[ppml] Proposed Policy: IPv4 Countdown

[Ted Mittelstaedt]

>-----Original Message-----
>From: ppml-bounces at arin.net [mailto:ppml-bounces at arin.net]On Behalf Of
>Howard, W. Lee
>Sent: Wednesday, March 14, 2007 11:24 AM
>To: ppml at arin.net
>Subject: Re: [ppml] Proposed Policy: IPv4 Countdown
>
>
>Ted, I can't tell from your tone whether you're trying to rant
>or make constructive contributions. 
>

Well, I honestly consider the issue of IPv4 runout to be a lost
cause, since as I already mentioned, too many deep pockets have
a vested interest in making the transition as uncomfortable as
possible.  In short, "they" want to switch the Internet over to
IPv6 and are simply not interested in any proposals that will
extend IPv4.

I personally believe that with effort on the number registries
part, we could extend the use of IPv4 on the backbone until long
after everyone on the list here has retired.  But I see no real
interest in doing this among any of the major players.  Instead
all "they" care about is making everyone buy new hardware and
renumbering.

So, ultimately I think that all attempts to soften the blow or
put off the day of reckoning or make that day easier, are going
to be ignored.  But, I do think it is facinating to watch someone
try to change the status quo.  Sometimes, they even succeed in
doing it.

>
>> Your welcome.  If you really want my $0.02 on this you need 
>> to work out several "baby step" proposals.
>
>If you can make it to the public policy meeting, you could 
>get some feedback on these pre-proposals at the open policy
>forum.  I beg anyone who wants to discuss potential policy 
>approaches to IPv4 exhaustion to come to the open policy 
>forum.  It'd be nice if you'd let policy at arin.net know ahead
>of time.
>
>If you can't make it, you can still email ideas to PPML.
>
> 
>> The first would be one to define an orderly way to bring 
>> abandoned space into the sheepfold so it could be added to 
>> the pool of IPv4 available to be allocated.
>
>I would love to see a policy proposal on this.
>ARIN does reclaim "abandoned" space if you mean, "Space assigned/
>allocated to organizations who no longer exist or who no longer
>want that space."  Non-payment of renewals starts staff looking 
>for any live contact; that's part of the reason for renewal fees.
>

I'm not talking about space where the owners have stopped paying
the bill.  That's a non-issue.  I'm talking about space where the
owners ARE paying the bill but clearly they aren't using it.  Or,
space assigned pre-ARIN that isn't being used.

When MCI pulled out of North America in 2003 every ISP in ARIN's
territory that had IP allocations
from MCI had to get new allocations.  There were many many ISPs.
You cannot possibly make any believable argument that MCI had any
further need for those IP allocations.  They had pulled out!!
ALL of the numbers in those blocks were available!

Yet, did ARIN go to MCI and say "Hey, you announced in the
newspapers your turning off your network.  So, since you don't
need the allocations in that network anymore, we are taking them
back"

HELL NO!  They let MCI keep them.  When the entire network that
was used in North America for those numbers WAS TURNED OFF.  Then,
to add insult to injury, A YEAR LATER when SAVVIS bought MCI, THEY
GOT ALL THOSE NUMBER BLOCKS AS PART OF THE SALE and ARIN let them
take them over!!!

In short, SAVVIS buys a network with NO CUSTOMERS ON IT and that 
has been TURNED OFF, and CLAIMS IT NEEDS IP ADDRESSES FOR IT????
When they ALREADY HAD THEIR OWN!!!

Yeahhh - RIIGGHHTT!  I believe that!  Sure, sure.  Damn hoarder!

