I actually pretty much agree with everything Mr. Herrin states in the below
email.

-Blake
On Dec 24, 2014 1:26 PM, "William Herrin" <[email protected]> wrote:

> On Wed, Dec 24, 2014 at 12:28 PM, John Curran <[email protected]> wrote:
> > On Dec 24, 2014, at 11:50 AM, William Herrin <[email protected]> wrote:
> >> I think this is bad policy which will encourage registry shopping by
> >> large multinational companies who really don't need yet another
> >> advantage over their smaller competitors. Worse than just making ARIN
> >> a flag-of-convenience registry to the world, it includes just enough
> >> in-region requirement to shut out small players. I reiterate my
> >> OPPOSITION to this draft policy.
> >
> >   Is there are any change to the draft policy which would address
> >   your concerns regarding it?  More specifically, if the community
> >   support for the policy ends up being strong due to a perception
> >   that it addresses an existing policy flaw, is there any change
> >   that would mitigate the harm to small players that you outline
> >   above?
>
> Hi John,
>
> I'm don't think there is such a change but there are a few things that
> jump out at me as being particularly offensive.
>
> 1. This issue is not a concern for ARIN number resources overall. Now
> and for the foreseeable future it frankly only matters for IPv4
> addresses. Crafting a one-size-fits-all policy here needlessly
> complicates the matter. No one here cares whether AS numbers or IPv6
> addresses are used out-region and burning one single staff minute
> analyzing the acceptability of such is a waste. Worse, crafting the
> policy to act reasonably with the other number resources corrupts its
> ability to deal correctly with the IPv4 situation.
>
> 2. I disagree with spinning it as an existing policy flaw. There's a
> ARIN -implementation- flaw here. Classically and consistent with the
> spirit of ICP2, the RIRs allow minor outregion use of addresses that's
> incidental to an in-region operation. And you know what? You haven't
> been the slightest bit shy about deciding that external documents like
> ICP2 and RFC2050 constrain ARIN activity in other matters like the /10
> for large scale NAT. I don't know how ARIN got itself twisted up where
> it couldn't find the limits of "minor" and "incidental" but trying to
> override that with rigid policy requirements is going to be
> problematic.
>
> 3. Registry shopping is a bad bad bad idea. It defeats and is directly
> contrary to the whole ICP2 spirit of LOCAL self-governance. As
> written, this policy doesn't discourage region shopping, it codifies
> it. RIPE policies gotcha down? No sweat, we'll buy a cage in Ashburn
> Equinix and use that as a jumping board to shop ARIN instead. As long
> as you're big enough to afford that cage and the servers inside, this
> policy removes all limits.
>
> 4. Limiting the registrants to folks making a notional use of IP
> addresses or a single AS number somewhere inside the ARIN region just
> makes it worse. There's already a fairness gulf between shops large
> enough to employ a dedicated number resource group and those who must
> rely on consultants and luck to find a path through the registries'
> arcane rules. The 1AS/22/44 rule poses no real obstacle to a
> multinational grabbing addresses where convenient but it sows even
> more challenge and confusion for a smaller shop.
>
> Regards,
> Bill Herrin
>
>
>
> --
> William Herrin ................ [email protected]  [email protected]
> Owner, Dirtside Systems ......... Web: <http://www.dirtside.com/>
> May I solve your unusual networking challenges?
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