How about if each company would have to make their case, based on the greatest
number of attachment points to a particular area? They could show they have a
plurality of elements linking them to ARIN's region rather than to any other
region (such as a majority of their end-users being present in that region
and/or it makes sense operationally to submit the request to ARIN because of
the presence of a majority of its equipment located in that region, and/or
other attachment elements to be defined). Instead of having only 1 criteria for
attachment to a particular region, there could be several and if 3 out 5 are
verified, than the entity would receive number resources from the RIR.
This would allow staff to have a global picture of that entity and the policy
could be made as liberal or as restrictive as desired by the community.
Nathalie Coupet
ARIN Member
________________________________
From: nathalie coupet <[email protected]>
To: "[email protected]" <[email protected]>
Sent: Saturday, September 14, 2013 1:58 PM
Subject: "Re: Contents of ARIN-PPML digest, Vol 99, Issue 10..."
How about if each company would have to make their case, based on the greatest
number of attachment points to a particular area? They could show they have a
plurality of elements linking them to ARIN's region rather than to any other
region (such as a majority of their end-users being present in that region
and/or it makes sense operationally to submit the request to ARIN because of
the presence of a majority of its equipment located in that region, and/or
other attachment elements to be defined).
Nathalie Coupet
ARIN Member
________________________________
From: "[email protected]" <[email protected]>
To: [email protected]
Sent: Friday, September 13, 2013 5:45 PM
Subject: ARIN-PPML Digest, Vol 99, Issue 9
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Today's Topics:
1. Re: Draft Policy ARIN-2013-6: Allocation of IPv4 and IPv6
Address Space to Out-of-region Requestors - Revised Problem
Statement and Policy Text (William Herrin)
2. Re: Draft Policy ARIN-2013-6: Allocation of IPv4 and IPv6
Address Space to Out-of-region Requestors - Revised Problem
Statement and Policy Text (William Herrin)
3. Re: Draft Policy ARIN-2013-6: Allocation of IPv4 and IPv6
Address Space
to Out-of-region Requestors - Revised Problem
Statement and Policy Text (William Herrin)
4. Re: Draft Policy ARIN-2013-6: Allocation of IPv4 and IPv6
Address Space to Out-of-region Requestors - Revised Problem
Statement and Policy Text (John Curran)
5. Re: Draft Policy ARIN-2013-6: Allocation of IPv4 and IPv6
Address Space to Out-of-region Requestors - Revised Problem
Statement and Policy Text (David Conrad)
6. Re: Draft Policy ARIN-2013-6: Allocation of IPv4 and IPv6
Address Space to Out-of-region Requestors - Revised Problem
Statement and Policy Text (Kevin Kargel)
7. Re: Draft Policy ARIN-2013-6: Allocation of IPv4 and IPv6
Address Space to Out-of-region Requestors
- Revised Problem
Statement and Policy Text (David Conrad)
----------------------------------------------------------------------
Message: 1
Date: Fri, 13 Sep 2013 15:54:37 -0400
From: William Herrin <[email protected]>
To: John Curran <[email protected]>
Cc: "[email protected]" <[email protected]>
Subject: Re: [arin-ppml] Draft Policy ARIN-2013-6: Allocation of IPv4
and IPv6 Address Space to Out-of-region Requestors - Revised Problem
Statement and Policy Text
Message-ID:
<cap-gugwhiffyhszgrvghqk+csnwhod+s_g-h_agbs+nn6he...@mail.gmail.com>
Content-Type: text/plain; charset=ISO-8859-1
On Fri, Sep 13, 2013 at 3:26 PM, John Curran <[email protected]> wrote:
> It is ARIN's practice to assign number resources to organizations,
> not individuals.
That's me, Mr. Outlier.
>> On Sep 13, 2013, at 11:59 AM, William Herrin <[email protected]> wrote:
>>> More importantly: why not?
>
> At a minimum, NRPM 2.6 ("End-user" definition) would need to be
> changed to recognize IP address assignments to individuals -
>
> "2.6 An end-user is an organization receiving assignments of IP
>
addresses exclusively for use in its operational networks."
An organization is some number of people acting on concert towards a
common goal. One is an acceptable number. Given Citizens United and
the history of similar rulings, I'm pretty sure I can make that claim
stick.
