Do we really have to say opposed in principal instead of just wording every draft for it to be considered applicable response?
-Blake On Thu, Sep 12, 2013 at 1:01 PM, David Farmer <[email protected]> wrote: > There has been only one comment on this revised text, the AC needs more > input from the community regarding this revised text. Next Thursday the AC > must voting if it should promote this Draft Policy to Recommended Draft > Policy status before the October ARIN meeting. A Draft Policy cannot go to > Last Call until it has gone to a Public Consultation as a Recommended Draft > Policy. > > Please provide your feedback, even if its as simple as you support the > policy or not. > > Thank you. > > > On 9/4/13 16:25 , ARIN wrote: > >> Revised text for ARIN-2013-6 is below and can be found at: >> >> https://www.arin.net/policy/**proposals/2013_6.html<https://www.arin.net/policy/proposals/2013_6.html> >> >> 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<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<https://www.arin.net/policy/proposals/index.html> >> >> Regards, >> >> >> Communications and Member Services >> American Registry for Internet Numbers (ARIN) >> >> >> ## * ## >> >> Draft Policy ARIN-2013-6 Allocation of IPv4 and IPv6 Address Space to >> Out-of-region Requestors - Revised Text (V2) >> >> Date: 4 September 2013 >> >> Problem Statement: >> ARIN number resources should be used primarily in the ARIN region, for >> ARIN region organizations. There is currently no explicit policy guiding >> staff in this area, this proposal seeks to correct that. >> >> Policy Statement: >> Create new policy Section X. >> >> X. Resource Justification within ARIN Region >> Organizations requesting Internet number resources from ARIN must >> provide proof that they (1) are an active business entity legally >> operating within the ARIN service region, and (2) are operating a >> network located within the ARIN service region. In addition to meeting >> all other applicable policy requirements, a plurality of resources >> requested from ARIN must be justified by technical infrastructure and >> customers located within the ARIN service region, and any located >> outside the region must be interconnected to the ARIN service region. >> The same technical infrastructure or customers cannot be used to justify >> resources in more than one RIR. >> ### >> >> Authors Comments: >> >> Although we represent law enforcement, and have brought forth this issue >> based upon our concerns and experience from a law enforcement >> perspective, this is a problem in which the entire ARIN community has a >> stake. >> >> As reported at the last meeting in Barbados, ARIN staff is having >> difficulty verifying organizations out-of-region. In many of the cases, >> particularly in VPS (Virtual Private Service), the only information >> received on these organizations by ARIN is a customer name and IP >> address. This information cannot be properly verified by ARIN. Accuracy >> of registration data is critical to not only law enforcement, but the >> greater ARIN community as it relates to abuse contact and complaints. In >> fact, most issues facing law enforcement are also shared by legitimate >> companies attempting, for instance, to identify an organization that has >> hijacked their IP address space. >> >> The expedited depletion of IPv4 address space in the ARIN region >> certainly seems to negatively impact those organizations currently >> operating in the region that may need to return to ARIN for additional >> IPv4 address space. While law enforcement¹s concern is that criminal >> organizations outside of the ARIN region can easily and quickly request >> large blocks of IPv4 address space from ARIN, organizations that are not >> truly global organizations, but specific national companies from the >> RIPE and APNIC regions, also have this capability which is detrimental >> to true ARIN region organizations. >> >> This policy proposal is re-enforcing practices the ARIN staff currently >> employs to ensure that ARIN IP space is used for and by companies that >> are legitimate and have a legitimate presence in the ARIN region. This >> policy will assist in defining clear criteria that will be helpful to >> ARIN staff and the community. >> >> The primary role of RIRs is to manage and distribute public Internet >> address space within their respective regions. The problem brought forth >> here clearly undermines the current RIR model; if any organization can >> acquire IP address space from any region, what then is the purpose of >> the geographical breakdown of the five RIRs? >> >> Advisory Council Comments: >> >> The term "Internet number resources" or more simply "resources" should >> be used instead of "IP Blocks" to more accurately reflect the totality >> of the Registry. This implies both IPv4 and IPv6, as well as ASNs. >> While Internet registries are organized on a regional