[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 farmer at umn.edu
Mon Sep 16 19:06:31 EDT 2013

On 9/15/13 13:18 , William Herrin wrote:
> On Sat, Sep 14, 2013 at 5:47 PM, Owen DeLong <owen at delong.com> wrote:
>> On Sep 13, 2013, at 8:53 AM, William Herrin <bill at herrin.us> wrote:
>>> 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.
>> With all due respect, if that's the intent, then I oppose the policy.
> Hi Owen,
> My paragraph above is in error. Terri clarified the intent of the
> draft several messages ago.
> Paraphrasing: the authors want better public records so they know who
> to go to or go after when there is a law enforcement issue. And they'd
> like that to be someone within their respective jurisdictions. They
> would have us tighten eligibility to those folks with some kind of
> substantive legal presence in the region. Something more than "We've
> registered a Delaware LLC and park IP addresses on rented equipment in
> a rented data center."
> Based on her clarification, I'd drop the language which seeks to have
> the number resources employed in-region. That muddies the issue and
> makes consensus harder than it needs to be. The issue is not where the
> IP addresses are used, but whether the registrant can be compelled to
> cooperate with local law enforcement and adhere to local law.

The intent of requiring a plurality or a minimum percentage is not to 
keep resources within the region, but along with the other requirements 
of a legal presence and operating a network in region, the intent is to 
ensure all organizations receiving resources from ARIN actually have a 
real presence within the ARIN region, be that a network with a footprint 
wholly contained within the region, a network with a global footprint 
based in the ARIN region, or the in-region need of a global network, 
based any where.  Requiring a minimum percentage of resource be 
justified from within the region adds another level of assurance that an 
organization has such a real presence within the ARIN region.

Without some minimum for justification within the ARIN region it would 
be theoretically possible for an organization to have a legal presence 
and operational network within region, and get resources from ARIN and 
use 0.001% within the region 99.999% outside the region, that just 
doesn't pass a smell test for me.  That sounds more like they are 
operating a network with a global footprint that is really based out of 
another region, than based in the ARIN region.

I think we want to allow organizations with a global network based in 
the region to get resources from ARIN if they wish.  Some organizations 
may want to get resources from other RIRs, or all 5.  Others 
organizations may find it easier to get resources from some other RIRs 
(those near the minimum), and a few may need to by policy (those with 
less than the minimum).  But, the vast majority of organizations 
shouldn't have to get resources from other RIRs unless they want to.

>>> 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%.
>> I suppose you can make it sound complex like that, but, in reality, it's
>> much simpler… You need to make sure that more of your operations
>> using ARIN space are in the ARIN region than anywhere else.

As I said in my response to Matt, I think we could simplify things by 
going with a minimum percentage rather than a plurality.  But I agree 
with Owen a plurality really isn't that complicated.  A minimum 
percentage would probably water down the requirement more that some 
people want.  But if we can find consensus around a simple percentage 
then lets use that.  I'm suggesting 20%, 25% or 30%, but I'd like to 
know what others think.

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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