.com>
To: "arin-ppml at arin.net" <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
Message-ID:
    <8695009A81378E48879980039EEDAD28012B3D4D77 at MAIL1.polartel.local>
Content-Type: text/plain; charset="us-ascii"

-----Original Message-----
From: David Conrad [mailto:drc at virtualized.org] 
Sent: Friday, September 13, 2013 4:13 PM
To: Kevin Kargel
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

Kevin,

On Sep 13, 2013, at 2:42 PM, Kevin Kargel <kkargel at polartel.com> wrote:
> 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.

>>Why wouldn't an assertion by the applicant that they run a network in the ARIN region and perhaps a traceroute or two be sufficient to meet the "operating a network located in the ARIN service region" requirement?

A traceroute would only satisfy an initial test.  Trivially easy to set one up, get your allocation, and then move the network to where you really wanted it.

> 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.  

>>I don't see this being significantly different than gaming the "operational needs" requirement. I think the issue here is establishing a policy basis upon which violations, when detected, can be addressed. If it is discovered that someone is getting addresses to stockpile them for later sale, ARIN policy exists to allow ARIN to revoke those addresses.  This draft policy is saying that if someone is getting addresses for use outside ARIN's region, there would be a policy to allow ARIN to address that issue.

Just like ARIN follows up on the utilization requirement?  

>>And, FWIW, I'll note that both AfriNIC and LACNIC (the remaining RIRs that have not gone into "last /8" policy) require companies to demonstrate in-region legal status and network usage. 

Maybe they have a way to test and enforce their requirement.  If so perhaps it is a model we should pattern after.

> 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.

>>Wait, I liked my grandfather... :) (sorry, not sure what an 'anti-grandfather clause is)

Anti-grandfather means that the restrictions should equally apply to existing allocations, and current allocations that are operating outside of the ARIN region should be required to obtain allocations from their region and return the ARIN allocation.  Old allocations should not have a 'grandfather' exemption.  We would probably need to forgive their latest set of fees.
It would be onerously difficult to separate the pre and post allocations for enforcement.

Regards,
-drc

------------------------------

Message: 7
Date: Fri, 13 Sep 2013 17:45:41 -0400
From: David Conrad <drc at virtualized.org>
To: Kevin Kargel <kkargel at polartel.com>
Cc: "arin-ppml at arin.net" <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
Message-ID: <D17E2A39-386B-4804-9E26-AA8CB39B7D10 at virtualized.org>
Content-Type: text/plain; charset="us-ascii"

Kevin,

On Sep 13, 2013, at 5:20 PM, Kevin Kargel <kkargel at polartel.com> wrote:
> A traceroute would only satisfy an initial test.  Trivially easy to set one up, get your allocation, and then move the network to where you really wanted it.

Yes. However, if this subterfuge was noticed, the policy would give ARIN the capability to do something about it (if necessary), just like other ARIN policies.

> Just like ARIN follows up on the utilization requirement?  

I've been told ARIN has revoked address space for violation of policy.

> Anti-grandfather means that the restrictions should equally apply to existing allocations, and current allocations that are operating outside of the ARIN region should be required to obtain allocations from their region and return the ARIN allocation.  

My understanding of the policy proposal was that it was to apply to future allocations because the out-of-region requests appear to be increasing with the exhaustion of various RIR free pools.  Historically, it has been ... challenging to retroactively apply policy to pre-existing allocations.  If such retroactive application were desired (not going to comment one way or another on that aspect), I'd suggest it should be a different policy proposal.

Regards,
-drc

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