Re: [arin-ppml] Draft Policy ARIN-2015-5: Out of region use - revised

[ARIN]

ARIN-2015-5 has been revised.

ARIN staff provided a staff and legal assessment to the ARIN Advisory 
Council (AC) on 18 August. The AC revised the policy text, staff revised 
their assessment, and then the AC made some editorial changes to the 
policy text (which were suggested by staff).


You are encouraged to discuss the merits and your concerns of Draft
Policy 2015-5 on the Public Policy Mailing List.

The AC will evaluate the discussion in order to assess the conformance
of this draft policy with ARIN's Principles of Internet Number Resource
Policy as stated in the PDP. Specifically, these principles are:

   * Enabling Fair and Impartial Number Resource Administration
   * Technically Sound
   * Supported by the Community

ARIN-2015-5 is below and can be found at:
https://www.arin.net/policy/proposals/2015_5.html

Regards,

Communications and Member Services
American Registry for Internet Numbers (ARIN)


## * ##


Draft Policy ARIN-2015-5
Out of region use

Date: 17 September 2015

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 explored several options to restrict or otherwise limit 
out of region use or loosen controls and totally authorize such 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 the key concerns expressed about unlimited openness to 
out of region use and enables ARIN staff to implement the policy 
efficiently.


Policy statement:

Create new Section X:

ARIN registered resources may be used outside the ARIN service region. 
Out of region use of ARIN registered resources are valid justification 
for additional number resources, provided that the applicant has a real 
and substantial connection with the ARIN region which applicant must 
prove (as described below) and is using the same type of resources (with 
a delegation lineage back to an ARIN allocation or assignment) within 
the ARIN service region as follows:


* IPv4: At least a /22 used in region
* IPv6: At least a /44 used in region
* ASN: At least one ASN present on one or more peering sessions and/or 
routers within the region.


A real and substantial connection shall be defined as carrying on 
business in the ARIN region in a meaningful manner.  The determination 
as to whether an entity is carrying on business in the ARIN region in a 
meaningful manner shall be made by ARIN. Simply being incorporated in 
the ARIN region shall not be sufficient, on its own, to prove that an 
entity is carrying on business in the ARIN region in a meaningful 
manner. Methods that entities may consider using, including 
cumulatively, to prove that they are carrying on business in the ARIN 
region in a meaningful manner include:
* Demonstrating a physical presence in the ARIN region through a bricks 
and mortar location that is actually used for the purposes of conducting 
business in the ARIN region in a meaningful manner. That is to say, the 
location is not merely a registered office that serves no other business 
purpose.
* Demonstrating that the entity has staff in the ARIN region. The 
greater the number of staff, the stronger this connecting factor is.
* Demonstrating that the entity holds assets in the ARIN region. The 
greater the asset value, the stronger this connecting factor is.
* Demonstrating that the entity provides services to and solicits sales 
from residents of the ARIN region.

* Demonstrating that the entity holds periodic meetings in the ARIN region.
* Demonstrating that the entity raises investment capital from investors 
in the ARIN region.
* Demonstrating that the entity has a registered corporation in the ARIN 
region, although this factor on its own shall not be sufficient.
* Other fact based criterion that the entity considers appropriate and 
submits for ARIN's review.
The weight accorded to any of the above-noted factors, if any, shall be 
determined solely by ARIN.


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 application 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 obtain from the applicant a 
listing of all the applicant's number holdings in the region(s) of 
proposed use, when there are factual reasons to support the request.


Comments:

a) Timetable for implementation: Various iterations of this policy have 
been presented and debated by ARIN for well over a year now. Given the 
amount of time that has already been spent on 

Re: [arin-ppml] Draft Policy ARIN-2015-5: Out of region use - revised

[Martin Hannigan]

On Fri, Sep 11, 2015 at 10:12 PM, John Curran  wrote:

> On Sep 11, 2015, at 9:47 PM, Martin Hannigan  wrote:
>
> John,
>
> I believe its a norm to expect paid staff to be neutral with respect to
> all proposals as many consensus bodies  do. ICANN would be a good
> reference. Feel free to object.
>
>
> Martin -
>
> If you are implying that my statement (to the effect that Owen’s
> description of ARIN’s
> current policy implementation in this area is correct) is somehow
> advocating a position
> in favor or opposed to the draft policy under consideration, I’d suggest
> that you read it
> again.
>
> Thanks!
> /John
>
> John Curran
> President and CEO
> ARIN
>


Hi John,

I've read your response, thanks for the suggestion.

Back to the proposal.

One point that's missed in the conversation is that we've rejected the
inverse of this proposal, restricting out of region use, multiple times.
This is exactly the same attempt with nothing more than confusing language.
The "allow" is actually a set up to "deny", just like the previous
attempts. "Flipping the script" into "allow" doesn't change anything.
Instead, it creates unnecessary encumbrances to commerce which doesn't hurt
any bad actors, it hurts us. Almost every requirement that the proposal
makes is easily achieved by the staff using public resources. If the staff
suspects that there is an issue with an applicant, ARIN _should_ use our
money to flush it out. No policy proposal is needed for ARIN to validate
who is a member or who is using our numbers. These are administrative
issues that we should not be concerned with.

I have never had any of the issues that the "proposal" seeks to resolve in
justifying almost a /8 for global use including assigning numbers from ARIN
to infrastructure in other regions. I expect that without this proposal I
will continue to have no problem. If this proposal does get adopted as
policy, I will still have no problem. I can assure you though, that small
network operators will have a big problem.

Best,

-M<
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Re: [arin-ppml] Draft Policy ARIN-2015-5: Out of region use - revised

[Owen DeLong]

For those that are wondering if this is a real problem…

I quote from a recent ARIN response to a resource transfer preapproval request:

 In accordance with section 2.2 of the NRPM, ARIN issues number resources for 
use within its region. Please confirm the requested number resources will be 
routed within the ARIN region. 

If one takes this language literally, then the scenario where you have servers 
in USVI that you are addressing, but your anchor routes are held in upstream 
routers in Brazil and Uruguay would actually potentially preclude you from 
getting addresses from ARIN.

This policy is, in fact, necessary to constrain ARIN staff and provide a clear 
mechanism by which ARIN region entities can obtain addresses through ARIN for 
their network, regardless of how far the footprint of their network extends.

We all know that geography != topology. Further, the arbitrary lines drawn on a 
map with passport control stations sprinkled on either side mean very little to 
bits flowing through fiber. There are no border guards on the fiber networks, 
or if there are, they are generally not national border guards anyway.

As such, unless you believe this policy causes actual harm, I urge you to 
support it.

Owen

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Re: [arin-ppml] Draft Policy ARIN-2015-5: Out of region use - revised

[John Curran]

On Sep 11, 2015, at 9:47 PM, Martin Hannigan 
> wrote:
John,

I believe its a norm to expect paid staff to be neutral with respect to all 
proposals as many consensus bodies  do. ICANN would be a good reference. Feel 
free to object.

Martin -

If you are implying that my statement (to the effect that Owen’s description of 
ARIN’s
current policy implementation in this area is correct) is somehow advocating a 
position
in favor or opposed to the draft policy under consideration, I’d suggest that 
you read it
again.

