Jason

From: [email protected] [mailto:[email protected]] 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 
<[email protected]<mailto:[email protected]>> 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" 
<[email protected]<mailto:[email protected]>> 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|[email protected]<mailto:[email protected]>|571-266-0006

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