Besides which, I presume ARIN doesn't refuse to do business with sole
proprietorships. A sole proprietorship has no legal existence separate
from the single individual who owns it. With minor exceptions (Bob's
Bait and Tackle can't get married or adopt children) a proprietorship
is legally synonymous with its owner.
What else ya got? :)
Regards,
Bill Herrin
--
William D. Herrin ................ [email protected] [email protected]
3005 Crane Dr. ...................... Web:
<http://bill.herrin.us/>
Falls Church, VA 22042-3004
------------------------------
Message: 2
Date: Fri, 13 Sep 2013 16:41:42 -0400
From: William Herrin <[email protected]>
To: John Santos <[email protected]>
Cc: "[email protected]" <[email protected]>
Subject: Re: [arin-ppml] Draft Policy ARIN-2013-6: Allocation of IPv4
and IPv6 Address Space to Out-of-region Requestors - Revised Problem
Statement and Policy Text
Message-ID:
<CAP-guGUe5kebTSQNgD_jsNznMv3=2bjm_gqqad7bbfxer-u...@mail.gmail.com>
Content-Type: text/plain; charset=ISO-8859-1
On Fri, Sep 13, 2013 at 12:52 PM, John Santos <[email protected]> wrote:
> What if the business is international, with sites all over the world?
> Should they be forced to run at least 5 separate networks instead of a
> single integrated network?
Hi John,
That's a fair question. I hope I don't mischaracterize the ITU's
position when I say they think a strictly regionalized registry system
is detrimental to business in exactly this manner. They would have
themselves designated as a registry with worldwide scope in order to
serve these interests among others.
I'd offer this answer: if we want to continue as a system of
regional
registries then it's generally appropriate for a multinational
organization get acquire the number resources it deploys in each
region from that region's registry. One network. Five suppliers, whose
goods have geographical constraints on their use.
If a system of regional registries is no longer indicated, that's a
much bigger topic of discussion which we shouldn't back-door by having
ARIN unilaterally act as registry to the world.
Regards,
Bill Herrin
--
William D. Herrin ................ [email protected] [email protected]
3005 Crane Dr. ...................... Web: <http://bill.herrin.us/>
Falls Church, VA 22042-3004
------------------------------
Message:
3
Date: Fri, 13 Sep 2013 16:30:36 -0400
From: William Herrin <[email protected]>
To: Gary Buhrmaster <[email protected]>
Cc: "[email protected]" <[email protected]>
Subject: Re: [arin-ppml] Draft Policy ARIN-2013-6: Allocation of IPv4
and IPv6 Address Space to Out-of-region Requestors - Revised Problem
Statement and Policy Text
Message-ID:
<CAP-guGWPfrSPJbsvc2ZTshWgyQ-KzXF-+Zjhq0aoBq3=3Z=m...@mail.gmail.com>
Content-Type: text/plain;
charset=ISO-8859-1
On Fri, Sep 13, 2013 at 1:06 PM, Gary Buhrmaster
<[email protected]> wrote:
> On Fri, Sep 13, 2013 at 3:53 PM, William Herrin <[email protected]> wrote:
>> Yuck!
>
> Unless I am misreading this, this proposal deals with the initial
> (or additional) allocation/assignments, and not on-going activities.
> Once you get the numbers, you could then move the numbers
> to other regions.
Hi Gary,
Did I miss the text which exempts this draft from the exercise of NRPM
section 12.2.c and d?
Regards,
Bill Herrin
--
William D. Herrin ................ [email protected] [email protected]
3005 Crane Dr. ...................... Web: <http://bill.herrin.us/>
Falls Church, VA 22042-3004
------------------------------
Message: 4
Date: Fri, 13 Sep 2013 21:13:39 +0000
From: John Curran <[email protected]>
To: William Herrin <[email protected]>
Cc: "[email protected]" <[email protected]>
Subject: Re: [arin-ppml] Draft Policy ARIN-2013-6: Allocation of IPv4
and IPv6 Address Space to Out-of-region Requestors - Revised Problem
Statement and Policy Text
Message-ID: <[email protected]>
Content-Type: text/plain; charset="us-ascii"
On Sep 13, 2013, at 3:54 PM, William Herrin <[email protected]> wrote:
> On Fri, Sep 13, 2013 at 3:26 PM, John Curran <[email protected]> wrote:
>> It is ARIN's practice to assign number resources to organizations,
>> not individuals.