Thanks!
/John

John Curran
President and CEO
ARIN

While I have no view on the relative merits of the referenced draft policy, I 
believe your
description of ARIN’s present policy implementation in this area is essentially 
correct
(and aligns with what was communicated in the ARIN 31 Policy Experience Report  
-
https://www.arin.net/participate/meetings/reports/ARIN_31/PDF/monday/nobile_policy.pdf)



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Re: [arin-ppml] Draft Policy ARIN-2015-5: Out of region use - revised

[Martin Hannigan]

John, 

I believe its a norm to expect paid staff to be neutral with respect to all 
proposals as many consensus bodies  do. ICANN would be a good reference. Feel 
free to object. 

Best,

-M<



> On Sep 11, 2015, at 20:26, John Curran  wrote:
> 
>> On Sep 11, 2015, at 6:33 PM, Owen DeLong  wrote:
>> 
>> For those that are wondering if this is a real problem…
>> 
>> I quote from a recent ARIN response to a resource transfer preapproval 
>> request:
>> 
>>  In accordance with section 2.2 of the NRPM, ARIN issues number resources 
>> for use within its region. Please confirm the requested number resources 
>> will be routed within the ARIN region. 
>> 
>> If one takes this language literally, then the scenario where you have 
>> servers in USVI that you are addressing, but your anchor routes are held in 
>> upstream routers in Brazil and Uruguay would actually potentially preclude 
>> you from getting addresses from ARIN.
>> 
>> This policy is, in fact, necessary to constrain ARIN staff and provide a 
>> clear mechanism by which ARIN region entities can obtain addresses through 
>> ARIN for their network, regardless of how far the footprint of their network 
>> extends.
>> 
>> We all know that geography != topology. Further, the arbitrary lines drawn 
>> on a map with passport control stations sprinkled on either side mean very 
>> little to bits flowing through fiber. There are no border guards on the 
>> fiber networks, or if there are, they are generally not national border 
>> guards anyway.
>> 
>> As such, unless you believe this policy causes actual harm, I urge you to 
>> support it.
> 
> Owen - 
> 
> While I have no view on the relative merits of the referenced draft policy, I 
> believe your
> description of ARIN’s present policy implementation in this area is 
> essentially correct
> (and aligns with what was communicated in the ARIN 31 Policy Experience 
> Report  - 
> https://www.arin.net/participate/meetings/reports/ARIN_31/PDF/monday/nobile_policy.pdf)
> 
> Thanks!
> /John
> 
> John Curran
> President and CEO
> ARIN
> 
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Re: [arin-ppml] Draft Policy ARIN-2015-5: Out of region use - revised

[Martin Hannigan]

I use my addresses globally and will continue to do so as needed.  I've
never needed a policy to tell me I can or can't.

Why can't ARIN just confirm that they're a business and be done with it?
Isn't this what we pay them for?

GOTO 10

Not in favor.

Best,

-M<





On Wed, Sep 9, 2015 at 9:38 AM, ARIN  wrote:

> ARIN-2015-5 has been revised.
>
> You are encouraged to discuss the merits and your concerns of Draft
> Policy 2015-5 on the Public Policy Mailing List.
>
> The AC will evaluate the discussion in order to assess the conformance
> of this draft policy with ARIN's Principles of Internet Number Resource
> Policy as stated in the PDP. Specifically, these principles are:
>
>* Enabling Fair and Impartial Number Resource Administration
>* Technically Sound
>* Supported by the Community
>
> ARIN-2015-5 is below and can be found at:
> https://www.arin.net/policy/proposals/2015_5.html
>
> Regards,
>
> Communications and Member Services
> American Registry for Internet Numbers (ARIN)
>
>
> ## * ##
>
>
> Draft Policy ARIN-2015-5
> Out of region use
>
> Date: 9 September 2015
>
> 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 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 the key concerns expressed about unlimited
> openness to out of region use and enables ARIN staff to implement the
> policy efficiently.
>
> Policy statement:
>
> Create new Section X: ARIN registered resources may be used outside the
> ARIN service region.
>
> Out of region use of ARIN registered resources are valid justification for
> additional number resources, provided that the applicant has a real and
> substantial connection with the ARIN region which applicant must prove (as
> described below) and is using the same type of resources (with a delegation
> lineage back to an ARIN allocation or assignment) within the ARIN service
> region as follows:
>
> * IPv4: At least a /22 used in region
> * IPv6: At least a /44 used in region
> * ASN: At least one ASN present on one or more peering sessions and/or
> routers within the region.
>
> A real and substantial connection shall be defined as carrying on business
> in the ARIN region in a meaningful manner, whether for or not for profit.
> The determination as to whether an entity is carrying on business in the
> ARIN region in a meaningful manner shall be made by ARIN. Simply being
> incorporated in the ARIN region shall not be sufficient, on its own, to
> prove that an entity is carrying on business in the ARIN region in a
> meaningful manner. Methods that entities may consider using, including
> cumulatively, to prove that they are carrying on business in the ARIN
> region in a meaningful manner include:
> * Demonstrating a physical presence in the ARIN region through a bricks
> and mortar location that is actually used for the purposes of conducting
> business in the ARIN region in a meaningful manner. That is to say, the
> location is not merely a registered office that serves no other business
> purpose.
> * Demonstrating that the entity has staff in the ARIN region. The greater
> the number of staff, the stronger this connecting factor is.
> * Demonstrating that the entity holds assets in the ARIN region. The
> greater the asset value, the stronger this connecting factor is.
> * Demonstrating that the entity provides services to or solicits sales
> from residents of the ARIN region.
> * Demonstrating that the entity holds annual meetings in the ARIN region.
> * Demonstrating that the entity raises investment capital from investors
> in the ARIN region.
> * Demonstrating that the entity has a registered office in the ARIN
> region, although this factor on its own shall not be sufficient.
> * Any other method that the entity considers appropriate.
> The weight accorded to any of the above-noted factors, if any, shall be
> determined solely by ARIN.
>
> 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 application 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: Various 

Re: [arin-ppml] Draft Policy ARIN-2015-5: Out of region use - revised

[Matthew Kaufman]

On 9/10/2015 2:40 PM, Martin Hannigan wrote:


I use my addresses globally and will continue to do so as needed.  
I've never needed a policy to tell me I can or can't.


+1

As I've said before, isn't the whole point of the Internet that 
geography can become largely irrelevant. Like I can take a disaster hit 
in California and spin up the standby VMs that are in London, adjust a 
little BGP, and keep rolling... why would where I happen to be using a 
particular address today be ARIN's business at all?


Matthew Kaufman

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Re: [arin-ppml] Draft Policy ARIN-2015-5: Out of region use - revised

[Scott Leibrand]

On Thu, Sep 10, 2015 at 2:40 PM, Martin Hannigan  wrote:

>
> I use my addresses globally and will continue to do so as needed.  I've
> never needed a policy to tell me I can or can't.
>
> Why can't ARIN just confirm that they're a business and be done with it?
> Isn't this what we pay them for?
>

ARIN staff has indicated that a policy like this one is required for them
to stop interpreting ICP-2 as requiring in-region use of addresses.  In
other words, you may not have needed a policy to use your addresses
globally, but ARIN has indicated they do need a policy for others to do so.


> GOTO 10
>
> Not in favor.
>

Do you have any arguments against the proposal?  "I've never needed a
policy to tell me I can use my addresses globally" doesn't seem sufficient
to me as reason to oppose it, particularly since others have not been able
to do so.