basis, policy must >> recognize that many networks, services and operations are trans-regional >> and it would be burdensome and impractical to attempt to strictly >> enforce territorially exclusive allocations. Therefore, policy should >> seek to balance the regional structure of address allocation with >> flexibility of service provision, by ensuring that ARIN¹s resources are >> primarily aligned with the ARIN service region but facilitate >> flexibility and efficiency of use by applicants from any region. >> There are concerns that out of region organizations should be able to >> request resources for use within the ARIN service region. The proposed >> text accommodates this issue by requiring only proof that an >> organization is "legally operating within the ARIN Service Region". This >> includes business entities formed in the region, or other business >> entities with legal branch offices within the region. So, as long as an >> out of region organization is "legally operating within the ARIN Service >> Region" they can request resources from ARIN. >> >> Current operational practice is to require an organization be formed >> within the ARIN service region. However, if this were applied by all the >> RIRs, a global network would be required to have a minimum of five >> subsidiaries, one formed in each of the five RIR regions, this seems >> overly burdensome. Good resource policy should consider the consequences >> of all RIRs adopting the same policy. >> >> Previous discussions of the topic indicated that it is difficult to >> enforce and undesirable for many in the community to dictate where >> resources are to be used once they are allocated. A strategy to deal >> with this is to focus the policy on the technical infrastructure and >> customers used to justify the requested number resources from ARIN, as >> opposed to where resources are actually used once allocated. This is a >> subtle but important distinction. >> >> While resources received from ARIN may be used outside the ARIN region, >> a common technical infrastructure must interconnect the use of these >> resources to the ARIN region. This provides a necessary nexus with the >> ARIN service region for such out of region use. Therefore, if a discrete >> network is operating within another region, not interconnected to the >> ARIN region, then resources for that discrete network should be >> requested from that region's RIR. >> >> A concern was raised that this policy shouldn't limit or interfere with >> outbound inter-RIR transfers. If we focus on what justifies a request >> for resources from ARIN, outbound inter-RIR transfers shouldn't be >> affected, as they are clearly based on the receiving RIR's policies. >> >> From previous discussions of the topic, "double dipping" should not be >> allowed, that is using the same technical infrastructure or customers to >> justify resources from ARIN and another RIR at the same time. >> The legal jurisdiction an organization is formed in doesn¹t necessarily >> reflect the jurisdictions in which it operates, or even that it operates >> a network in a jurisdiction. This implies that we should have both >> technical and legal requirements regarding operating within the ARIN >> service region in order to receive resources. >> >> The original text used the term "majority", seeming to describe a >> "simple," "absolute" or "overall" majority, which means greater than >> 50%. Many organizations don't have greater than 50% of their users or >> customers in any one region. A "plurality", "relative majority", >> "largest of", or more specifically "more than any other RIR's service >> region" seems to be the intended and appropriate meaning of the term >> "majority" in this context. Let's clarify that intent by using the term >> "plurality". >> >> The intent is not to require an organization to have an overall >> plurality of its technical infrastructure and customers within the ARIN >> service region. Rather, it is to ensure that the plurality of currently >> requested resources is justified from within the ARIN region. If an >> organization¹s primary, or largest, demand for resources is in another >> region then the organization should request resources from that region's >> RIR. >> -- >> >> ## * ## >> > > -- > ==============================**================== > David Farmer Email: [email protected] > Office of Information Technology > University of Minnesota > 2218 University Ave SE Phone: 1-612-626-0815 > Minneapolis, MN 55414-3029 Cell: 1-612-812-9952 > ==============================**================== > > ______________________________**_________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List ([email protected]). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/**listinfo/arin-ppml<http://lists.arin.net/mailman/listinfo/arin-ppml> > Please contact [email protected] if you experience any issues. >
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