>> The second would be one to define additional requirements for 
>> justification submittal.  One of the biggest and most obvious 
>> would be that if an IPv4 allocation holder was to be acquired 
>> by another IPv4 allocation holder - regardless of whether 
>> both allocation holders were in the same number registry or 
>> not - that the acquiring party would have to submit 
>> justification for holding the acquired block.
>
>http://www.arin.net/policy/nrpm.html#eight
>8.1 Transfers
>ARIN will consider requests for the transfer of IP space only upon
>receipt of evidence that the new entity has acquired the assets which
>had, as of the date of the acquisition or proposed reorganization,
>justified the current entity's use of the IP space.
>

Once more that doesen't address the issue.  The issue is where an
entity that has plenty of numbering buys another entity that has
numbering, and continues to maintain it as for example a wholly
owned subsidiary.  In those cases since the subsidiary is wholly
owned, I believe the subsidiary should automatically lose the
right to obtain and use allocations from the registry, that they
must instead go through their parent that owns them for allocations.
But, in reality, since the subsidiary is a separate corporation,
even if only on paper, the parent can merely continue to use the
subsidiary's old name when dealing with ARIN and thus avoid any
existing rules such as 8.1 Transfers that you cited above.

>Examples follow in the NRPM.  I read this to mean that if you
>buy a network, the need for address space for that network 
>does not change.

But that does not follow since in the majority of ISP acquisitions
that have happened, the acquiring ISP merely moves the aquired
ISP's customers to their own existing infrastructure and then
decommissions the acquired ISP's network hardware.

And, it is also a fact that there's always customer loss when an
ISP acquires another ISP and so therefore the need is going to go
down.

Think about it - why would a network be for sale anyway?  Because it
does not have enough customers to make a profit, that is why.  And
if it doesen't have enough customers then who is using all it's
allocations?  Nobody.

>  Please, though, send a proposal.
>

I would if I thought that the numbering authorities were truly
interested in extending the use of IPv4 on the Internet past the point
at which allocations run out.  I just don't believe they are.

>> The third would be one to define a mechanism that IANA could 
>> offer a "bounty" for proof of deliberate criminal contract 
>> violations that is similar to what the SPA and BSA offer for 
>> reporting software piracy.  In other words if an admin at a 
>> network was ordered to "hoard" assignments he could rat out 
>> the network and trigger an IP number audit.
>
>That's an interesting idea.  It might be easier to limit it
>to ARIN, rather than IANA.  Could you make this a proposal?
>
>> You just do not 
>> understand how many people right now have a vested interest 
>> in allowing the train wreck to happen.  Honestly, they WANT 
>> it to happen.
>
>I don't understand.  Who?
>

Cisco for one.  That is why they have been so late at introducing
IPv6 support for their "legacy" routers.  Oh sure, they have IPv6
in IOS 12.4 service provider now.  You just can't run it on anything
other than a brand new router because the IOS package it is in is so
big.  In 3 years when IPv4 allocations run out it will be virtually
impossible to upgrade your older routers to handle
BGP by simply updating IOS, you will have to buy hardware.

>> If you think about it you might begin to understand one of 
>> the reasons that the large orgs are rather diffident about
>> IPv6 switchover, and are very lackadasical about turning in 
>> unused allocations.  They aren't stupid, even boneheads know 
>> that if they have something that is constrained, it is worth 
>> money to someone.
>
>I don't know any large orgs that are diffident about IPv6.  They
>all seem concerned, to various degrees, and most are active.

If they were concerned then they would be getting rid of their
large allocations and slimming down, to make more IPv4 addreeses
available.  In other words, they would be putting money into paying
employees to renumber.  Not simply making concerned noises in
various public statements.

>I
>don't know anyone who is hoarding in hopes of selling.
>

People aren't exactly going to advertise that they are doing that
since it's kind of a violation of the ARIN regs, you know.

But once the IPv4 allocations run out, unless the Internet is
immediately switched over to IPv6 you are going to find out who
has been hoarding pretty quick.

>> If the Internet Registries do nothing of course they will be 
>> criticized.  But if they do anything then they are going to 
>> also be criticized.  Thus, why bother since your going to be 
>> screwed either way?  Better to hold on to what you have now 
>> and hope when the storm hits that you can hang on.
>
>The Internet Registries is us.  Send proposals.
> 

If ARIN makes a public statement that it is looking for proposals
to stave off the day that IPv4 allocations will run out, then
I'll be right there.