-Scott


> On Wed, Sep 9, 2015 at 9:38 AM, ARIN  wrote:
>
>> ARIN-2015-5 has been revised.
>>
>> You are encouraged to discuss the merits and your concerns of Draft
>> Policy 2015-5 on the Public Policy Mailing List.
>>
>> The AC will evaluate the discussion in order to assess the conformance
>> of this draft policy with ARIN's Principles of Internet Number Resource
>> Policy as stated in the PDP. Specifically, these principles are:
>>
>>* Enabling Fair and Impartial Number Resource Administration
>>* Technically Sound
>>* Supported by the Community
>>
>> ARIN-2015-5 is below and can be found at:
>> https://www.arin.net/policy/proposals/2015_5.html
>>
>> Regards,
>>
>> Communications and Member Services
>> American Registry for Internet Numbers (ARIN)
>>
>>
>> ## * ##
>>
>>
>> Draft Policy ARIN-2015-5
>> Out of region use
>>
>> Date: 9 September 2015
>>
>> 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 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 the key concerns expressed about unlimited
>> openness to out of region use and enables ARIN staff to implement the
>> policy efficiently.
>>
>> Policy statement:
>>
>> Create new Section X: ARIN registered resources may be used outside the
>> ARIN service region.
>>
>> Out of region use of ARIN registered resources are valid justification
>> for additional number resources, provided that the applicant has a real and
>> substantial connection with the ARIN region which applicant must prove (as
>> described below) and is using the same type of resources (with a delegation
>> lineage back to an ARIN allocation or assignment) within the ARIN service
>> region as follows:
>>
>> * IPv4: At least a /22 used in region
>> * IPv6: At least a /44 used in region
>> * ASN: At least one ASN present on one or more peering sessions and/or
>> routers within the region.
>>
>> A real and substantial connection shall be defined as carrying on
>> business in the ARIN region in a meaningful manner, whether for or not for
>> profit. The determination as to whether an entity is carrying on business
>> in the ARIN region in a meaningful manner shall be made by ARIN. Simply
>> being incorporated in the ARIN region shall not be sufficient, on its own,
>> to prove that an entity is carrying on business in the ARIN region in a
>> meaningful manner. Methods that entities may consider using, including
>> cumulatively, to prove that they are carrying on business in the ARIN
>> region in a meaningful manner include:
>> * Demonstrating a physical presence in the ARIN region through a bricks
>> and mortar location that is actually used for the purposes of conducting
>> business in the ARIN region in a meaningful manner. That is to say, the
>> location is not merely a registered office that serves no other business
>> purpose.
>> * Demonstrating that the entity has staff in the ARIN region. The greater
>> the number of staff, the stronger this connecting factor is.
>> * Demonstrating that the entity holds assets in the ARIN region. The
>> greater the asset value, the stronger this connecting factor is.
>> * Demonstrating that the entity provides services to or solicits sales
>> from residents of the ARIN region.
>> * Demonstrating that the entity holds annual meetings in the ARIN region.
>> * Demonstrating that the entity raises investment capital from investors
>> in the ARIN region.
>> * Demonstrating that the entity has a registered office in the ARIN
>> region, although this factor on its own shall not be sufficient.
>> * Any other method that the entity considers appropriate.
>> The weight accorded to any of the above-noted factors, if any, shall be
>> determined solely by ARIN.
>>
>> The services and 

Re: [arin-ppml] Draft Policy ARIN-2015-5: Out of region use - revised

[William Herrin]

On Wed, Sep 9, 2015 at 9:38 AM, ARIN  wrote:
> Draft Policy ARIN-2015-5
> Out of region use

I remain OPPOSED to this is well. If you guys really feel a need to
work in this space, start on a globally coordinated proposal which
facilitates all of the registries acting globally with common rules,
not just ARIN.

Regards,
Bill Herrin


-- 
William Herrin  her...@dirtside.com  b...@herrin.us
Owner, Dirtside Systems . Web: 
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[arin-ppml] Draft Policy ARIN-2015-5: Out of region use - revised

[ARIN]

ARIN-2015-5 has been revised.

You are encouraged to discuss the merits and your concerns of Draft
Policy 2015-5 on the Public Policy Mailing List.

The AC will evaluate the discussion in order to assess the conformance
of this draft policy with ARIN's Principles of Internet Number Resource
Policy as stated in the PDP. Specifically, these principles are:

   * Enabling Fair and Impartial Number Resource Administration
   * Technically Sound
   * Supported by the Community

ARIN-2015-5 is below and can be found at:
https://www.arin.net/policy/proposals/2015_5.html

Regards,

Communications and Member Services
American Registry for Internet Numbers (ARIN)


## * ##


Draft Policy ARIN-2015-5
Out of region use

Date: 9 September 2015

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 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 the key concerns expressed 
about unlimited openness to out of region use and enables ARIN staff to 
implement the policy efficiently.


Policy statement:

Create new Section X: ARIN registered resources may be used outside the 
ARIN service region.


Out of region use of ARIN registered resources are valid justification 
for additional number resources, provided that the applicant has a real 
and substantial connection with the ARIN region which applicant must 
prove (as described below) and is using the same type of resources (with 
a delegation lineage back to an ARIN allocation or assignment) within 
the ARIN service region as follows:


* IPv4: At least a /22 used in region
* IPv6: At least a /44 used in region
* ASN: At least one ASN present on one or more peering sessions and/or 
routers within the region.


A real and substantial connection shall be defined as carrying on 
business in the ARIN region in a meaningful manner, whether for or not 
for profit. The determination as to whether an entity is carrying on 
business in the ARIN region in a meaningful manner shall be made by 
ARIN. Simply being incorporated in the ARIN region shall not be 
sufficient, on its own, to prove that an entity is carrying on business 
in the ARIN region in a meaningful manner. Methods that entities may 
consider using, including cumulatively, to prove that they are carrying 
on business in the ARIN region in a meaningful manner include:
* Demonstrating a physical presence in the ARIN region through a bricks 
and mortar location that is actually used for the purposes of conducting 
business in the ARIN region in a meaningful manner. That is to say, the 
location is not merely a registered office that serves no other business 
purpose.
* Demonstrating that the entity has staff in the ARIN region. The 
greater the number of staff, the stronger this connecting factor is.
* Demonstrating that the entity holds assets in the ARIN region. The 
greater the asset value, the stronger this connecting factor is.
* Demonstrating that the entity provides services to or solicits sales 
from residents of the ARIN region.

* Demonstrating that the entity holds annual meetings in the ARIN region.
* Demonstrating that the entity raises investment capital from investors 
in the ARIN region.
* Demonstrating that the entity has a registered office in the ARIN 
region, although this factor on its own shall not be sufficient.

* Any other method that the entity considers appropriate.
The weight accorded to any of the above-noted factors, if any, shall be 
determined solely by ARIN.


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 application 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: Various iterations of this policy have 
been presented and debated by ARIN for well over a year now. Given the 
amount of time that has already been spent on developing a policy, 
ideally, this policy would be implemented as soon as possible.
b) Explanation of draft policy: The draft policy addresses both the 
problem statement as well as the concerns raised at ARIN 35 by 
participants as well as ARIN counsel.
Firstly, the draft policy addresses the concerns of ARIN 

Re: [arin-ppml] Draft Policy ARIN-2015-5: Out of region use

[Milton L Mueller]

From: John Curran [mailto:jcur...@arin.net]

ICP-2 is likely long overdue for a refresh at this point, and if there were a 
group of brave souls
who wished to take that on (in conjunction with the ASO AC), we might be able 
to achieve a
framework more suitable for the years that lie ahead...

