[arin-ppml] Draft Policy ARIN-2013-6: Allocation of IPv4 and IPv6 Address Space to Out-of-region Requestors - Revised

John Santos JOHN at egh.com
Wed Sep 25 18:27:08 EDT 2013

On Wed, 25 Sep 2013, William Herrin wrote:

> On Wed, Sep 25, 2013 at 10:59 AM, ARIN <info at arin.net> wrote:

> >, and (2) are operating a
> > network located within the ARIN service region. In addition to meeting
> > all other applicable policy requirements, a plurality of new resources
> "Plurality" is a non-starter for me. You really want to do this, pick a
> percent. 
> The reasons have all been stated before, both in the previous
> discussion, the staff comments and the legal assessment. In context,
> plurality is a sloppy, hard to pin down concept that makes management
> and analysis needlessly hard.

Huh?  "Plurality" is a precisely defined mathematical concept.

The part I have a problem with is "a network located within the ARIN
service region."

Networks intrinsically span service regions.  Nodes can be scattered
across RIR regions, links between nodes can (and often do) cross regional
boundaries, and what's worse, nodes can move, both day-to-day (for
example, an international corporation moves its "www.support.foocorp.com"
web servers from a data center in Michigan to one in Luxembourg), and
totally dynamically, as in load-balancing and site failover, as well as
mobile nodes that can cross RIR boundaries at will.  In which region is a
Liberian-registered cruise ship sailing out of San Diego currently exploring
the coast of Patagonia?  Or an airplane or the ISS? 

There needs to be a degree of fuzziness.  If we are going to force a
regional preponderance of the network (a much vaguer term than
"plurality"), to be in ARIN's geographical region, then (1) clearly a
network with 30% ARIN, 70% RIPE should be getting its resources from RIPE,
but (2) one with 29% ARIN, 28% RIPE, 25% APNIC, and the other 17% spread
across Africa and Latin America should get their resources from ARIN,
despite having a smaller footprint than the 1st organization.  And what of
(3), which has 28.99% ARIN, 29.01% RIPE right now, but it could change in
the next 15 minutes?  Maybe "within 5% of a plurality in the ARIN region"
would be a better metric. 

I think right now, an organization can basically deal with the registry it
finds most convenient, whether for geography, language, culture or
whatever. The proposal doesn't seem to be about registry shopping (my
local RIR rejected my request or has too many restrictions on my trying to
commoditize or speculateon the resources, so I'm going take a dip from
another well), or double-dipping or playing registries off against each
other.  Its goal seems to be accountability of the registrants, so I think
thats what it should try to do directly.  It shouldn't matter *where* an
organization is based, it should matter whether it is contactable,
receives and pays its bills, handles abuse complaints and technical
issues, etc.  If these are true, local law enforcement should have no
problem tracking them down if needed. 

John Santos
Evans Griffiths & Hart, Inc.
781-861-0670 ext 539

More information about the ARIN-PPML mailing list