[ppml] Re: ARIN Policy Proposal 2002-7

Whipple, Scott (CCI-Atlanta) Scott.Whipple at cox.com
Fri Sep 27 12:28:03 EDT 2002


 

 
Proposal 2002-7


9/24/2002 Bernard:
Arin should reduce the current minimum IP allocation requirement to /21 - /24 if an organization is multihomed and actively using AS number(s).
Arin may periodically inquire and verify that the multihomed organization
is actively using AS number(s). ARIN may reclaim its IP's from
organizations that no longer are multihomed and/or stop using AS
number(s).
The following new fee schedule for /21 - /24 should be implemented as
 follows (based on the current fee schedule with a smaller minimum):
$400.00 per year for /23 - /24
$1000.00 per year for /21 - /22
 
9/25/2002 Alec
I do not believe the proposed fees would be fair to either ARIN or other 
ARIN members.  I don't think the amount of work that the ARIN staff would 
need to perform for allocations of this size jibes with the proposed fees.
 
 
9/26/2002 Bernard:
Can you explain how much work is involved for ARIN to perform allocations? If you believe it is too much work for the stated fee, our company will be glad to take over allocations of a smaller size at half the stated fees, maintaining and updating the necessary database and any work needed to process smaller allocations. As an example, NSI (Network Solutions) used to charge the public $100/two years for one domain and after competition was introduced, the prices are now as low as $16/two years.
 
ARIN's policy should be made so it's fair to the general public not ARIN staff and its members. Your above statement of "not being fair to ARIN's members" is the clear indication that you lien toward implementing policies that benefits current ARIN's members not general public. I don't think that it's fair for ARIN to have you in their Advisory Counsel since you only have the ARIN's and its best interest in mind not the general public.
[Whipple, Scott (CCI-Atlanta)] 
I think this statement is exactly why we have an organization like ARIN.  Of course your company would be glad to take over allocations (as would the one I work for) it has the potential to be very profitable.  That's why ARIN is a non-profit organization.  You don't only have the work that is involved in updating the database but you have the actual evaluation of the requests.  Making sure that the requester does actually meet the requirements.  If this policy were to be passed I think the community should realize that ARIN will need to at least double the size of there registration services dept. because of the new amount of requests that would come in.  I don't believe that should be a consideration in adopting this policy but if trying to decide what the fee should be that will have to be a factor.
 
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9/24/2002 Bernard:
1. ARIN's current minimum IP allocation policy has a direct correlation
with the size of a company. Generally a company that uses a  /20 IP
allocation has a larger network and customer base, therefore they would be
considered in the category of large size companies. This policy currently
discriminates, puts a small business at a disadvantage and promotes and
 helps to monopolize large ISP's and upstream providers.
 
9/25/2002 Alec:
ARIN's policies were not crafted to discriminate against anybody.  They 
were crafted to help manage the resources that ARIN has responsibility for 
(autonomous system numbers and IP addresses).  Contrary to your point 
below, the issue with routing table size relates to routing table 
processing (CPU cycles), and not memory.

9/26/2002 Bernard: 
I don't believe that ARIN and ICANN are elected federal administrative agencies; hence, they have been invoking the techniques of administrative law and implementing important public policies.  They also have invoked the techniques of consensus; however, they do not have a working procedure in place that can determine and recognize consensus. There seems to be a small group of people and/or volunteers who are not publicly elected and they are arriving at policies that affect millions of people. There are also ethical questions such as its membership influence and a monopoly in IP address allocations.
I would like to find out how ARIN has arrived at the consensus of setting the /20 minimum IP implementation. I do not believe that this policy which affected millions of people has been implemented in our ordinary way of invoking public policymaking.  I guess we are dealing with technology and the public does not understant it, so they accept the policies trusting that someone arrived at it by our ordinary public consensus procedure. The public enjoys a government-free-Internet; however, if the current Internet's governing body takes advantage of its power and invokes bureaucratic methods, I believe the public would prefer that our government helps to provide fair and balanced policies.   For example, anytime I have called ARIN's registration services, I've been imediately turned away by their staff; the first thing they say is: "You are not qualified to receive IPs from us; you need to get your IPs from your upstream provider." Unless the caller is WorldCom or some recognized company name, I believe that ARIN has the pre-determined decision to not provide IPs to non-familiar company names and assuming that they are a small company. It seems that no startup small company is ever going to qualify for ARIN's initial IP request. 
ARIN has taken the responsibilities of IP addresses and policymaking. There have been policies regarding minimum IP allocations of /20; however, I do not see any data analysis from ARIN that can explain how they arrive at this decision. Since there are restrictive policies like a minimum /20 in place today, the public should have at least the following data analysis:
[Whipple, Scott (CCI-Atlanta)]  
 
