[ppml] Proposed Policy: IPv4 Countdown

[Howard, W. Lee]

Wow, this post got very long.  I apologize to everyone; I'm
trying to trim as I go, without losing context.

I'm not sure how many more ways I can say the following:
1.  Send a proposal.
2.  IP numbering policies are determined on this list, and
informed by public policy meetings.
3.  ARIN is us.
4.  Please send a policy proposal.

I will continue correcting factually faulty assertions about
the ARIN organization (community, Advisory Council, Board, 
staff), process, and fees.  I will try to refrain from further
posting about style, conspiracies, or the intent of industries
or other organizations.  The AC should continue extruding
clear policy proposals from the email threads.


> -----Original Message-----
> From: Ted Mittelstaedt [mailto:tedm at ipinc.net] 
> Sent: Wednesday, March 14, 2007 9:48 PM
> To: Howard, W. Lee; 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.

"Rant" then?

> 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.

Who are these "major players?"
Telcos?  Cable companies?  Router manufacturers?  All of the
above?  
Since you say "buy new hardware" I'll assume you mean router
manufacturers, but we've heard loud concern from a major ISP
that the router people aren't provided boxes to scale for 
five years.  

> But, I do think it is facinating to 
> watch someone try to change the status quo.  Sometimes, they 
> even succeed in doing it.

This is frequently the case at ARIN.

> >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.  

How do we determine that?

> Or, space assigned pre-ARIN that isn't being used.

How do we determine that?  Send a proposal.

Also, to inform discussion on reclamation, there was a roundtable
at ARIN XVI, including expiration projections from Tony Hain and
Geoff Huston, and analyses from kc claffy and Thomas Narten.  
http://www.arin.net/meetings/minutes/ARIN_XVI/ppm.html
http://www.arin.net/meetings/minutes/ARIN_XVI/PDF/wednesday/claffy_ipv4_
roundtable.pdf

 
> 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!

My recollection is that MCI divested InternetMCI to allow the
merger of WorldCom and MCI.  Cable and Wireless bought InternetMCI,
and later (2003 sounds right) announced that they would stop
operating in the U.S.
 
> 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!!!

Your use of capitalization and exclamation points weakens your 
argument.  
 
> 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!

Did you see the transfer request?

Did you see any subsequent applications for additional address space?


> >> 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.

Propose a policy that says that.  Here, let me show you how.
Send the following text to any of the email addresses on
http://www.arin.net/about_us/ac.html

  How would I propose the following?

  When an organization with an existing allocation acquires 
  another organization with an existing allocation, the
  acquired company shall have nine months to renumber into
  space allocated to the acquiring company, and return the
  unused allocation to ARIN.  The acquiring organization may
  apply for additional address space, as needed, under 
  existing policies.

They'll reply back with helpful information about how to use
the proposal template and help you get it to the right place,
and they'll offer to help write clearer words, and to respond
to comments received from the list, meetings, staff, and
counsel, as you (the author) see fit.

> 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.

A separate corporation "only on paper" is a separate corporation.
I don't know how else to define it.

 
> >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.

My experience is that acquired networks are decomissioned over a 
period of years, if at all, and the addresses numbering them are
either used, reused or returned.

> 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.

There are many reasons.  Maybe somebody offered the owners a lot
of money.  Maybe (as with MCI) a proposed merger is contingent
on divestiture.  

 
> >  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.

I don't know who these "authorities" are, if not the people who
submit and discuss proposals on this list.  

 
> >> 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.

Perhaps someone from Cisco would care to comment.  I know they have
claimed IPv6 support for several versions now (later revs of 12.2).


> >> 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.

Come to a meeting, meet the IP Analysts for the large ISPs, and ask
them why they don't renumber.  Look at the list of attendees, and
ask them (you'll have to find their contact information another
way).  Ask the Whois Technical POCs.

> >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.

People running production networks have better things to do with
their time.  There may be some people sitting on unused space,
but (you'd have to ask them) to the extent that they're hoarding,
they're hoarding for their own future use.
 
> 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.

Probably.  I missed your proposed solution.

> >> 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.

You saw John's response.  I'll add mine to the many other times 
I have asked you to submit a policy proposal:
ARIN requests policy proposals.

If you submit a policy proposal to stave off the day that IPv4
allocations will run out, it's up to the community to decide 
whether ARIN should do it.  It is not up to the Board or staff
to decide what proposals are needed.
 
> >> 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.

People on this list decide for ARIN.  If they agree with the 
communities in other regions, the RIRs work together.


> >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?

Most IPv6 adopters are dual-stacked.  The incremental cost of
adding an IPv6 address to a name server is relatively low.  I
do not dispute that there are costs to implementing IPv6.
I, personally, have not renumbered a name server that was 
authoritative for many domains and was also a resolver for many
people.
 
> 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, 

IANA does not control the "global BGP network".
Do you propose that we should somehow delegate some kind of
authority for routing to IANA, so that they can declare a flag
day?

> 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.
 
 
> 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?

I'm not sure.
You assert:
- Router vendors will only support IPv6 in OS versions that require
more flash/memory than recent chassis can hold, to force upgrades.
- ISPs won't implement IPv6 until forced to do so, so they can 
delay the expenses as long as possible.

You conclude:
- None of the above are interested in proposals which would delay
the exhaustion of IPv4.

I will counter-assert that router vendors and large ISPs do not
control the public policy process.  They can send email and speak
at the meetings only as much as anyone else.  The only argument I
recall seeing against some proposal you continue not making is 
that reclamation wouldn't be worth the effort.


Really, send a proposal.  It may not be adopted, but it definitely
won't be if you don't send it.

Lee