Draft Policies and Proposals
Formal introduction on PPML on 29 January 2014
Origin - ARIN-prop-192
Draft Policy - 29 January 2014
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Draft Policy ARIN-2014-1
Out of Region Use
Date: 29 January 2014
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.
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.
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 don’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. ARIN’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.