On 24 January 2014 the ARIN Advisory Council (AC) accepted
"ARIN-prop-192 Out of Region Use" as a Draft Policy.
Draft Policy ARIN-2014-1 is below and can be found at:
https://www.arin.net/policy/proposals/2014_1.html
You are encouraged to discuss the merits and your concerns of Draft
Policy 2014-1 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-2014-1
Out of Region Use
Date: 29 January 2014
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 to discuss a proposal that
clearly permits out of region use without limits, beyond those already
existing in policy.
Permitting out of region use, however, poses issues that have to be
addressed by policy and adjustments to operational practice. Out of
region use needs a clear definition and any operational practices based
on that definition must not be unnecessarily burdensome. It is
significantly more difficult and costly for ARIN Staff to independently
verify the justification and utilization of resources that are
reassigned or otherwise used outside of the ARIN service region. There
needs to be recognition of this difference in policy and associated
operational practices, especially the cost differential when there is
more than an incidental amount of out of region use.
Policy statement:
Create new Section X;
X. Out of Region Use
ARIN registered resources may be used outside the ARIN service region
and such use is valid justification for additional resources. Resources
are considered to be used outside the region if any of the following are
located outside the region.
A. The user or customer billing address
B. The user or customer service address
C. The technical infrastructure address, such as the point of presence
(POP), data center, or other similar location
X.1 Verification of Out of Region Use
The utilization of ARIN registered resources must be verified when
evaluating a request for additional resources or during a resource
review, including any resources used outside the ARIN service region.
Resources used outside the region must be verified to no less than an
equivalent standard as resources used within the region. To this end
ARIN, in its sole discretion, may engage independent external entities
to assist it in the verification of information related to any resources
used outside the region.
X.2 Incidental Use
Out of region use of ARIN registered resources by an organization that
totals less than an equivalent of a /20 of IPv4, a /36 of IPv6, and 10
ASNs are considered incidental use and as such are accounted for as if
used within the ARIN service region.
X.3 Critical Infrastructure
Resources justified through critical infrastructure policies are
accounted for as if used within the ARIN service region, regardless of
their actual location of use.
X.4 Multi-Instance Use
Any resources used simultaneously in multiple locations, such as an
anycast prefix or ASN, are accounted for as used outside the region,
only if they are exclusively used outside the region.
6. Comments:
a. Timetable for implementation: Immediate
b. Anything else
Current policy is ambiguous on the issue of out of region use of ARIN
registered resources. The only guidance on the issue in current policy
is in Section 2.2, that defines the term RIR; “... The primary role of
RIRs is to manage and distribute public Internet address space within
their respective regions.” Some in the community believe this means out
of region use should be at least limited or restricted while others
believe this is only intended to focus efforts within the region and not
define where resources may be used.
Several other policy proposals have explored restricting or otherwise
limiting out of region use. None of these proposals gained consensus
within the ARIN community. During the latest of these proposals,
ARIN-2013-6, several standards were explored, a majority of use within
region, a plurality of use within region, and some discussion of a
minimum of 20 percent use within region. It was felt that each of these
standards would interfered, to one extent or another, with the
legitimate operations of multi- or trans-regional networks.
Section 2.2 tells us, the primary purpose of the RIRs are to manage and
distribute resources within their regions. None the less, there have
always been networks that donÂ’t neatly fit within the regions created
by the RIR system. These legitimate trans-regional networks are operated
by international businesses or global service providers, many of which
are based within the ARIN region. Prior to IPv4 run-out, these
trans-regional networks requested resources from ARIN for use both
inside or outside the region, as long as the requests were justified by
need.
As a result of IPv4 run-out, many in the community want to restrict out
of region use to prevent ARIN resources from going to networks without a
real technical presence in the ARIN region. However, any attempt to
limit or restrict such out of region use inevitably will affect these
legitimate trans-regional networks. Further, even the most restrictive
regional use requirements will not significantly prolong the
availability of IPv4 resources within the ARIN region. Therefore,
attempting to restrict or limit out of region use of resources, even if
it were for IPv4 only, is ineffective, inefficient, and overly
burdensome to important elements of the global Internet.
The major concept behind this proposal is to allow out of region use
without any limits, other than those already in policy, but bring an
economic factor to play on the issue. It requires ARIN to verify out of
region use to no less than an equivalent standard as in region use, and
enables ARIN to engage external entities to assist in this verification.
