Opposed as written.

I think the only way I could support something like this is if part(2) were done away with entirely and if part (1) were construed as codifying existing practice. If part (1) envisions additional validation/verification on ARIN's part beyond the current practice of requiring corporate documentation, I will require some persuasion before I can support it. At minimum, I would expect that all additional validation/verification intended be explicitly spelled out in advance.

John Springer

On Fri, 13 Sep 2013, Stumme, Terri L. wrote:

As the author of the original DRAFT policy proposal, I'd like to reiterate the original 
intent of the policy:  to enable ARIN staff to validate/verify requestors of address 
space who establish a "shell company" in the US for the sole purpose of 
acquiring ARIN resources.  ARIN has historically required legal incorporation within the 
region.  Due to the depletion of IPv4 there has been a significant increase in 
out-of-region requestors, and they are returning often (every three weeks) to request 
larger blocks.  ARIN staff does not have the capability or mechanisms in place to verify 
customer usage, nor to verify/validate physical contact information for these 
out-of-region entities.
If ARIN staff is unable to validate/verify requestors contact information or 
customer usage, enforcement of ARIN contractual obligations is significantly 
impeded.
Law enforcement simply wants to ensure that mechanisms are in place for 
verification/validation of ARIN's customers to avoid allocation to 
organizations/individuals who may intend to utilize IP address space for 
nefarious purposes, and that should this occur, accurate pointers (requested 
via subpoena) are available from ARIN for law enforcement to proceed with a 
criminal investigation.

-----Original Message-----
From: arin-ppml-boun...@arin.net [mailto:arin-ppml-boun...@arin.net] On Behalf 
Of Jeffrey Lyon
Sent: Friday, September 13, 2013 12:02 PM
To: William Herrin
Cc: arin-ppml@arin.net
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

On Fri, Sep 13, 2013 at 11:53 AM, William Herrin <b...@herrin.us> wrote:
On Thu, Sep 12, 2013 at 10:37 PM, Owen DeLong <o...@delong.com> wrote:
Majority is certainly more problematic than plurality. Plurality
might not be the best possible choice, either, but nobody, including
myself, has yet proposed a better alternative. The AC would certainly
welcome any improved language from the community if anyone has a better idea.

Hi Owen,

The intent of the policy proposal is to keep the use of ARIN addresses
in-region. I say this with the utmost respect: A 20% rule doesn't do
that. It does, however, create a new and potentially onerous
documentary burden on every registrant requesting addresses.

More, "plurality" makes the 20% rule needlessly complicated. I have to
keep 20% in the ARIN region... unless I have 23% in the RIPE region
and then I need to keep 24% in the ARIN region unless I have 30% in
the APNIC region in which case I need 31% in the ARIN region, but if
that drops the RIPE region down to 27% I can reduce the ARIN region
holdings to 28%.

Yuck!

I'm for keeping ARIN addresses in region. I'm against creating new and
potentially onerous documentary burdens. I'm doubly against creating
new and potentially onerous documentary burdens which fail to
plausibly achieve their defined goal.

If there is no community consensus for a "should be in region" number
in the 80% to 90% range then I think the draft should be abandoned. A
plurality rule combines the worst elements of the notion, not the
best.

Regards,
Bill Herrin


--
William D. Herrin ................ her...@dirtside.com  b...@herrin.us
3005 Crane Dr. ...................... Web: <http://bill.herrin.us/>
Falls Church, VA 22042-3004
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I agree that ARIN IP's must be reserved for in region use.

--
Jeffrey A. Lyon, CISSP
President, Black Lotus Communications
mobile: (757) 304-0668 | gtalk: jeffrey.l...@gmail.com | skype: blacklotus.net 
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