I don't personally know how the decision of a /20 came about as the minimum and would also like the history, but ARIN staff is employed to enforce the policies that have been adopted by the ARIN membership.  If they told you that you don't meet the minimum requirements I don't think it's because of your organizations name it's probably because you don't meet the minimum requirements that are set right now.  I think it also has to be stated that you don't have to get IP space from ARIN to be a member.  Anyone that has $500 can be a member.  No matter what the size of your company you only get one vote on policy issues so the largest ISP has no more influence then Ma and Pa ISP when it comes to creating or modifying ARIN guidelines.  
  
 1. What is the current global IPv4 usage?
2. What is the maximum capability of IPv4 usage? 
3. What is the current global IP allocation?
4. How many IPs are available in each regional registries?
5. What is the growth rate per year for IPv4?
6. What are the new capabilities of our current routers?
7. What is the current usage for IPv6?
8. How many equipment manufacturers are supporting IPv6?
9. When do you predict we will be using IPv6 as our main IP usage?
10. If IPv6 should take care of our current IP shortage, why does ARIN continue with its extremly restrictive policies in allocating and promoting IPv6?
[Whipple, Scott (CCI-Atlanta)] 
I'm sure you can find the answer to any of these questions if you dig hard enough.  If you would like to see them on the ARIN website then I think that is a valid request.  I also think some of these questions may be debatable and I would only be for putting information on ARIN's website that are true statistics. 
 
 
I suggest inviting several non-partial technical, governmental and educational organizations that would analyze the foregoing items and make a determination that ARIN's current restrictive policy of a minimum /20 allocation is made for the best interest of our general public, not just for the benefit of ARIN's organization and its members.
[Whipple, Scott (CCI-Atlanta)] 
I'm sure the general public has no clue who ARIN is and if they do they have all the right in the world to be a member.  I don't think there is such thing as a non-partial technical, or governmental organization that's why policies and guidelines are proposed by the ARIN membership who should be the people that the policies directly effect.  I would like to say again that anyone can be an ARIN member so my suggestion would be if ARIN policies have an affect on your organization then pay the $500 and become a member so you can vote.  
 


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9/24/2002 Bernard:
4. The global routing table and its minimum allocation requirement must
be investigated by several third party technology companies, who are
non-partial and do not benefit from ARIN's decision in any way. They
could determine what is the best minimum requirement in order for the
 Internet to run at its optimum and without any routing table problems.
 
9/25/2002 Alec:
Given this suggestion I don't see why a specific minimum of /24 was 
proposed in this proposal.  However, ARIN is a perfect example of a body 
that does not benefit from ARIN's policies.  ARIN has an advisory council 
that is elected by its membership and whose job it is to consider the 
technical impact of ARIN's policies.  In the interest of disclosure, I 
currently sit on the ARIN AC.