It is expected ARIN will have agreements with all such external entities
to ensure the confidentiality of all supporting documentation is preserved.
ARIN engaging external entities to assist in verification of out of
region use is mostly an ARIN business issue, and not primarily a policy
issue. However, today there is a general assumption that such
verification for in region use is done almost exclusively in house at
ARIN. Making this issue clear in policy follows a principle of least
surprise, as the use of such external entities is likely to be
frequently necessary to verify out of region use, especially in parts of
the world where English is not the primary language. Or put another way,
use of an external entity when verifying out of region use is more
likely to be the rule rather than an exception.
There are additional expenses and complexity involved in verifying out
of region use, as a result of language and logistical barriers that the
regionality of the RIR system was originally conceived to mitigate. In
addition, section 2.2 is clear that providing resources for out of
region use is, at best, only a secondary role for ARIN. As a result, out
of region use should not significantly burden the primary role of
providing resources for use within the region. These factors justify a
recommendation to the Board of Trusties to create a separate fee
structure for out of region use, creating the aforementioned economic
factor.
This economic factor and the recommendation for a separate fee
structure, are again mostly ARIN business issues, and not part of policy
in general. However, this is one of those instances where policies and
fees are intertwined.
It seems reasonable that this economic factor should be applied only to
those that make substantial use of ARIN registered resources outside the
region, and not to those that primarily use resources within the region.
This proposal defines incidental out of region use, to ensure that
trivial, insignificant or otherwise incidental use are exempt from the
discussed economic factor, and are accounted for as if used within the
region.
Some amount of out of region use should be considered normal even for a
network primarily based within the ARIN region. For example, numbering a
global backbone that provides global access necessary for in region
customers. Also, the other RIRs have minimum requirements to justify an
initial allocation or assignment, similar to ARIN. These and other
examples and issues, justify allowing some minimal amount of out of
region use to be accounted for as if it were in region use. The
currently proposed policy statement, X.2, defines incidental use in
terms of an absolute thresholds for each type of resource.
Another option would be a percentage based threshold, say 20%. However,
a percentage based threshold has the disadvantage that even a minimal
change in usage can cause the ratio between in region and out of region
use to change, potentially causing an oscillation around this threshold.
This creates significant uncertainty for organizations as to if the
discussed economic factor will apply to them, or not. Where as once an
absolute threshold has been crossed by a significant amount, it is
highly unlikely that any additional changes in usage will cause an
oscillation around the threshold, providing much more certainty for most
organizations.
Additionally, the proposal deals with a couple special cases in X.3 and
X.4. Due to the relatively small resource impact and high importance to
overall Internet stability; resources for critical infrastructure are
also exempt from the discussed economic factors, and are accounted for
as if used within the region. Anycast prefixes, and other resources used
simultaneously in multiple locations, are considered as used outside the
region only when they are exclusively used outside the region. Or put
another way, as long as at least one instance is located within the
region, they are considered used within the region, regardless of how
many other instances are located outside the region. Both of these
special cases have an overall positive impact on the Internet and should
not be discouraged in anyway by this policy, lumping them in with
general out of region use could be a disservice to the Internet and
unnecessarily burdensome.
In summary, this proposal ensures that global organizations or global
service providers base within the ARIN region may receive resources to
operate their global network solely from ARIN, if they wish to do so. As
long as the utilization of the out of region resources are verified to
no less than an equivalent standard as in region resources. This is
particularly important for IPv6; requiring organizations get IPv6
resources from multiple RIRs, or even making it appear that they should,
will result in additional unique non-aggregatable prefixes within the
IPv6 route table, rather than minimizing them, which one of the policy
objectives for IPv6.
Finally, a separate but somewhat related issue; regardless of where ARIN
registered resources are used, inside or outside of the ARIN service
region, organizations must first qualify to receive resources from ARIN.
ARINÂ’s current operational practice is that an organization must be
formed within the ARIN service region in order to qualify to receive any
resources from ARIN. The issue of who should be eligible to receive
resources was commingled with out of region use in ARIN-2013-6. It was
felt these issues should be considered separately. Therefore, the issue
of who should be eligible to receive resources is purposefully not dealt
with by this proposal, and if any changes are necessary there should be
separate policy proposals to deal with this issue independently.
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