[arin-ppml] Revised text for Draft Policy 2014-1 (Out of region use)

[Jason Schiller]

I oppose as written, but support the concept.
(I oppose this version more that the previous version)

I still have concerns about the hard limit of and IPv4 /20, IPv6 /36 or two
ASNs.

I think the point here is to ensure that organizations are not double
counting equipment to get resources from multiple RIRs for the same use,
nor squatting on underutilized IP space from another RIR which could be
used and instead getting additional IP space from ARIN.

There was some idea in the original policy that this additional burden
could be avoided if the out of region use was only "incidental", yielding
this /20 text.  I argued that a hard limit of a /20 is not a fair dividing
line for incidental.  Many small organizations will never need more that a
/20.  Such a large hard limit suggests that the need to prove no double
counting or no sitting on underutilized  resources from another RIR does
not apply to small sites.  Either make it a percentage of total such "When
a request for resources from ARIN is justified by need located within
another RIR's service region and is more than 5% of the total utilization,
the requesting organization will also report to ARIN the utilization status
of all resources of the same type held with any other RIR that are used or
are available for use within the requested service region."  Or simply
always require it.  If the organization does not have resources in other
RIRs, there is no burden.


The original proposal suggested that when ARIN validates an out of region
use, they must be able to validate the use to no less than an equivalent
standard as resources used within the ARIN region.  This is with respect to
ensuring the utilization is nor fraudulent, such as if the customer service
address is a verifiable address, if the company name is an actual company,
and so on.

This proposal seems to go further and suggest that any ARIN space and other
RIR space must be efficiently utilized by ARIN's definition of efficient
utilization.

"The report must demonstrate that all resources currently available for use
within the requested service region are efficiently utilized based on
applicable ARIN policy."

If all the RIRs passed a similar policy global networks would be forced to
follow the most strict polices of all the RIRs.  In some cases the
conflicting requirements could not be met.  We had this discussion with the
original proposal to prevent out of region use.  Furthermore is flies in
the face that regional communities have some regional autonomy to deal with
local differences.


I believe I could get on board with the following two changes:

1. If you drop the hard limit either making it a percentage of total use,
or always require reporting of usage of IP space held by other RIRs

2. change " The report must demonstrate that all resources currently
available for use within the requested service region are efficiently
utilized based on applicable ARIN policy." to some text about ARIN
validating out of region space no less than an equivalent standard.
possibly "All ARIN registered resources used outside the region must be
verified to no less than an equivalent standard as resources used within
the ARIN region."


___Jason



On Fri, Jul 25, 2014 at 9:01 AM, Sweeting, John <john.sweeting at twcable.com>
wrote:

>  Good morning PPML,
>
>  Please provide comments in support or opposition as the plan is to vote
> to move this to Recommended Draft Status for the Baltimore meeting.
>
>  Thanks,
> John
>
>
>   On 7/25/14, 2:29 AM, "Milton L Mueller" <mueller at syr.edu> wrote:
>
>    At the Chicago meeting there was support for this policy but also
> calls for simplifying and shortening it. This is the revised version.
>
> ----
>
> Draft Policy ARIN-2014-1
> Out of Region Use
>
> Date: 21 July 2014
>
> Problem statement:
>
> Current policy neither clearly forbids nor clearly permits out of region
> use of ARIN registered resources. This has created confusion and
> controversy within the ARIN community for some time. Earlier work on this
> issue has restricting out of region use in various ways. None of these
> proposals have gained consensus. The next logical option is to discuss a
> proposal that clearly permits out of region use. Permitting out of region
> use, however, poses issues that have to be addressed by policy and
> adjustments to operational practice. Out of region use must be clearly
> defined and any operational practices based on that definition must not be
> unnecessarily burdensome. Also, it is more difficult and costly for ARIN
> staff to independently verify the justification and utilization of
> resources that are used outside of the ARIN service region. There needs to
> be recognition of this difference in policy and associated operational
> practices.
>
> Policy statement:
>
> Create new Section X;
>
> X. Out of region use
>
> ARIN registered resources may be used outside the ARIN service region and
> such use is valid justification for new or additional resources. A resource
> is considered to be used outside the region if it exclusively serves a
> user, customer or technical infrastructure location outside the ARIN
> service region.
>
>
>
> The services and facilities used to justify the need for ARIN resources
> that will be used out of region should not also be used to justify resource
> requests from another RIR. When a request for resources from ARIN is
> justified by need located within another RIR's service region and is more
> than the equivalent of a /20 for IPv4, a /36 for IPv6, or two (2) ASNs, the
> requesting organization will also report to ARIN the utilization status of
> all resources of the same type held with any other RIR that are used or are
> available for use within the requested service region. The organization
> will also supply any additional supporting documentation requested by ARIN
> regarding the need for the reported resources.  The report must demonstrate
> that all resources currently available for use within the requested service
> region are efficiently utilized based on applicable ARIN policy.
>
>
>
>
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-- 
_______________________________________________________
Jason Schiller|NetOps|jschiller at google.com|571-266-0006
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