9/26/2002 Bernard:
As you mentioned, ARIN's current advisory council is elected by its members. This means that ARIN's current advisory counsel is partial and could implement and favor policies that benefit its members. There should be an advisory counsel and/or technical and/or government organizations that are non-partial to ARIN and/or its members who could analyze and study ARIN's policy carefully and determine its technical and/or public communications and trade impact. 
ARIN also claims that the Internet community voted for their current policies. I believe that ARIN's current restrictive policies, that are directly affecting general public, are implemented by a small group of people. ARIN's policymaking is not exercised within our ordinary understanding of public power and public policymaking.
[Whipple, Scott (CCI-Atlanta)] 
Again this entire reasoning doesn't have much weight because anyone in the general public that has concern about ARIN policies can  be involved in shaping them.  I also believe that if ARIN did start to assign blocks longer then a /20 you would find that there are many ISPs that would filter them out.  This is not something that can be voted on or discussed.  It is up to the individual organizations on how they set up there filters.  I'm not sure how it would help companies to get smaller blocks that probably are not going to be routable anyway.   I know routing is not an ARIN concern but I think if we are going to change an existing guideline we should take it in consideration.
 
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9/24/2002 Bernard:
 5. ARIN's current policy of the minimum requirement of /20 addresses
 promotes IP usage and reduces the ability to conserve IPs, such as
 virtual hosting, for web sites. Companies now have to come up with
 wasteful uses for IPs that they don't really need, just to qualify for the
current policy minimum.
 

9/26/2002 Alec:
 I don't think I follow this.  Is the assertion that if IP addresses are 
essentially available with no requirements that people will use them more 
wisely?  I believe history has shown that engineers typically do what is 
easiest, and often it is easiest to be wasteful with address space 
reguardless of the available supply.



9/26/2002 Bernard:
If the only way that small companies and/or organizations are going to be approved for ARIN's restrictive IP requirement is to use a lot of IP addresses. Small companies and/or organizations have no other choice other than to switch their web servers from "virtual hosts" to "regular host per IP" and stop using NAT in order to qualify for ARIN's minimum IP requirements.
[Whipple, Scott (CCI-Atlanta)] 
Your example here doesn't really help your cause.  At this point it is not against ARIN policy to do IP based web hosting.   If there are organizations that have wasteful IP practices to get their initial block from ARIN it should directly effect the ISP that organization is getting space from.   ARIN should also be able to see wasteful IP practices when evaluating an organizations request.  I would think that this has a direct relation to an approval for an initial block as well as for an additional block to an ISP that continues to give space to a wasteful organization.
 
 

9/24/2002 Bernard: 
8. Theoretically, there are 4 billion IPv4 addresses available.  Out of
that, only a small fraction of them (Approx. 100 million) are being used
and approx. 2.3 billion are being allocated. This makes the current
minimum allocation policy not practical. Large organizations are sitting
on an exorbitant amount of IP addresses that they are not using and/or not
capable of ever being used. As an example, there is a company that owns
approximately 7 million IP addresses and has roughly 153,000 employees
(employees as of Nov, 1999). What is the justification for receiving
such large IP space, when a small business is not allocated any IP space?


9/25/2002 Alec:
Poor historical allocation policies should not be justification for making 
the same mistakes all over again.
 

9/26/2002 Bernard:
Why doesn't ARIN go to the companies that are squandering and wasting the valuable IPs that in shortage, and ask them to be returned; that would be a good policy. Yes, the allocations have already been made to all of the large and powerful companies and organizations, and now the small companies are left needing them as well. and/or companies have little power, so its easy to implement restrictive policies that hurt them. 
[Whipple, Scott (CCI-Atlanta)] 
I agree with there being organizations out there that have large amounts of IP space that is not being used.  I also would like to see ARIN undertake a reclamation project but I think at this point all they could do is ask companies to give space back.  ARIN does not have the teeth it would need to be able to go and take unused space back.  
 
I find it very difficult to believe that when this policy was initially created that it was intended to hurt smaller companies which to me is what you are insinuating.   I also think everyone should remember that ARIN is the body in which the internet community has created.   This means that the internet community has the ability to change any of the current guidelines but I think if you want to change a current guideline you should base the argument on technical issues and how it would be beneficial to the internet community to have this new policy instead of arguing how the current policies are detrimental.  
 
 
 
 
 

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