[ppml] Re: ARIN Policy Proposal 2002-7

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Thu Sep 26 14:28:08 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
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.


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:

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?

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.

In regard to routers' processing power, the new routers have increased in both processing power and memory size. As an example, even within the lower end Cisco 2600 routers series, the new model 2600XM/2691 has a processing power increase of 33%-50% and holds two to four times more memory than the old 2620 model. Also, with less than $4000.00, a person could build a Linux router/server with dual Xeon or dual Athlon processors, 4 GB PC2100 DDR SDRAM and two T1 CSU/DSU cards.  Are you telling us that dual Xeon processors and 4 GB PC2100 DDR SDRAM is not enough to run BGP?


9/24/2002 Bernard:
 2. Currently, many ISP's and upstream providers are in bankruptcy and/or
 have gone out of business; therefore, getting IP's from upstream
providers is no longer a good solution since small businesses will have
 the disadvantage of returning and re-numbering their IP's.

3. Once a small business obtains IP addresses from their upstream
providers, upstream providers are able to hold that small business
"hostage" and increase their rate without any consequences, because the
level of difficulty to move to another upstream provider is great and
could put the small company out of business.
9/25/2002 Alec:
Renumbering is not always trivial, but at the same time it is not 
impossibly hard either.  Things like DNS and DHCP make the process 
bearable, especially for small amounts of address space.
9/26/2002 Bernard:
A small business and/or ISP could be running hundreds of sites under virtual hosts and have colocation customers who run hundreds of sites under their virtual host servers. There is no flip of a switch to change IP addresses; there is a gray area of time when customers will be out of service. The process of changing IP's requires a company to change the DNS server's IP addresses for all of their sites, then send a request to Network Solutions to make their changes; hundreds of sites will go down until the proper changes can be made. Thousands of web sites and emails would likely go down because the logistics, timing and coordination of a vast number of people is overwhelming for a small company.  This process also requires the re-numbering of hosts and DNS server's data. A small ISP could lose customers when the customers find out that they are using IP's from upstream providers that are in bankruptcy and/or financial trouble, which happened in cases such as WorldCOM, XO, Global Crossing, PSInet, @home, ZipLink, ICG, CAIS, E.SPIRE, William Communications, WinStar, Northpoint, Rhythms, Flashcom and more. The small ISPs would lose customers and the big ISPs could capture the small ISPs' customers. This is one of the ways that ARIN's policy hurts small businesses.


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.


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.


9/24/2002 Bernard:
6. ARIN's current policy automatically qualifies a multihome
organization to obtain an AS number. There isn't any minimum IP
requirement to obtain AS numbers and AS numbers have the direct effect of
increasing the global routing table.

9/25/2002 Alec:
AS numbers are merely identifiers on routes, an increase in the number of 
AS numbers allocated does not cause the routing table size to increase.

9/26/2002 Bernard:
Then why can't we allocate smaller IP allocations to multihomed networks that are using AS numbers?


9/24/2002 Bernard:
7. Regarding the global routing table issue, memory is very inexpensive
 now, and Cisco is introducing new router models with a larger D-RAM size,
 that are reasonably priced and affordable by small businesses.

9/25/2002 Alec:
This is 100% correct, and 100% irrelevant.  Memory is no longer the 
limiting factor with respect to routing table size (it used to be, back in 
the AGS/7000 days).  Now the issue is the number of CPU cycles it takes for 
a router to generate its own view of the Internet based on the BGP feeds it 

9/26/2002 Bernard:
In regard to routers' processing power, the new routers have increased in both processing power and memory size. As an example, even within the lower end Cisco 2600 routers series, the new model 2600XM/2691 has a processing power increase of 33%-50% and holds two to four times more memory than the old 2620 model. Also, with less than $4000.00, a person could build a Linux router/server with dual Xeon or dual Athlon processors, 4 GB PC2100 DDR SDRAM and two T1 CSU/DSU cards.  Are you telling us that dual Xeon processors and 4 GB PC2100 DDR SDRAM is not enough to run BGP?


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. Small organizations and/or companies have little power, so its easy to implement restrictive policies that hurt them. 
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