A non-member's thoughts on the web hosting policy.

[avb at korax.net]

It has been stated that ARIN pays attention to the public policy list and
wants to see more input from non-members.  I certainly hope so.  Here is
my input, as a non-member with an application for CIDR space currently
before ARIN.

We are a small-to-medium sized ISP/web hosting/colocation provider with a
steadily growing customer base.  From the very beginning, we have applied
strict IP assignment policies, both to our downstream customers, and to
our own internal network; always making the smallest subnet assignments
possible, using NAT everywhere possible, and in general doing our utmost
to squeeze every last IP address we could from the allocations we had been
given by our upstream providers.

We are multihomed.  Not that it does us much good right now.  In fact,
it's pretty darn useless for anything other than rudimentary
load-balancing our outgoing traffic.  But we multihomed with the
understanding that we will eventually qualify for portable space.

For some time, we had been looking forward to the day when we would
finally qualify for an allocation from ARIN.  When ARIN lowered the
minimum requirements for multi-homed sites, it was naturally welcome news
for us.

We have now finally reached the point where we can qualify for a /20, and
given the amount of effort we put into efficiently managing our address
space, we didn't anticipate having too much trouble getting an allocation.

Now that we have been blind-sided with the new web hosting policy, I want
ARIN to be aware that I am more than a little upset.  I am, in fact,
_extremely_ frustrated by this turn of events.

Although I can fully appreciate why ARIN thought it necessary to introduce
this policy, it is, in our view, _grossly_ premature.

Firstly and foremost, we believe that it is utterly unconscionable of ARIN
to dictate such a policy until a serious, concerted effort has been made
to reclaim unused and underutilized address space from legacy holders.  I
have scoured the ARIN web site and I have yet to find any indication of an
active effort in that direction.  _That_ is the policy that is begging to
be drafted, implemented, and enforced.  It defies all logic to continue to
maintain vast numbers of legacy class A, B and C allocations that are not
utilized according to ARIN's own policies, and to maintain allocations to
organizations that don't even exist anymore, while making it ever more
difficult for newer organizations to obtain allocations.

It is equally difficult to understand why ARIN decided that large
providers which somehow find ways to burn through /14s in less than 3
months should qualify for even larger blocks of addresses.  It seems to me
those providers are the best candidates for implementing IP conservation
measures.

If ARIN is going to ask its members to be efficient with their address
assignments, then ARIN has a duty and a responsibility to its members and
to the Internet at large to do the same by reclaiming unused space and
enforcing its policies in a uniform and equitable manner.  Before bringing
in new policies that further restrict how we are to run our networks and
conduct business in general, ARIN should implement procedures to reclain
unused space, and put them into practice.  Not to do so would be nothing
short of hypocritical.

ARIN _must_ consider the real-world implications this broad, heavy-handed
decision will have for its customers, and, perhaps even more importantly,
for its yet-to-be customers.  I understand it's not part of ARIN's mandate
to consider business issues.  But let's face it: most of us are running
businesses.  We have customers with expectations which do not change
easily.  We have time and money invested in established processes.  And we
have fiscal constraints to work within.  None of this can change
overnight.  And more importantly, one does not expect an organization like
ARIN to make a pronouncement which forces sudden and drastic change onto
an already highly competitive and volatile marketplace.

I *implore* ARIN to reconsider this policy.  If it was done to conserve
remaining address space, then the time for this has not come yet.  The
time for this will not come until the majority of dead address space has
been reclaimed, returned to the available pool, and reassigned.

If this absolutely must be done, a phased approach would be infinitely
more preferable.  Give us time to adapt.  We suggest that organizations
which would otherwise qualify for an allocation, without this policy,
should receive at least one more allocation, with a notice that no further
allocations for IP-based hosting will be made -- possibly ever, or
possibly after a certain date.

Similarly, organizations such as ours, which are applying for the first
time, which qualify under the multi-homed policy and for whom receipt of
their first portable address space is _vitally_ important, should be
allowed at least one allocation, with no further allocations to be made
for IP-based hosting.  I think this is a reasonable compromise that will
slow down the consumption of addresses without drastically changing our
business realities overnight.

-- 
Alex Bulan <avb at korax.net>
Network Administrator
Korax Online Inc.