[arin-ppml] Draft Policy ARIN-2013-6: Allocation of IPv4 andIPv6Address Space to Out-of-region Requestors - Revised Problem StatementandPolicy Text

Steven Ryerse SRyerse at eclipse-networks.com
Mon Sep 16 20:56:26 EDT 2013


Requiring some legal presence and operational presence in the region is doable.  Meeting a current footprint size as a majority percentage or a plurality percentage is irrelevant and there will always be an exception that is legitimate.  Defining what a real presence means is very subjective and it means different things to different folks.  The easiest thing to do in a policy is require a legal address and use of resources in the region.  After that the subjective part comes in and is very difficult for ARIN to police. (I suppose ARIN could send renewals only to the legal address and then if there isn’t one it would go undelivered and thus resources go unrenewed.  Probably not practical though.)

Steven Ryerse
President
100 Ashford Center North, Suite 110, Atlanta, GA  30338
770.656.1460 - Cell
770.399.9099- Office

[Description: Description: Eclipse Networks Logo_small.png]℠ Eclipse Networks, Inc.
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From: Bill Darte [mailto:billdarte at gmail.com]
Sent: Monday, September 16, 2013 8:39 PM
To: Steven Ryerse
Cc: David Farmer; William Herrin; arin-ppml at arin.net
Subject: Re: [arin-ppml] Draft Policy ARIN-2013-6: Allocation of IPv4 andIPv6Address Space to Out-of-region Requestors - Revised Problem StatementandPolicy Text

Steve, I believe this policy would focus on the 'next' allocation...the one currently being requested from ARIN.  A plurality for that one.
bd

On Mon, Sep 16, 2013 at 7:01 PM, Steven Ryerse <SRyerse at eclipse-networks.com<mailto:SRyerse at eclipse-networks.com>> wrote:
The problem here of course is there could be a legitimate international organization with over 50% of their network say in Asia and only say 2% in the US.  As long as the resources are going to be used in the ARIN region it is reasonable that they should be allocated resources from ARIN.  So majority or plurality doesn't work and there will always be a scenario that is legitimate but that doesn't fit into a contrived policy.

I don't believe ARIN can NOT allocate resources solely because more than 50% of existing resources reside in other regions.  This is an example of trying to use policy to NOT allocate resources and of course ARIN's mission is TO allocate resources.  The best that could be done by policy is to require they use them within the ARIN region.  I'm not sure if ARIN really wants to get into the policing business after resources have been allocated, but that is the only recourse if an org lies in their allocation request.

Steven Ryerse
President
100 Ashford Center North, Suite 110, Atlanta, GA  30338
770.656.1460<tel:770.656.1460> - Cell
770.399.9099<tel:770.399.9099>- Office

℠ Eclipse Networks, Inc.
                     Conquering Complex Networks℠


-----Original Message-----
From: arin-ppml-bounces at arin.net<mailto:arin-ppml-bounces at arin.net> [mailto:arin-ppml-bounces at arin.net<mailto:arin-ppml-bounces at arin.net>] On Behalf Of David Farmer
Sent: Monday, September 16, 2013 7:07 PM
To: William Herrin
Cc: arin-ppml at arin.net<mailto:arin-ppml at arin.net>
Subject: Re: [arin-ppml] Draft Policy ARIN-2013-6: Allocation of IPv4 andIPv6 Address Space to Out-of-region Requestors - Revised Problem Statementand Policy Text

On 9/15/13 13:18 , William Herrin wrote:
> On Sat, Sep 14, 2013 at 5:47 PM, Owen DeLong <owen at delong.com<mailto:owen at delong.com>> wrote:
>> On Sep 13, 2013, at 8:53 AM, William Herrin <bill at herrin.us<mailto: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.


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