MM: Amen to that.  I am a brave soul but the combination of IANA transition and 
move to a new institution are holding me back from taking the lead at this 
time. Other brave souls welcome…

--MM
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Re: [arin-ppml] Draft Policy ARIN-2015-5: Out of region use

[John Curran]

On Jul 6, 2015, at 12:41 PM, William Herrin 
b...@herrin.usmailto:b...@herrin.us wrote:

On Mon, Jul 6, 2015 at 12:08 PM, Milton L Mueller 
muel...@syr.edumailto:muel...@syr.edu wrote:
start from the perspective that
it is simply to clarify that the resources are for global use, and ARIN's role 
is
simply to be a facilitator within a reasonably local time-zone, and having
local language support. Any language that implies that there is a limitation
to use needs to be removed, or an explanation as to why that restriction is
any different than nationally aligned allocations needs to be added.

That kind of language/approach is how I intended to follow up on the failure of 
the old Out of Region Use proposal.
Such a proposal should probably be conceived as a global policy rather than an 
ARIN policy, however.

Yes, a global policy. No single region alone has the right. And a very
carefully conceived policy at that, lest the subregistries in each
region subvert it in various anticompetitive ways.

Bill -

In general, the Internet numbers community has used the term “global policy” to 
refer to policy
that is used by IANA in administration of the global unicast number resource 
free pools, and
has used the term “globally coordinated policy” to refer to policy that was 
developed with the
intent of global scope, but is ultimately adopted by each RIR community for use 
during the
administration of their respective regional Internet number registry.

In this case, it may not matter which term you use, as the policy that you seek 
to establish may
be more fundamental  in nature, i.e. related to requirements presently embedded 
within ICANN
Internet Coordination Policy 2 (ICP-2) 
https://www.icann.org/resources/pages/new-rirs-criteria-2012-02-25-en
ICP-2 is likely long overdue for a refresh at this point, and if there were a 
group of brave souls
who wished to take that on (in conjunction with the ASO AC), we might be able 
to achieve a
framework more suitable for the years that lie ahead...

Thanks!
/John

John Curran
President and CEO
ARIN

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Re: [arin-ppml] Draft Policy ARIN-2015-5: Out of region use

[William Herrin]

On Mon, Jul 6, 2015 at 12:08 PM, Milton L Mueller muel...@syr.edu wrote:
 start from the perspective that
 it is simply to clarify that the resources are for global use, and ARIN's 
 role is
 simply to be a facilitator within a reasonably local time-zone, and having
 local language support. Any language that implies that there is a limitation
 to use needs to be removed, or an explanation as to why that restriction is
 any different than nationally aligned allocations needs to be added.

 That kind of language/approach is how I intended to follow up on the failure 
 of the old Out of Region Use proposal.
 Such a proposal should probably be conceived as a global policy rather than 
 an ARIN policy, however.

Yes, a global policy. No single region alone has the right. And a very
carefully conceived policy at that, lest the subregistries in each
region subvert it in various anticompetitive ways.

Regards,
Bill Herrin


-- 
William Herrin  her...@dirtside.com  b...@herrin.us
Owner, Dirtside Systems . Web: http://www.dirtside.com/
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Re: [arin-ppml] Draft Policy ARIN-2015-5: Out of region use

[Milton L Mueller]

 start from the perspective that
 it is simply to clarify that the resources are for global use, and ARIN's 
 role is
 simply to be a facilitator within a reasonably local time-zone, and having
 local language support. Any language that implies that there is a limitation
 to use needs to be removed, or an explanation as to why that restriction is
 any different than nationally aligned allocations needs to be added.

Tony:
That kind of language/approach is how I intended to follow up on the failure of 
the old Out of Region Use proposal.
Such a proposal should probably be conceived as a global policy rather than an 
ARIN policy, however. 
Unfortunately due to a number of things I haven't had time to develop it. If 
you'd like to put one together I'd welcome it. 

--MM
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Re: [arin-ppml] Draft Policy ARIN-2015-5: Out of region use

[John Curran]

On Jul 3, 2015, at 6:23 PM, Matthew Kaufman 
matt...@matthew.atmailto:matt...@matthew.at wrote:

If I request (or transfer) a /22 and launch every piece of gear that the /22 is 
used on to Mars, and I come back for another /22 (request or transfer), can I 
count the first /22 as utilized even though it isn't being used in-region, or 
will I be denied because my first /22 isn't in-use in-region?

Matthew -

It’s utilized, but the processing of the request depends on whether it is an 
end-user
or ISP request 
http://lists.arin.net/pipermail/arin-ppml/2013-October/027405.html
You haven’t referenced “customers” in the above, so it’s not clear which policy 
you’d
be applying for additional resources under - I’d note that ISP customer growth 
that
is outside of region would not be considered for sizing any additional 
allocation...
(how relevant or meaningful that is given a depleted regional IPv4 free pool is 
an
excellent question.)

Thanks!
/John

John Curran
President and CEO
ARIN



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Re: [arin-ppml] Draft Policy ARIN-2015-5: Out of region use

[Tony Hain]

Milton L Mueller wrote:
 Jimmy
 Comments inline
 I agree with many of your arguments, especially this one:
 
  -Original Message-
  As of now.  there is really no pool of scarce IPv4  resources to
  distribute according to local policies...
  The purpose of having multiple RIRs in the first place, instead of one
  global GIRthat can  allocate, register, transfer resources in any
  region,   is greatly diminished.
 
  I would suggest that Out of Region use be fully allowed for all
  resources,  with disclosure of the caveat that  optimal routing might
  be more limited for out of region usage.
 
  The only hard constraint should be that the resource holder must at
  all times provide and maintain a contact or agent with physical
  mailing address in one of the countries served by ARIN,  unless,  or
  until such time as there is a global registry.
 
 I would note that the current version of out of region use allowance
(2015-
 5) is designed to restrict out of region use far beyond these constraints.
It
 requires companies to meet criteria that are, in effect, a jurisdictional
nexus
 test. This was added to the policy because a) of concerns about gaming
 access to the free pool, a concern that is no longer salient; and b)
objections
 from law enforcement agencies who would like to align number resources
 with jurisdiction.
 
 Although it might be possible for these provisions to mitigate that kind
of
 opposition, the current policy is a step backwards rather than forwards in
 terms of actually allowing out of region use. I would be interested in
 hearing from community members whether they think the increasingly
 formalized jurisdictionalization of the number space fostered by 2015-5
is
 worth whatever gains might be obtained by formally approving out of
 region use for those who qualify
 
 --MM

It really needs to be taken a step further than that though, in that the
real question is whether the implied alignment with jurisdiction is *ANY*
different than nationally aligned PSTN numbering? If someone believes it is,
they need to be very explicit about why geographic alignment of addresses is
now a good thing, when it has always been fought against in the past
(https://www.ietf.org/archive/id/draft-hain-ipv6-geo-addr-02.txt  others
from the ITU on national alignments).