>
> That's me, Mr. Outlier.
>
>>> On Sep 13, 2013, at 11:59 AM, William Herrin <[email protected]> wrote:
>>>> More importantly: why not?
>>
>> At a minimum, NRPM 2.6 ("End-user" definition) would need to be
>> changed to recognize IP address assignments to individuals -
>>
>> "2.6 An end-user is an organization receiving assignments of IP
>> addresses exclusively for use in its operational networks."
>
> An organization is some number of people acting on concert towards a
> common goal. One is an acceptable number. Given Citizens United and
> the history of similar rulings, I'm pretty sure I can make that claim
> stick.
>
> Besides which, I presume ARIN doesn't refuse to do business with sole
> proprietorships. A sole proprietorship has no legal existence separate
> from the single individual who owns it. With minor exceptions (Bob's
> Bait and Tackle can't get married or adopt children) a proprietorship
> is legally synonymous with its owner.
>
>
What else ya got? :)
Bill -
We have no problem dealing with sole proprietorships; they are
organizations and can receive assignments. Note that the number
resources are still assigned in such cases to the organization
(i.e. in the name of the sole proprietorship) not the individual.
FYI,
/John
John Curran
President and CEO
ARIN
------------------------------
Message: 5
Date: Fri, 13 Sep 2013 17:12:58 -0400
From: David Conrad <[email protected]>
To: Kevin Kargel <[email protected]>
Cc: "[email protected]" <[email protected]>
Subject: Re: [arin-ppml] Draft Policy ARIN-2013-6: Allocation of IPv4
and IPv6 Address Space to Out-of-region Requestors - Revised Problem
Statement and Policy Text
Message-ID: <[email protected]>
Content-Type: text/plain; charset="us-ascii"
Kevin,
On Sep 13, 2013, at 2:42 PM, Kevin Kargel <[email protected]> wrote:
> I still don't see how this is going to be enforceable. To my eye it would
> entail getting geo-data for all last mile routers that service IP's under
> ARIN control and having someone or a sophisticated AI
bot continuously scanning the BGP tables to enumerate and verify the
geo-locations of the endpoints.
Why wouldn't an assertion by the applicant that they run a network in the ARIN
region and perhaps a traceroute or two be sufficient to meet the "operating a
network located in the ARIN service region" requirement?
> If the idea is just to ask people if they are in the ARIN governance area and
> make them promise to never move offshore (knowing it will not be subsequently
> policed) then I submit that the algorithm is way too easy to game by
> unscrupulous operators and will end up being a token policy that creates more
> bureaucracy and trouble for legitimate operators.
I don't see this being significantly different than gaming the "operational
needs" requirement. I think the issue here is establishing a policy basis upon
which violations, when detected, can be addressed. If it is discovered that
someone is getting addresses to
stockpile them for later sale, ARIN policy exists to allow ARIN to revoke
those addresses. This draft policy is saying that if someone is getting
addresses for use outside ARIN's region, there would be a policy to allow ARIN
to address that issue.
And, FWIW, I'll note that both AfriNIC and LACNIC (the remaining RIRs that have
not gone into "last /8" policy) require companies to demonstrate in-region
legal status and network usage.
> If you can figure out a way to enforce *and* implement it I would support the
> policy, but until that time I have to vote "nay". I suspect that even if it
> were implemented enforcement would only be possible if it were written with
> an anti-grandfather clause.
Wait, I liked my grandfather... :) (sorry, not sure what an 'anti-grandfather
clause is)
Regards,
-drc
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Message: 6
Date: Fri, 13 Sep 2013 16:20:22 -0500
From: Kevin Kargel <[email protected]>
To: "[email protected]" <[email protected]>
Subject: Re: [arin-ppml] Draft Policy ARIN-2013-6: Allocation of IPv4
and IPv6 Address Space to Out-of-region Requestors - Revised Problem
Statement and Policy
Text
Message-ID:
<[email protected]>
Content-Type: text/plain; charset="us-ascii"
-----Original Message-----
From: David Conrad [mailto:[email protected]]
Sent: Friday, September 13, 2013 4:13 PM
To: Kevin Kargel
Cc: [email protected]
Subject: Re: [arin-ppml] Draft Policy ARIN-2013-6: Allocation of IPv4 and IPv6
Address Space to Out-of-region Requestors - Revised Problem Statement and
Policy Text
Kevin,
On Sep 13, 2013, at 2:42 PM, Kevin Kargel <[email protected]> wrote:
> I still don't see how this is going to be enforceable. To my eye it would
> entail getting geo-data for all last mile routers that service IP's under
> ARIN control and having someone or a sophisticated AI bot continuously
> scanning the BGP tables to enumerate and verify the geo-locations of the
> endpoints.
