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

Milton L Mueller mueller at syr.edu
Sun Jul 27 02:08:01 EDT 2014


From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On Behalf Of Jason Schiller
>I oppose as written, but support the concept.
>(I oppose this version more that the previous version)

That's odd, because the previous version had the same hard limits. It was simply defined as "incidental use" and created 3 categories of such use. In this respect, there is no substantive difference between the two versions. This one is just simpler.

> 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.

It does indeed mean that, and it also means that the time and effort required by ARIN staff to monitor such smaller sites may simply not be worth it.

If your point here is that this limit is "unfair" to large organizations you are going to have trouble finding much sympathy here. Larger organizations consume more resources and thus merit closer attention. Fixed reporting costs are, proportionately, a larger cost to small organizations than to larger ones. The fixed limits save ARIN from expending a lot of effort for very small potential gains, and save small orgs from burdensome requirements. For organizations with larger use of number resources, the stakes are higher in terms of resource consumptions and the potential unfairness of double counting, so the extra monitoring effort is worth it.

> Either make it a percentage of total such "When a request for resources

Earlier proposals by David already explained why percentages don't work. Percentages vary with the total amount of resources one has and thus one could fluctuate in and out of the limit as one grows. That doesn't make sense. Besides, the concept of "incidental use" implies more of an absolute limit than one relative to one's other holdings. "Incidentalness" is relative to ARIN pools, not the users' holdings.

>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.

That was not the intent - the intent was to ensure that only ARIN resources are efficiently utilized by ARIN's standards.

>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

I would not be willing to do that, for reasons stated above.

> 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."

This sounds OK to me, and I suspect David would not have a problem with it but let him speak for himself.

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


On 7/25/14, 2:29 AM, "Milton L Mueller" <mueller at syr.edu<mailto: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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