The entirety of 2015-5 is misguided in that it starts from the assumption
that the resources are ARIN property to begin with, then assumes that the
registrant is engaged in a business activity. As far as I know, ARIN is a
registration facilitator for a set of global resources, and one could argue
that if NASA wanted to use some for communication between here and Mars,
that would still qualify as valid and 'out of region'. The entirety of the
current language needs to  be scrapped, and start from the perspective that
it is simply to clarify that the resources are for global use, and ARIN's
role is simply to be a facilitator within a reasonably local time-zone, and
having local language support. Any language that implies that there is a
limitation to use needs to be removed, or an explanation as to why that
restriction is any different than nationally aligned allocations needs to be
added.

Tony





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Re: [arin-ppml] Draft Policy ARIN-2015-5: Out of region use

[John Curran]

On Jul 3, 2015, at 2:29 PM, Tony Hain 
alh-i...@tndh.netmailto:alh-i...@tndh.net wrote:
The entirety of 2015-5 is misguided in that it starts from the assumption
that the resources are ARIN property to begin with, then assumes that the
registrant is engaged in a business activity.

Tony -

   That’s not a correct characterization - Internet number resources are global
   in scope, but often administrated by entities that only have a specific 
service
   region or scope of services.   ARIN has a defined service region, and it is a
   valid question what defines an entity (legal presence, operational nexus, 
etc.)
   for purposes of who ARIN provides services to...

As far as I know, ARIN is a
registration facilitator for a set of global resources, and one could argue
that if NASA wanted to use some for communication between here and Mars,
that would still qualify as valid and 'out of region’.

   It would - if NASA was the requester, there’d unlikely to be any issue…

   If the request came entirely from the other end, we presently would not
   provide services due to their lack of a meaningful legal presence in the
   region.

The entirety of the
current language needs to  be scrapped, and start from the perspective that
it is simply to clarify that the resources are for global use, and ARIN's
role is simply to be a facilitator within a reasonably local time-zone, and
having local language support.

  Even under such a definition, we’d like refer the requesters from Mars to 
their
  service provider for their number resource needs, as their time zone is either
  formally undefined or not be reasonably local depending on one’s perspective.

Thanks,
/John

John Curran
President and CEO
ARIN

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Re: [arin-ppml] Draft Policy ARIN-2015-5: Out of region use

[Milton L Mueller]

Jimmy
Comments inline
I agree with many of your arguments, especially this one:

 -Original Message-
 As of now.  there is really no pool of scarce IPv4  resources to
 distribute according to local policies...
 The purpose of having multiple RIRs in the first place, instead of one
 global GIRthat can  allocate, register, transfer resources in any
 region,   is greatly diminished.

 I would suggest that Out of Region use be fully allowed for all
 resources,  with disclosure of the caveat that  optimal routing might be
 more limited for out of region usage.
 
 The only hard constraint should be that the resource holder must at all
 times provide and maintain a contact or agent with physical mailing
 address in one of the countries served by ARIN,  unless,  or until such
 time as there is a global registry.

I would note that the current version of out of region use allowance (2015-5) 
is designed to restrict out of region use far beyond these constraints. It 
requires companies to meet criteria that are, in effect, a jurisdictional nexus 
test. This was added to the policy because a) of concerns about gaming access 
to the free pool, a concern that is no longer salient; and b) objections from 
law enforcement agencies who would like to align number resources with 
jurisdiction. 

Although it might be possible for these provisions to mitigate that kind of 
opposition, the current policy is a step backwards rather than forwards in 
terms of actually allowing out of region use. I would be interested in hearing 
from community members whether they think the increasingly formalized 
jurisdictionalization of the number space fostered by 2015-5 is worth 
whatever gains might be obtained by formally approving out of region use for 
those who qualify

--MM
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Re: [arin-ppml] Draft Policy ARIN-2015-5: Out of region use

[Matthew Kaufman]

On 7/3/2015 12:05 PM, John Curran wrote:
   It would - if NASA was the requester, there’d unlikely to be any 
issue…


   If the request came entirely from the other end, we presently would 
not
   provide services due to their lack of a meaningful legal presence 
in the

   region.



John,

If I request (or transfer) a /22 and launch every piece of gear that the 
/22 is used on to Mars, and I come back for another /22 (request or 
transfer), can I count the first /22 as utilized even though it isn't 
being used in-region, or will I be denied because my first /22 isn't 
in-use in-region?


Matthew Kaufman
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Re: [arin-ppml] Draft Policy ARIN-2015-5: Out of region use

[Tony Hain]

John Curran wrote:
On Jul 3, 2015, at 2:29 PM, Tony Hain alh-i...@tndh.net wrote:
The entirety of 2015-5 is misguided in that it starts from the assumption
that the resources are ARIN property to begin with, then assumes that the
registrant is engaged in a business activity. 

Tony - 
 
   That’s not a correct characterization - Internet number resources are global
   in scope, but often administrated by entities that only have a specific 
service
   region or scope of services.   ARIN has a defined service region, and it is a
   valid question what defines an entity (legal presence, operational nexus, 
etc.)
   for purposes of who ARIN provides services to... 

[TH] I believe the rest of what I said and this paragraph are in violent 
agreement, but defining who ARIN provides service to is not the point of this 
proposed text; by content or title. This document is trying to scope where 
resources get used, not who is allowed to do business with ARIN. 


As far as I know, ARIN is a
registration facilitator for a set of global resources, and one could argue
that if NASA wanted to use some for communication between here and Mars,
that would still qualify as valid and 'out of region’. 

   It would - if NASA was the requester, there’d unlikely to be any issue…

   If the request came entirely from the other end, we presently would not 
   provide services due to their lack of a meaningful legal presence in the 
   region.

[TH] So does ARIN have an expansion plan, or will the NRO need to allow for 
another RIR?  ... ;)

The entirety of the
current language needs to  be scrapped, and start from the perspective that
it is simply to clarify that the resources are for global use, and ARIN's
role is simply to be a facilitator within a reasonably local time-zone, and
having local language support. 

  Even under such a definition, we’d like refer the requesters from Mars to 
their 
  service provider for their number resource needs, as their time zone is either
  formally undefined or not be reasonably local depending on one’s perspective.

[TH]  I can certainly understand wanting to have clarity (legal or otherwise) 
about who is allowed to be a customer, but as I read it, that is not what this 
proposal is about. If the requesting ISP from Mars didn't have, or couldn't do 
business with their local RIR for some reason, it would be useful to have a 
policy that allowed at least one of the RIR's to provide service. In any case, 
once the resources were allocated and registered, where they are used is 
outside the scope of the registrar's jurisdiction, as they were and continue to 
be a global (universal) resource. All attempts to restrict region of use by 
policy, assert 'property rights' which never existed in the first place. At the 
end of the day, allowing ill-thought-out policy adjustments to 'manage' the 
IPv4 address pool will do nothing except endanger the ability to properly 
manage the IPv6 pool. All IPv4 policy changes should be limited to recognizing 
that the free-pool is exhausted, and otherwise stop.

Tony

Thanks,
/John

John Curran
President and CEO
ARIN


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Re: [arin-ppml] Draft Policy ARIN-2015-5: Out of region use

[William Herrin]

On Wed, Jul 1, 2015 at 3:32 PM, Heather Schiller
heather.ska...@gmail.com wrote:
 Thank you for your feedback. It would be useful to the AC and the authors if
 you could site the specific language that causes your concern, so that we
 can work to improve it.  We would also welcome suggestions for
 modifications.

Hi Heather,

As near as I can figure, it's the whole darn thing. Pick a sentence,
put it in quotes and ask, What the heck does that mean?

For example:

Demonstrating that the entity raises investment capital from
investors in the ARIN region.

