[arin-ppml] Draft Policy ARIN-2015-6: Transfers and Multi-national Networks

[Scott Leibrand]

On Tue, Jun 23, 2015 at 3:36 PM, William Herrin <bill at herrin.us> wrote:

> On Tue, Jun 23, 2015 at 4:06 PM, ARIN <info at arin.net> wrote:
> > Draft Policy ARIN-2015-6
> > Transfers and Multi-national Networks
>
> OPPOSED.
>

Noted.  Can you read over my comments below, and then note why you think
it's a bad idea to ignore the geographic location where an organization is
utilizing its ARIN-registered addresses when evaluating transfer requests?
I'm hoping to hear the consequentialist argument behind your position,
independent of the appeal to authority (of the PDP) that you gave below.


> Policy violates PDP section 3.2. The policy requires ARIN to consider
> addresses used outside the region but the PDP restricts policy scope
> to "number resources managed within the ARIN region."
>

I believe that is the whole point: while these number resources may be
*used* outside the ARIN region, they are still *managed* within the ARIN
region (by a multinational network with meaningful business that operates
in the ARIN region, and is currently using IPv4 or IPv6 addresses in the
ARIN region).  So I don't see a conflict with the PDP here, just a
disagreement with the principle of allowing use of ARIN-issued and -managed
addresses outside the ARIN region.

Policy violates PDP section 4.1. The policy requires ARIN to provide
> favorable treatment to longstanding customers. PDP 4.1 requires "fair
> and impartial" administration.
>
> Policy violates PDP section 4.1. The policy requires ARIN to
> facilitate number usage in locations worldwide but refuses to serve
> would-be registrants in those locations unless they also have a major
> presence in the ARIN region. PDP 4.1 requires "fair and impartial"
> administration.
>

The PDP actually states that "Internet number resource policy must provide
for fair and impartial management of resources according to unambiguous
guidelines and criteria."  It doesn't mean "the rules must be the same for
everyone", but rather that there must be unambiguous rules, guidelines, and
criteria, that are applied to everyone according to the text of the
policies, not according to the whim of the resource analyst.

We can wait and see what the ARIN Staff and Legal analysis says on the
subject, but I'm pretty sure there isn't a conflict with the PDP here
either.

-Scott
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