>>Why wouldn't an assertion by the applicant that they run a network in the
>>ARIN region and perhaps a traceroute or two be sufficient to meet the
>>"operating a network located in the ARIN service region" requirement?
A traceroute would only satisfy an initial test. Trivially easy to set one up,
get your allocation, and then move the network to where you really wanted it.
> If the idea is just to ask people if they are in the ARIN governance area and
> make them promise to never move offshore (knowing it will not be subsequently
> policed) then I
submit that the algorithm is way too easy to game by unscrupulous operators
and will end up being a token policy that creates more bureaucracy and trouble
for legitimate operators.
>>I don't see this being significantly different than gaming the "operational
>>needs" requirement. I think the issue here is establishing a policy basis
>>upon which violations, when detected, can be addressed. If it is discovered
>>that someone is getting addresses to stockpile them for later sale, ARIN
>>policy exists to allow ARIN to revoke those addresses. This draft policy is
>>saying that if someone is getting addresses for use outside ARIN's region,
>>there would be a policy to allow ARIN to address that issue.
Just like ARIN follows up on the utilization requirement?
>>And, FWIW, I'll note that both AfriNIC and LACNIC (the remaining RIRs that
>>have not gone into "last /8" policy) require companies to demonstrate
>>in-region legal
status and network usage.
Maybe they have a way to test and enforce their requirement. If so perhaps it
is a model we should pattern after.
> If you can figure out a way to enforce *and* implement it I would support the
> policy, but until that time I have to vote "nay". I suspect that even if it
> were implemented enforcement would only be possible if it were written with
> an anti-grandfather clause.
>>Wait, I liked my grandfather... :) (sorry, not sure what an 'anti-grandfather
>>clause is)
Anti-grandfather means that the restrictions should equally apply to existing
allocations, and current allocations that are operating outside of the ARIN
region should be required to obtain allocations from their region and return
the ARIN allocation. Old allocations should not have a 'grandfather'
exemption. We would probably need to forgive their latest set of fees.
It would be onerously difficult to
separate the pre and post allocations for enforcement.
Regards,
-drc
------------------------------
Message: 7
Date: Fri, 13 Sep 2013 17:45:41 -0400
From: David Conrad <[email protected]>
To: Kevin Kargel <[email protected]>
Cc: "[email protected]" <[email protected]>
Subject: Re: [arin-ppml] Draft Policy ARIN-2013-6: Allocation of IPv4
and IPv6 Address Space to Out-of-region Requestors - Revised Problem
Statement and Policy Text
Message-ID: <[email protected]>
Content-Type: text/plain; charset="us-ascii"
Kevin,
On Sep 13, 2013, at 5:20 PM, Kevin Kargel <[email protected]> wrote:
> A traceroute would only satisfy an initial test. Trivially easy to set one
> up, get your allocation, and then move the network to where you really wanted
> it.
Yes. However, if this subterfuge was noticed, the policy would give ARIN the
capability to do something about it (if necessary), just like other ARIN
policies.
> Just like ARIN follows up on the utilization requirement?
I've been told ARIN has revoked address space for violation of policy.
> Anti-grandfather means that the
restrictions should equally apply to existing allocations, and current
allocations that are operating outside of the ARIN region should be required to
obtain allocations from their region and return the ARIN allocation.
My understanding of the policy proposal was that it was to apply to future
allocations because the out-of-region requests appear to be increasing with the
exhaustion of various RIR free pools. Historically, it has been ...
challenging to retroactively apply policy to pre-existing allocations. If such
retroactive application were desired (not going to comment one way or another
on that aspect), I'd suggest it should be a different policy proposal.
Regards,
-drc
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