What the heck does that mean? Does it mean that if as a citizen of the
Commonwealth of Virginia I own a single share of ChinaCorp, then
ChinaCorp can register ARIN addresses for use in China? Maybe I don't
have to, it's good enough that the Chinese ambassador residing in D.C.
own a single share.

How are staff supposed to assess whether an organization meets such an
impossibly vague criteria?


Frankly, I think the idea of expansively enumerating the situations in
which addresses may be used outregion is unworkable and should be
abandoned.

If we want addresses to be blithely usable on a global basis, there
are right ways and wrong ways to go about it. This is one of the wrong
ways. A right way would be globally standardizing the address
registration and transfer process, policies and address pools. No more
regionality to IPv4 at any level, just multiple staffs following
identical rules for access to the same assets.

If we want regional policy control, that should and must include
regional use constraints. That means address use outregion only where
such use is strictly incidental to the in-region use. Number both
sides of the New York to London link out of ARIN addresses, but the
London office gets its addresses from RIPE.

Regards.
Bill Herrin



-- 
William Herrin  her...@dirtside.com  b...@herrin.us
Owner, Dirtside Systems . Web: http://www.dirtside.com/
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Re: [arin-ppml] Draft Policy ARIN-2015-5: Out of region use

[Martin Hannigan]

Opposed.  

We all have already been here and done that. 

The community told the AC and ARIN  to abandon. Not to do over. We already have 
all of our objections on record including THST we already use resources 
globally (cdn, content).  

Where are we disconnected? Can you elaborate? Will help us to comprehend.

Best,

Marty


 



 On Jul 1, 2015, at 15:32, Heather Schiller heather.ska...@gmail.com wrote:
 
 Hi Bill,
 
 Thank you for your feedback. It would be useful to the AC and the authors if 
 you could site the specific language that causes your concern, so that we can 
 work to improve it.  We would also welcome suggestions for modifications.
 
 Thanks,
 -- Heather
 On Jun 23, 2015 7:00 PM, William Herrin b...@herrin.us wrote:
 On Tue, Jun 23, 2015 at 4:06 PM, ARIN i...@arin.net wrote:
  Draft Policy ARIN-2015-5
  Out of region use
 
 OPPOSED.
 
 This draft calls for ARIN staff to make highly subjective value
 judgments which will, by their nature, vary from individual to
 individual and probably even from an individual's mood to mood. This
 would make a fair and impartial implementation of such a policy
 impossible.
 
 Regards,
 Bill Herrin
 
 --
 William Herrin  her...@dirtside.com  b...@herrin.us
 Owner, Dirtside Systems . Web: http://www.dirtside.com/
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Re: [arin-ppml] Draft Policy ARIN-2015-5: Out of region use

[Heather Schiller]

Hi Bill,

Thank you for your feedback. It would be useful to the AC and the authors
if you could site the specific language that causes your concern, so that
we can work to improve it.  We would also welcome suggestions for
modifications.

Thanks,
-- Heather
 On Jun 23, 2015 7:00 PM, William Herrin b...@herrin.us wrote:

 On Tue, Jun 23, 2015 at 4:06 PM, ARIN i...@arin.net wrote:
  Draft Policy ARIN-2015-5
  Out of region use

 OPPOSED.

 This draft calls for ARIN staff to make highly subjective value
 judgments which will, by their nature, vary from individual to
 individual and probably even from an individual's mood to mood. This
 would make a fair and impartial implementation of such a policy
 impossible.

 Regards,
 Bill Herrin

 --
 William Herrin  her...@dirtside.com  b...@herrin.us
 Owner, Dirtside Systems . Web: http://www.dirtside.com/
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Re: [arin-ppml] Draft Policy ARIN-2015-5: Out of region use

[Jon Lewis]

I'm in favor of 2015-5, but think it's a little late to be even talking 
about this.  My problem with current policy is ARIN has adopted a highly 
conservative interpretation of vague policy (basically inventing policy 
disallowing out of region use when such a thing is not explicitly in any 
established policy).


There are ARIN members running global networks who have been using ARIN 
resources out of region for many years, only to eventually find out those 
IPs don't count as 'utilized' depending on exactly how you've allocated 
and routed them.


Given how close ARIN is to run-out, I'm not sure how meaningful passage of 
2015-5 would be...but I'd still like to see more of a connection between 
ARIN's number policies and the actual NRPM (not some narrow interpretation 
of its vagueness).


On Wed, 1 Jul 2015, Martin  Hannigan wrote:


Opposed.

We all have already been here and done that.

The community told the AC and ARIN  to abandon. Not to do over. We already have 
all of our objections on record including THST we already use resources 
globally (cdn, content).

Where are we disconnected? Can you elaborate? Will help us to comprehend.

Best,

Marty







On Jul 1, 2015, at 15:32, Heather Schiller heather.ska...@gmail.com wrote:

Hi Bill,

Thank you for your feedback. It would be useful to the AC and the authors if 
you could site the specific language that causes your concern, so that we can 
work to improve it.  We would also welcome suggestions for modifications.

Thanks,
-- Heather

On Jun 23, 2015 7:00 PM, William Herrin b...@herrin.us wrote:
On Tue, Jun 23, 2015 at 4:06 PM, ARIN i...@arin.net wrote:

Draft Policy ARIN-2015-5
Out of region use


OPPOSED.

This draft calls for ARIN staff to make highly subjective value
judgments which will, by their nature, vary from individual to
individual and probably even from an individual's mood to mood. This
would make a fair and impartial implementation of such a policy
impossible.

Regards,
Bill Herrin

--
William Herrin  her...@dirtside.com  b...@herrin.us
Owner, Dirtside Systems . Web: http://www.dirtside.com/
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--
 Jon Lewis, MCP :)   |  I route
 |  therefore you are
_ http://www.lewis.org/~jlewis/pgp for PGP public key_
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Re: [arin-ppml] Draft Policy ARIN-2015-5: Out of region use

[Owen DeLong]

Since this would impact IPv6, ASNs, and IPv4 transfers, I don’t think it’s 
particularly late.

I agree it’s late for the IPv4 free pool, as that is essentially dead (and 
hopefully really dead soon), but I think there remains relevance to addressing 
the policy issues.

Admittedly this is less of an issue for ASNs due to the nature of their usage, 
but I think it’s still just as relevant for some cases of IPv6.

Owen

 On Jul 1, 2015, at 16:36 , Jon Lewis jle...@lewis.org wrote:
 
 I'm in favor of 2015-5, but think it's a little late to be even talking about 
 this.  My problem with current policy is ARIN has adopted a highly 
 conservative interpretation of vague policy (basically inventing policy 
 disallowing out of region use when such a thing is not explicitly in any 
 established policy).
 
 There are ARIN members running global networks who have been using ARIN 
 resources out of region for many years, only to eventually find out those 
 IPs don't count as 'utilized' depending on exactly how you've allocated and 
 routed them.
 
 Given how close ARIN is to run-out, I'm not sure how meaningful passage of 
 2015-5 would be...but I'd still like to see more of a connection between 
 ARIN's number policies and the actual NRPM (not some narrow interpretation of 
 its vagueness).
 
 On Wed, 1 Jul 2015, Martin  Hannigan wrote:
 
 Opposed.
 
 We all have already been here and done that.
 
 The community told the AC and ARIN  to abandon. Not to do over. We already 
 have all of our objections on record including THST we already use resources 
 globally (cdn, content).
 
