[arin-ppml] Policy Proposal: Protective Usage TransferPolicyforIPv4 Address

Wed Feb 11 10:01:00 EST 2009

In a message written on Wed, Feb 11, 2009 at 01:26:15AM -0500, Chris Malayter wrote:
>    There are a large number of IX's in the North American region (as well
>    as other regions) that have address space allocated from a provider
>    that specializes in exchange allocations.

I love how people dance around issues without coming out and saying
them.

Since the proposer and yourself work at Switch and Data, let's look at
one of the Switch and Data blocks, say, for PAIX Palo Alto:

% whois -h whois.arin.net 198.32.176.0

OrgName:    EP.NET, LLC.
OrgID:      EPB-Z
Address:    PO 12317
City:       Marina del Rey
StateProv:  CA
PostalCode: 90295
Country:    US

NetRange:   198.32.0.0 - 198.32.255.255
CIDR:       198.32.0.0/16
NetName:    NET-EP-1
NetHandle:  NET-198-32-0-0-1
Parent:     NET-198-0-0-0-0
NetType:    Direct Assignment
NameServer: DOT.EP.NET
NameServer: FLAG.EP.NET
Comment:
RegDate:    1997-06-09
Updated:    2008-01-15

RTechHandle: WM110-ARIN
RTechName:   Manning, Bill
RTechPhone:  +1-310-322-8102
RTechEmail:  bmanning at karoshi.com

OrgTechHandle: WM110-ARIN
OrgTechName:   Manning, Bill
OrgTechPhone:  +1-310-322-8102
OrgTechEmail:  bmanning at karoshi.com

Ah ha!  Let's go to www.ep.net, and follow the about link
(http://www.ep.net/aboutUS.html):

] EP.NET, LLC. provides a variety of services to the Internet community.
] These include publication of Internet exchange facilities worldwide,
] links to supporting organizations, documentation on exchange creation
] and operation, and statistical information. EP.NET LLC. also offers
] consulting and support services and unique identifier management for
] neutral exchange point operations. These identifiers may include ASN's,
] IPv4 and IPv6 prefixes, and VPI/VCI assignment. 

Finally, let's cross reference with other sources, say Bill Manning's
LinkedIn Profile (note, account required to view):

http://www.linkedin.com/pub/2/b58/469

With a status of:

  "Bill Manning is working on the Phd, selling off the business, starting
   a new one 1 month ago".

Indeed, if you happen to be linked to Bill, you may have seen this
message back on November 9th:

  "Bill Manning is selling EP... make me an offer 9 hours ago"

So, Bill Manning is selling EP.Net, and varous exchanges have IP
addresses from EP.Net, and are worried they will not be able to continue
to use them after the sale.  How many exchanges, well, here is a list
sorted by location:

http://www.ep.net/ep-main.html

This is far from a "US" or "ARIN Region" problem, as exchange points all
over the world have gone to EP.Net rather than the RIR's to get address
space.

>    According to the current ARIN policy, we are all eligible to request
>    space as a direct allocation from ARIN.  That is not lost on the IX's
>    and they do completely understand that they are eligible for a direct
>    allocation.

Have you applied for an ARIN micro-allocation for the exchange yet, at
least as a backup plan, or are all the hopes pinned on this policy?

>    The real issue is that if the current provider was to serve a majority
>    of the US IX's with a cease and desist order from using the space at
>    the term of all of the existing contracts at the end of 2009 that
>    would force a massive renumber of most every IX in the North American
>    region, save one major IX.

I'm not sure I agree with this statement.

Equinix appears to have direct allocations for ARIN for their exchanges
in San Jose (206.223.116.0), Chicago (206.223.119.0), Ashburn (206.223.115.0),
Dallas (206.223.118.0) and New Jersey (206.223.131.0).

CRGWest's Any2 LA (206.223.143.0) has a direct allocation.

Pacific Wave (207.231.240.0) on the education side has a direct
allocation.

It's easy to independently check.  Go to www.peeringdb.com and search
exchange points by country, put in US.  There are 56 exchange points
listed in the US.

It does appear that several major players use EP.Net space, including
Switch and Data, Telehouse, and TelX.

>    The reason behind the policy proposal was to provide a method to allow
>    IX's 1) protection from having to renumber all of the IX's, or  2) to
>    at least let the IX's have enough time, before they are forced out of
>    the space, to have a smooth transition.

In the previous paragraph you state that "the term of all of the
existing contracts at the end of 2009".  That appears to provide
10 months from right now to do the renumbering under the current
contract.

Is 10 months not enough time?  In the relatively few cases I've
seen where a provider let a customer continue to use PA space outside
of their network to ease renumbering 6 months seems to be an industry
accepted time frame.  If 6 months is enough time for an end user,
than surely 6 months should be enough time to get an exchange point
renumbered.  After all, it can be done as an overlay, and more
importantly rather than dealing with end users who may have no
particular network still an exchange point is dealing with network
operators, who presumably have qualified engineers on staff who
understand how to make this work smoothly.

If 10 months isn't enough time, and an appeal were to happen, how
much more time would the exchange operators want ARIN to give them?
Can we put a limit to a policy, if it were to pass?

Has anyone tried renumbering any of these exchanges yet?  I've seen
exchanges renumbered before (in Europe, at least).  It would be a lot
more credible to have some real world evidence of why 10 months is not
enough, or why already attempted renumbers are going slower than
expected.

Should this policy allow appeals by those outside the ARIN region?  I
see ep.net has allocated space across Europe and Asia, if those exchange
point operators came to ARIN to ask for an extension should it be
granted?  What if they can't get critical infrastructure allocations in
their region, should ARIN extend the prohibition on transfer
indefinitely?

-- 
       Leo Bicknell - bicknell at ufp.org - CCIE 3440
        PGP keys at http://www.ufp.org/~bicknell/
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