[arin-ppml] Recommended Draft Policy ARIN-2014-1: Out of Region Use

William Herrin bill at herrin.us
Wed Dec 24 14:26:00 EST 2014

On Wed, Dec 24, 2014 at 12:28 PM, John Curran <jcurran at arin.net> wrote:
> On Dec 24, 2014, at 11:50 AM, William Herrin <bill at herrin.us> wrote:
>> I think this is bad policy which will encourage registry shopping by
>> large multinational companies who really don't need yet another
>> advantage over their smaller competitors. Worse than just making ARIN
>> a flag-of-convenience registry to the world, it includes just enough
>> in-region requirement to shut out small players. I reiterate my
>> OPPOSITION to this draft policy.
>   Is there are any change to the draft policy which would address
>   your concerns regarding it?  More specifically, if the community
>   support for the policy ends up being strong due to a perception
>   that it addresses an existing policy flaw, is there any change
>   that would mitigate the harm to small players that you outline
>   above?

Hi John,

I'm don't think there is such a change but there are a few things that
jump out at me as being particularly offensive.

1. This issue is not a concern for ARIN number resources overall. Now
and for the foreseeable future it frankly only matters for IPv4
addresses. Crafting a one-size-fits-all policy here needlessly
complicates the matter. No one here cares whether AS numbers or IPv6
addresses are used out-region and burning one single staff minute
analyzing the acceptability of such is a waste. Worse, crafting the
policy to act reasonably with the other number resources corrupts its
ability to deal correctly with the IPv4 situation.

2. I disagree with spinning it as an existing policy flaw. There's a
ARIN -implementation- flaw here. Classically and consistent with the
spirit of ICP2, the RIRs allow minor outregion use of addresses that's
incidental to an in-region operation. And you know what? You haven't
been the slightest bit shy about deciding that external documents like
ICP2 and RFC2050 constrain ARIN activity in other matters like the /10
for large scale NAT. I don't know how ARIN got itself twisted up where
it couldn't find the limits of "minor" and "incidental" but trying to
override that with rigid policy requirements is going to be

3. Registry shopping is a bad bad bad idea. It defeats and is directly
contrary to the whole ICP2 spirit of LOCAL self-governance. As
written, this policy doesn't discourage region shopping, it codifies
it. RIPE policies gotcha down? No sweat, we'll buy a cage in Ashburn
Equinix and use that as a jumping board to shop ARIN instead. As long
as you're big enough to afford that cage and the servers inside, this
policy removes all limits.

4. Limiting the registrants to folks making a notional use of IP
addresses or a single AS number somewhere inside the ARIN region just
makes it worse. There's already a fairness gulf between shops large
enough to employ a dedicated number resource group and those who must
rely on consultants and luck to find a path through the registries'
arcane rules. The 1AS/22/44 rule poses no real obstacle to a
multinational grabbing addresses where convenient but it sows even
more challenge and confusion for a smaller shop.

Bill Herrin

William Herrin ................ herrin at dirtside.com  bill at herrin.us
Owner, Dirtside Systems ......... Web: <http://www.dirtside.com/>
May I solve your unusual networking challenges?

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