 Where are we disconnected? Can you elaborate? Will help us to comprehend.
 
 Best,
 
 Marty
 
 
 
 
 
 
 On Jul 1, 2015, at 15:32, Heather Schiller heather.ska...@gmail.com wrote:
 
 Hi Bill,
 
 Thank you for your feedback. It would be useful to the AC and the authors 
 if you could site the specific language that causes your concern, so that 
 we can work to improve it.  We would also welcome suggestions for 
 modifications.
 
 Thanks,
 -- Heather
 On Jun 23, 2015 7:00 PM, William Herrin b...@herrin.us wrote:
 On Tue, Jun 23, 2015 at 4:06 PM, ARIN i...@arin.net wrote:
 Draft Policy ARIN-2015-5
 Out of region use
 
 OPPOSED.
 
 This draft calls for ARIN staff to make highly subjective value
 judgments which will, by their nature, vary from individual to
 individual and probably even from an individual's mood to mood. This
 would make a fair and impartial implementation of such a policy
 impossible.
 
 Regards,
 Bill Herrin
 
 --
 William Herrin  her...@dirtside.com  b...@herrin.us
 Owner, Dirtside Systems . Web: http://www.dirtside.com/
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Re: [arin-ppml] Draft Policy ARIN-2015-5: Out of region use

[Jimmy Hess]

On Wed, Jul 1, 2015 at 7:18 PM, William Herrin b...@herrin.us wrote:
 Applying regional use constraints to AS numbers makes exactly zero
 sense to me.  If anyone feels there's a need to spell this out, please

As of now.  there is really no pool of scarce IPv4  resources to
distribute according to local policies...

The purpose of having multiple RIRs in the first place, instead of one
global GIRthat can  allocate, register, transfer resources in any
region,   is greatly diminished.

I would suggest that ARIN perhaps begin to transform itself into a
global registry and drop the  service region idea   and   the
region specific usage ideas  for all resources and services.

Applying regional use constraints to *ANY* number resources  no longer
makes any sense;   it barely did for IPv4,  and  IPv6 is not scarce.


The only remaining utility would be  hierarchical distribution of IPv6
resources according to region,  to facilitate filtering.

It is questionable whether that will in fact be useful in practice.


I would suggest that Out of Region use be fully allowed for all
resources,  with disclosure of the caveat that  optimal routing might
be more limited for out of region usage.

The only hard constraint should be that the resource holder must at
all times provide and maintain a contact or agent with physical
mailing address in one of the countries served by ARIN,  unless,  or
until such time as there is a global registry.

Originally,  there was a concern that some orgs might game the RIR
system, byshopping different regions  to obtain scarce IPv4
resources they might not be eligible for otherwise.

It's hard to imagine how it could be a concern now


 Regards,
 Bill Herrin
--
-JH
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Re: [arin-ppml] Draft Policy ARIN-2015-5: Out of region use

[John Curran]

On Jul 1, 2015, at 7:36 PM, Jon Lewis jle...@lewis.org wrote:
 
 I'm in favor of 2015-5, but think it's a little late to be even talking about 
 this.  My problem with current policy is ARIN has adopted a highly 
 conservative interpretation of vague policy (basically inventing policy 
 disallowing out of region use when such a thing is not explicitly in any 
 established policy).

Actually, the fact that ARIN has a service region is quite clear.  The 
implications of having 
a service region is that organizations that have no operational presence in the 
region and 
request resources not for use in the region are denied.   This was called out 
to the community 
in April 2013 Barbados Policy Experience Report, so that the community could 
discuss and 
change policy if so desired.

 There are ARIN members running global networks who have been using ARIN 
 resources out of region for many years, only to eventually find out those 
 IPs don't count as 'utilized' depending on exactly how you've allocated and 
 routed them.”

Actually, the policy experience report was not the result of any issues or 
concerns raised
by any global organization seeking to obtain or use IP address space from ARIN 
- it was 
the result of a number of organizations seeking address space that had no 
operational 
presence in the region.

 Given how close ARIN is to run-out, I'm not sure how meaningful passage of 
 2015-5 would be...but I'd still like to see more of a connection between 
 ARIN's number policies and the actual NRPM (not some narrow interpretation of 
 its vagueness).

The existing policy text is sufficient for current registry administration, but 
clarity is always
helpful (and why the staff provides policy experience reports at the meetings)  
At this point, 
it has been more than two years since the Barbados experience report without 
consensus 
for a change - if the community wants to provide additional clarity, that would 
be still be 
welcome (even if it does not get much use in light of the depletion of the IPv4 
free pool.)

Thanks!
/John

John Curran
President and CEO
ARIN

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Re: [arin-ppml] Draft Policy ARIN-2015-5: Out of region use

[John Curran]

On Jul 1, 2015, at 8:37 PM, Jimmy Hess 
mysi...@gmail.commailto:mysi...@gmail.com wrote:
...
The purpose of having multiple RIRs in the first place, instead of one
global GIRthat can  allocate, register, transfer resources in any
region,   is greatly diminished.

Regional Internet registries were established predominantly for distribution
the administration of the Internet number registry system, i.e. not as a way
of managing regional pools of resources, but as a way of providing access
to the global pool of resources via distributed regional locations.  You can
read more about these beginnings in RFC 1174 'IAB Recommended Policy
on Distributing Internet Identifier Assignment and IAB Recommended Policy
Change to Internet Connected” Status’.

The runout of the regional free pool does not change the reasoning behind
why regional Internet registries help with administration; i.e. providing local
hours and language support, etc.   It does argue that regional registries may
not have reduced need for exclusive service regions (as described in ICANN
ICP-2) -

Each region should be served by a single RIR, established under one management 
and in one location. The establishment of multiple RIRs in one region is likely 
to lead to:

• fragmentation of address space allocated to the region;
• difficulty for co-ordination and co-operation between the RIRs;
• confusion for the community within the region.”

If RIRs do not have to worry about fragmentation during new issuance,
than the first of the bullets above becomes less of any issue.

I would suggest that ARIN perhaps begin to transform itself into a
global registry and drop the  service region idea   and   the
region specific usage ideas  for all resources and services.

“ARIN transform itself” is probably better said as “The ARIN community
should perhaps discuss the need for the RIR system structure to evolve,
and discussion next steps in this evolution.”, i.e. ARIN staff cannot lead
such discussions; it it up to the global numbers community to discuss and
build consensus on how to best evolve the system.

Thanks!
/John

John Curran
President and CEO
ARIN




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Re: [arin-ppml] Draft Policy ARIN-2015-5: Out of region use

[William Herrin]

On Wed, Jul 1, 2015 at 7:43 PM, Owen DeLong o...@delong.com wrote:
 Admittedly this is less of an issue for ASNs due to the nature of their
 usage, but I think it’s still just as relevant for some cases of IPv6.

Howdy,

Applying regional use constraints to AS numbers makes exactly zero
sense to me.  If anyone feels there's a need to spell this out, please
write a policy to that effect and I doubt you'll see any opposition to
its passage.

The different types of number resources aren't the same. Policies
which make sense for one type don't necessarily make sense for
another.

