Hi Milton and All,
I am concerned with the following:
"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."
I feel this should be changed to the following:
"ARIN reserves the right to request a listing of all the applicant's
number holdings in the region(s) of proposed use"
I don't believe that it is good policy to micromanage people. Either
you trust the RIR or you don't. if you are writing policy for the RIR
that to me indicates you trust the RIR.
If ARIN decides to pull a listing of applicant holdings, they are
going to have some suspicion there's fraud or other duplicate requests
going on. If the request is legit, then the requestor isn't going to
have a problem showing ARIN this listing. But if the request is
fraudulent, then the requestor is going to use every hook possible
to fight ARIN and your handing them a weapon with this "significant
reasons" thing. "Significant reasons" are not defined elsewhere in
the policy manual, and your just asking the requestor to threaten
to sue ARIN over a difference of interpretation of that statement.
If you feel this strongly about it please just say:
"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 duplicate requests are suspected."
I also think a /22 of IPv4 is too small a litmus test and a real
multi or trans-regional network is going to have more IP numbering
in play, but I recognize that this is a separate fight that needs to
be argued over during a different time.
Ted
On 10/21/2014 7:20 AM, Milton L Mueller 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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