>> Ask yourself this.  What do you think that IANA in it's heart 
>> of hearts wants to be doing in 2012?  Do you think they want 
>> to be fighting a hundred lawsuits by organizations that they 
>> are telling that they are going to take away allocations from 
>> and give to someone else?  Or do you think they would rather 
>> be sitting back mediating between organizations that want to 
>> make lawful monetary transactions with each other - I have/you buy.
>
>The IANA doesn't get a vote.  People on this list decide.
>

All registries are going to have to work in unison on this
issue.

>> It makes perfect sense to me.  It is a textbook technical 
>> response to a political problem.  And it will fail in a 
>> textbook manner, as all technical responses to political 
>> problems fail.
>
>It's a political problem in the sense that we may not have
>the right policies in place.  Propose some.
>
>> the problem isn't that 
>> there's a lack of IPv4 numbers, the problem is that not 
>> enough people have adopted IPv6 that they can start pushing 
>> for the Internet to be switched over.  Those people really 
>> and truly want an IPv4 train wreck if for no other reason 
>> that they can point to it and say "see, I told you that you 
>> should have switched over"
>
>This is the part I don't understand.  
>People are not adopting IPv6, because they want to create a
>market for IPv4 addresses, so that they can say, "I told you 
>to adopt IPv6."  If this is important to the policy process,
>could you clarify?
>

People are not adopting IPv6 because it is very expensive to
renumber and there are side effects that can last years.  Let me
ask you have you ever renumbered a nameserver that has had
a large number of domains on it and an even larger number of
people using it as their nameserver?

Also there is another reason that not many people have switched
to IPv6 and that is, since it is costly and disrupts customers,
if an ISP devotes resources to doing it, the ISP's customers that
are affected are going to wonder why they simply don't just go to
a competitor ISP that isn't requiring them to do all this IPv6
stuff.  In short it is a competitive advantage to NOT change your
network and disrupt your customers, yet have everyone else change
their network and disrupt their customers.  This creates a condition
where all of the ISPs facing this would much rather have everything
disrupted at one time.

If for example IANA announced that on January 1st 2012 that there
would be no more IPv4 traffic allowed on the global BGP network, and
that every ISP and network would have to renumber at that time, then
all the ISPs could go to their customers and tell them that they MUST
spend money on upgrading their network to be IPv6 compliant, whether
that means buying a proxy or translator or whatever, or on Jan 1st
they would lose Internet access.  The customers could not then go to
some competitor ISP and tell that ISP "I don't wanna pay for a new
firewall/desktop/switching my network over" because that ISP would
tell them "Sorry we can't do anything about it either"

But the way it is now, it's a giant game of chicken.  Since there is
no drop-dead date that everyone has to renumber, no ISP is going to
stick out it's neck and be the first into the boat, because if they
start telling their customers that they have to spend money, the
customers will simply move to some other ISP that isn't telling them
they have to spend money.


This is the same reason that all of the television broadcasters in
the United States told the US Congress that if they wanted to change
to digital broadcasting and get back the large VHF allocations, that
every last broadcaster in every city would have to switch over the same
date. Broadcasters know that if you have a situation in a city where 
one broadcaster stops broadcasting analog and starts broadcasting 
digital, the other broadcaster continues to broadcast analog, that
most people will not bother buying converters for their old analog
TV sets they will just watch the TV broadcasts of the broadcaster that
does not switch over.  Thus, the broadcaster that DOES switch is
going to suffer.  The way that they got Congress to set it up, every
last owner of a TV set in the US will be screwed over all at the same
exact time.  So no broadcaster will get an advantage, and the customers
will all be forced kicking and screaming into buying new TV sets or
a converter.  (frankly I kind of hope a lot of people stop watching TV
for a while - it might raise the average intelligence of the US
population a few points!)

So now do you understand when I say a lot of people have a vested interest
in having the IPv4 allocations running out be a big train wreck?

Ted