Regards,
Bill Herrin


-- 
William Herrin  her...@dirtside.com  b...@herrin.us
Owner, Dirtside Systems . Web: http://www.dirtside.com/
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Re: [arin-ppml] Draft Policy ARIN-2015-5: Out of region use

[Jason Schiller]

The primary objection to this policy's successor was legal concerns
surrounding the strength on the nexus to the region, liability to ARIN ,
and an inability to pursue legal redress (apologies if I didn't get that
quite right).

Does this policy mitigate those concerns?

Is it possible to get an early legal assessment (noting the policy and the
assessment may change prior the the next meeting)?

Thanks,

__Jason

On Tue, Jun 23, 2015 at 4:06 PM, ARIN i...@arin.net wrote:

 Draft Policy ARIN-2015-5
 Out of region use

 On 18 June 2015 the ARIN Advisory Council (AC) accepted ARIN-prop-219 Out
 of region use as a Draft Policy.

 Draft Policy ARIN-2015-5 is below and can be found at:
 https://www.arin.net/policy/proposals/2015_5.html

 You are encouraged to discuss the merits and your concerns of Draft
 Policy 2015-5 on the Public Policy Mailing List.

 The AC will evaluate the discussion in order to assess the conformance
 of this draft policy with ARIN's Principles of Internet Number Resource
 Policy as stated in the PDP. Specifically, these principles are:

   * Enabling Fair and Impartial Number Resource Administration
   * Technically Sound
   * Supported by the Community

 The ARIN Policy Development Process (PDP) can be found at:
 https://www.arin.net/policy/pdp.html

 Draft Policies and Proposals under discussion can be found at:
 https://www.arin.net/policy/proposals/index.html

 Regards,

 Communications and Member Services
 American Registry for Internet Numbers (ARIN)


 ## * ##


 Draft Policy ARIN-2015-5
 Out of region use

 Date: 23 June 2015

 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 the key concerns expressed about unlimited
 openness to out of region use and enables ARIN staff to implement the
 policy efficiently.

 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 currently using at least the
 equivalent of a /22 of IPv4, /44 of IPv6, or 1 ASN within the ARIN service
 region, respectively. In addition, the applicant must have a real and
 substantial connection with the ARIN region, which the applicant shall be
 responsible for proving.

 A real and substantial connection shall be defined as carrying on business
 in the ARIN region in a meaningful manner, whether for or not for profit.
 The determination as to whether an entity is carrying on business in the
 ARIN region in a meaningful manner shall be made by ARIN. Simply being
 incorporated in the ARIN region shall not be sufficient, on its own, to
 prove that an entity is carrying on business in the ARIN region in a
 meaningful manner. Methods that entities may consider using, including
 cumulatively, to prove that they are carrying on business in the ARIN
 region in a meaningful manner include:
 •   Demonstrating a physical presence in the ARIN region through a
 bricks and mortar location that is actually used for the purposes of
 conducting business in the ARIN region in a meaningful manner. That is to
 say, the location is not merely a registered office that serves no other
 business purpose.
 •   Demonstrating that the entity has staff in the ARIN region. The
 greater the number of staff, the stronger this connecting factor is.
 •   Demonstrating that the entity holds assets in the ARIN region. The
 greater the asset value, the stronger this connecting factor is.
 •   Demonstrating that the entity provides services to or solicits
 sales from residents of the ARIN region.
 •   Demonstrating that the entity holds annual meetings in the ARIN
 region.
 •   Demonstrating that the entity raises investment capital from
 investors in the ARIN region.
 •   Demonstrating that the entity has a registered office in the ARIN
 region, although this factor on its own shall not be sufficient.
 •   Any other method that the entity considers appropriate.

 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, the 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, 

[arin-ppml] Draft Policy ARIN-2015-5: Out of region use

[ARIN]

Draft Policy ARIN-2015-5
Out of region use

On 18 June 2015 the ARIN Advisory Council (AC) accepted ARIN-prop-219 
Out of region use as a Draft Policy.


Draft Policy ARIN-2015-5 is below and can be found at:
https://www.arin.net/policy/proposals/2015_5.html

You are encouraged to discuss the merits and your concerns of Draft
Policy 2015-5 on the Public Policy Mailing List.

The AC will evaluate the discussion in order to assess the conformance
of this draft policy with ARIN's Principles of Internet Number Resource
Policy as stated in the PDP. Specifically, these principles are:

  * Enabling Fair and Impartial Number Resource Administration
  * Technically Sound
  * Supported by the Community

The ARIN Policy Development Process (PDP) can be found at:
https://www.arin.net/policy/pdp.html

Draft Policies and Proposals under discussion can be found at:
https://www.arin.net/policy/proposals/index.html

Regards,

Communications and Member Services
American Registry for Internet Numbers (ARIN)


## * ##


Draft Policy ARIN-2015-5
Out of region use

Date: 23 June 2015

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 the key concerns expressed 
about unlimited openness to out of region use and enables ARIN staff to 
implement the policy efficiently.


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 currently using at least 
the equivalent of a /22 of IPv4, /44 of IPv6, or 1 ASN within the ARIN 
service region, respectively. In addition, the applicant must have a 
real and substantial connection with the ARIN region, which the 
applicant shall be responsible for proving.


A real and substantial connection shall be defined as carrying on 
business in the ARIN region in a meaningful manner, whether for or not 
for profit. The determination as to whether an entity is carrying on 
business in the ARIN region in a meaningful manner shall be made by 
ARIN. Simply being incorporated in the ARIN region shall not be 
sufficient, on its own, to prove that an entity is carrying on business 
in the ARIN region in a meaningful manner. Methods that entities may 
consider using, including cumulatively, to prove that they are carrying 
on business in the ARIN region in a meaningful manner include:
•	Demonstrating a physical presence in the ARIN region through a bricks 
and mortar location that is actually used for the purposes of conducting 
business in the ARIN region in a meaningful manner. That is to say, the 
location is not merely a registered office that serves no other business 
purpose.
•	Demonstrating that the entity has staff in the ARIN region. The 
greater the number of staff, the stronger this connecting factor is.
•	Demonstrating that the entity holds assets in the ARIN region. The 
greater the asset value, the stronger this connecting factor is.
•	Demonstrating that the entity provides services to or solicits sales 
from residents of the ARIN region.

•   Demonstrating that the entity holds annual meetings in the ARIN region.
•	Demonstrating that the entity raises investment capital from investors 
in the ARIN region.
•	Demonstrating that the entity has a registered office in the ARIN 
region, although this factor on its own shall not be sufficient.

•   Any other method that the entity considers appropriate.

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, the 
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: Various iterations of this policy have 
been presented and debated by ARIN for well over a year now. Given the 
amount of time that has already been spent on developing a policy, 
ideally, this policy would be implemented as soon as possible.


b)	Explanation of draft policy: The draft policy addresses both the 
problem statement as well as the concerns raised at ARIN 35 by 
participants as well as ARIN 

Re: [arin-ppml] Draft Policy ARIN-2015-5: Out of region use

[William Herrin]

On Tue, Jun 23, 2015 at 4:06 PM, ARIN i...@arin.net wrote:
 Draft Policy ARIN-2015-5
 Out of region use

OPPOSED.

This draft calls for ARIN staff to make highly subjective value
judgments which will, by their nature, vary from individual to
individual and probably even from an individual's mood to mood. This
would make a fair and impartial implementation of such a policy
impossible.

Regards,
Bill Herrin

-- 
William Herrin  her...@dirtside.com  b...@herrin.us
Owner, Dirtside Systems . Web: http://www.dirtside.com/
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