LACNIC Staff's Interpretation of the Proposal
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LACNIC staff understands this is a first approximation to a final proposal and that several details must be defined prior to its implementation. Nevertheless, the impact of this preliminary idea will be analyzed. Once the final proposal is submitted, a new impact analysis will be conducted to update the one presented today.
Applicability
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This would apply when an organization proves it has operations in more than one region.
However, it would be necessary to specify how to the organization would prove “it has operations in more than one region,” i.e., whether this means “being legally incorporated in more than one region.”
Modifications to the current text
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Before this analysis can be completed, it is necessary to define which sections of the manual the proposal would seek to modify.
We understand this might be section 9. Global Policies.
LACNIC Staff Comments:
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LACNIC believes this proposal would have a significant impact on all RIRs.
The following is a list of some important aspects that should be considered:
• First, the creation of a new RIR must follow the criteria established by ICANN (ICP-2: Criteria for Establishment of New Regional Internet Registries https://www.icann.org/resources/pages/new-rirs-criteria-2012-02-25-en.
• A global policy for the creation of a GIR has not been defined, whereas it has been established that each region should be served by a single RIR. Therefore, in addition to adjustments to the global policies, it would be necessary to modify ICP-2.
• In any case, the creation of a new ‘global RIR’ (GIR) managed by the five RIRs would involve coordination among all the RIRs, as well as adjustments to their resource assignment systems, among others.
• In the event of incompatibility between the requirements established by two different regions, it is not clear what rationale the GIR would use to decide which requirements the organization should meet, whether those of one RIR or those of the other.
• Currently, each RIR has different levels of flexibility when an organization needs to use the resources it has been assigned in more than one region. As the case may be, it would not always be necessary to request resources in each of the RIRs.
• According to the proposal, “The GIR will assign global IP (IPv4 and IPv6) address resources.” However, it would not be possible to assign IPv4 resources as there are no longer any IPv4 blocks available in the IANA pool which might be assigned to the new GIR.
Impact of the policy on the registration system and address management
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This proposal would involve adjustments to the registration systems of LACNIC and the other RIRs.
It would be necessary to create a new registration system for the GIR, which would be maintained and coordinated by the five RIRs.
The following is a global proposal for assigning resources at global level.
It proposes the creation of a virtual RIR that would be responsible for assigning IP addresses and Autonomous System Numbers to organizations without a well-defined, single regionalization (i.e., to organizations that are global by nature and can effectively prove they have operations in more than one region).
There are currently several organizations operating in more than one region which request address resources from one RIR and then use those same addresses (even the same Autonomous System) in more than one region outside the one where such resources were obtained. This is mostly due to economic reasons, as otherwise they would have to request IP and ASN resources in each of the regions in which they operate.
In certain cases, they also use tunnels to expose a single, unified network to the Internet, while in others they simply publish part of the blocks from one site and part from others, sometimes even using the same Autonomous System Number.
As we know, this has the potential to cause various technical issues with Internet routing and additional difficulties both when operating these networks and when interconnecting with them.
I also believe that these cases may be further increased by the proliferation of organizations operating globally distributed networks of Internet of Things devices (IoT) or in case of some possible future evolution of global mobile telephony.
Because of the above, I am proposing a solution that would create a virtual Global Internet Registry (GIR) which would be charged with handling resource assignment requests from organizations that require such resources and can demonstrate this need.
The implementation (as well as the need itself) is an open topic which I believe must be discussed by the community. However, I will present my initial idea which I hope will serve as a starting point for what may become a good solution to a problem that is not (at least in its origin) of a technical nature.
A sixth registry would be created, one which instead of being regional (RIR) would be of a global nature (GIR). This registry would be virtual, so it would not imply the creation of a new organization and would be operated by the five existing Regional Internet Registries (RIRs) in a coordinated manner.
