[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

Blake Dunlap ikiris at gmail.com
Thu Sep 12 14:43:06 EDT 2013

Do we really have to say opposed in principal instead of just wording every
draft for it to be considered applicable response?


On Thu, Sep 12, 2013 at 1:01 PM, David Farmer <farmer at umn.edu> wrote:

> 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<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<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<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.
>> --
>> ## * ##
> --
> ==============================**==================
> David Farmer               Email: farmer at umn.edu
> Office of Information Technology
> University of Minnesota
> 2218 University Ave SE     Phone: 1-612-626-0815
> Minneapolis, MN 55414-3029  Cell: 1-612-812-9952
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