[arin-ppml] support for 2014-1 (out of region use)

David Huberman David.Huberman at microsoft.com
Thu Feb 6 13:40:55 EST 2014

Thank you, Milton, for bringing this thread up.

I've reviewed 2014-1 and thought about it carefully.  I am against this proposal.  I'll try and organize my thoughts, though they come from a few different angles.

Text: https://www.arin.net/policy/proposals/2014_1.html

1) I'm against the specific 2014-1 language because I think it is almost entirely no-op.  

In general, I want NRPM to be brief, concise, and prescriptive.  "You qualify by doing X.  You don't qualify because of Y. You must show A, B, C."  We need less fluffy text in NRPM so that it is a more accessible and polished Policy document, imho.  In this case, only paragraph X.1 is operational.  It formally lays out just a few steps that ARIN already has available to it.  But these aren't the only tools ARIN has to verify request data, and I'm not convinced that having these specific bullet points in Policy helps the community or ARIN staff in any meaningful way.

Put more straight forwardly:  ARIN staff already have these mechanisms available to them, and this policy text will not change the request process materially.

2) The PPML community has reviewed similar proposals twice, in my recollection.   There was a draft limiting out-of-region use discussed in Philadelphia. The community vocally was against it, and clearly told ARIN staff to keep doing what they were already doing. There was also a draft limiting out-of-region use discussed in Phoenix.  The community was again vocally against it, and clearly told the ARIN staff that this isn't a policy area they wish to discuss.

3) At the same time, the staff are continuing to report that there are significant problems from out-of-region requestors abusing the policies.  If you disagree with the PPML community (and I do - I think this is a serious issue that cries for Policy changes), then we need to draft text that significantly and materially helps ARIN staff fight fraud from out-of-region requestors.  

With regards,

David R Huberman
Microsoft Corporation
Senior IT/OPS Program Manager (GFS)

From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On Behalf Of Milton L Mueller
Sent: Thursday, February 6, 2014 6:42 AM
To: ARIN PPML (ppml at arin.net)
Subject: [arin-ppml] support for 2014-1 (out of region use)

Draft policy 2014-1 attempts to solve a problem left over from last year. During 2013 there was a round of policy proposals attempting to tie ARIN allocations more closely to usage in the region. They failed to gain consensus because they would have interfered with trans-regional networks in undesirable ways. Yet, current policy is still ambiguous on the issue of out of region use of ARIN registered resources. This proposal attempts to clear up that ambiguity in a way that avoids harmful effects on transnational or trans-regional network operators. The gist of the idea is to allow out of region use for organizations eligible for ARIN resources, but also provide policy authorization for ARIN to charge fees to verify the identity or usage of applicants outside the region. I think this approach provides the most flexibility while addressing the only real problems that have been cited for out of region use (verification issues). 

You can see the proposal in full here: https://www.arin.net/policy/proposals/2014_1.html
Appreciate reading your comments about this.

Milton L Mueller
Professor, Syracuse University School of Information Studies
Internet Governance Project

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