This GIR would receive resources – both IP addresses and Autonomous System Numbers – from the IANA (now PTI) and assign them based on the resource assignment policies in force in each region, with the following provisos:
- The organization applying for resources must prove that it maintains operations in more than one region and comply with the requirements for the assignment of resources of all the regions in which it operates. If the requirements of two different regions are incompatible, the GIR will be responsible for specifying which of the requirements presenting incompatibility the organization must meet (the GIR must justify its decision).
- The assigned resources will be registered in a GIR registration system which will be maintained and coordinated by the five existing RIRs. These resources will be registered as global resources, with no specific link to any particular region.
- The GIR (made up and operated by the five RIRs) will have the ability to define a membership fee scheme for requesting resources, for which their global nature will be considered. For this I suggest a cost that is higher than that of requesting resources from a single RIR, but lower than the cost of applying for membership in each region where the applying organization has operations. This scheme should be designed and proposed by the GIR to each of the RIRs, where it should be approved using the mechanism each of the five RIRs has for approving membership fees and characteristics.
- When assigning resources, the GIR will assign as many Autonomous Systems as are necessary for the requesting organization to operate its networks in all the regions in which it maintains operations. For this, the organization must submit a global general diagram of its networks and a global addressing plan, in addition to the requirements of the RIRs in each region where it operates.
The GIR will assign global IP (IPv4 and IPv6) address resources, which may be used by the requesting organization in any of the global ASNs it holds, always according to the addressing plan submitted to the GIR at the time of the request.
If an organization which has been assigned global resources wishes to modify its general network structure or address plans in such a way that it affects or modifies the geographical distribution presented at the time of the last request, the organization must present an updated addressing plan and general distribution of its networks.
The implementation (as well as the need itself) is an open topic which I believe must be discussed by the community. However, I will present my initial idea which I hope will serve as a starting point for what may become a good solution to a problem that is not (at least in its origin) of a technical nature.
A sixth registry would be created, one which instead of being regional (RIR) would be of a global nature (GIR). This registry would be virtual, so it would not imply the creation of a new organization and would be operated by the five existing Regional Internet Registries (RIRs) in a coordinated manner.
This GIR would receive resources – both IP addresses and Autonomous System Numbers – from the IANA (now PTI) and assign them based on the resource assignment policies in force in each region, with the following provisos:
- The organization applying for resources must prove that it maintains operations in more than one region and comply with the requirements for the assignment of resources of all the regions in which it operates. If the requirements of two different regions are incompatible, the GIR will be responsible for specifying which of the requirements presenting incompatibility the organization must meet (the GIR must justify its decision).
- The assigned resources will be registered in a GIR registration system which will be maintained and coordinated by the five existing RIRs. These resources will be registered as global resources, with no specific link to any particular region.
- The GIR (made up and operated by the five RIRs) will have the ability to define a membership fee scheme for requesting resources, for which their global nature will be considered. For this I suggest a cost that is higher than that of requesting resources from a single RIR, but lower than the cost of applying for membership in each region where the applying organization has operations. This scheme should be designed and proposed by the GIR to each of the RIRs, where it should be approved using the mechanism each of the five RIRs has for approving membership fees and characteristics.
- When assigning resources, the GIR will assign as many Autonomous Systems as are necessary for the requesting organization to operate its networks in all the regions in which it maintains operations. For this, the organization must submit a global general diagram of its networks and a global addressing plan, in addition to the requirements of the RIRs in each region where it operates.
The GIR will assign global IP (IPv4 and IPv6) address resources, which may be used by the requesting organization in any of the global ASNs it holds, always according to the addressing plan submitted to the GIR at the time of the request.
If an organization which has been assigned global resources wishes to modify its general network structure or address plans in such a way that it affects or modifies the geographical distribution presented at the time of the last request, the organization must present an updated addressing plan and general distribution of its networks.
It is estimated that this proposal requires broad regional and global discussion at RIR level.
TimetableAs much as the global policy requires.
ReferencesThe issue of regional resources being used outside the region where they are obtained has been discussed at various times in both technical and public policy forums.
Presented at:LACNIC 29 (30/04/2018)