I will reiterate my comment that /44 is too stringent and /48 should be used 
instead.

Owen

On Oct 21, 2014, at 7:20 AM, Milton L Mueller <[email protected]> wrote:

> 
> Based on feedback from NANOG, our Baltimore general meeting, and the AC 
> meeting and list I have revised 2014-1 for what I hope is the last time. I 
> have updated the Wiki and am requesting staff and legal review. 
> 
> I believe the proposal is technically sound, enables fair and impartial 
> resource allocation and has widespread community support .
> 
> Full amended text below. Note that I have also amended the problem statement 
> to reflect the revisions. The earlier text about defining out of region use, 
> engagement of external entities, etc is no longer needed and thus is gone. 
> The comments section is also modified to reflect the overall simplification. 
> 
> Milton L. Mueller
> Laura J. and L. Douglas Meredith Professor Syracuse University School of 
> Information Studies http://faculty.ischool.syr.edu/mueller/mueller/Home.html 
> 
> ===
> 
> Draft Policy ARIN-2014-1 Out of Region Use
> 
> Date: 21 October 2014
> 
> Problem statement:
> Current policy neither clearly forbids nor clearly permits out or 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 
> explored several options to restrict or otherwise limit out of region use. 
> None of these options have gained consensus within the community. The next 
> logical option is a proposal that clearly permits out of region use while 
> addressing some of the concerns expressed about unlimited openness to out of 
> region use.
> 
> Policy statement:
> 
> Create new Section X:
> 
> ARIN registered resources may be used outside the ARIN service region. Out of 
> region use of IPv4, IPv6, or ASNs are valid justification for additional 
> number resources if the applicant is an ARIN member in good standing and is 
> currently using at least the equivalent of a /22 of IPv4, or a /44 of IPv6, 
> or 1 ASN within the ARIN service region, respectively.
> 
> The services and facilities used to justify the need for ARIN resources that 
> will be used out of region cannot 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, an officer of the applicant must 
> attest that the same services and facilities have not been used as the basis 
> for a resource request in the other region(s). ARIN reserves the right to 
> request a listing of all the applicant's number holdings in the region(s) of 
> proposed use, but this should happen only when there are significant reasons 
> to suspect duplicate requests.
> 
> Comments:
> a. Timetable for implementation: Immediate b. Anything else Current policy is 
> ambiguous on the issue of out of region use of ARIN registered resources. The 
> only guidance on the issue in current policy is Section 2.2, which defines 
> the the role of RIRs as "to manage and distribute public Internet address 
> space within their respective regions." Some in the community believe this 
> means out of region use should be prevented or restricted, while others 
> believe this is only intended to focus efforts within the region and not 
> define where resources may be used.
> Previous policy proposals have explored restricting or otherwise limiting out 
> of region use, but none have gained consensus within the ARIN community. 
> Several standards for restricting out of region use were explored, but all of 
> them were perceived as interfering with the legitimate operations of multi- 
> or trans-regional networks.
> The requirement to have a minimal level of resources deployed in the region 
> (/44 for IPv6, /22 for IPv4, 1 ASN) is an attempt to respond to law 
> enforcement and some community concerns. An absolute threshold ensures that 
> those applying for ARIN resources are actually operating in the region and 
> not simply a shell company, but it avoids the known pitfalls of trying to use 
> percentages of the organization's overall holdings to do that. The use of 
> officer attestation and the possibility of an audit is an attempt to prevent 
> duplicate requests without requiring burdensome reporting requirements.
> In summary, this proposal ensures that trans-regional organizations or 
> service providers operating within the ARIN region may receive all the 
> resources they need from ARIN if they wish to do so. This change is 
> particularly important for IPv6. Requiring organizations get IPv6 resources 
> from multiple RIRs will result in additional unique non-aggregatable prefixes 
> within the IPv6 route table.
> 
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