[arin-ppml] ARIN-prop-139 No reassignment without network service

[Charles O'Hern]

First, I'd like to state that I'm representing one of those little rural (w)ISP's, and that in part is defining my perspective.  We had to go through quite a lot of time and money
to get to the point of qualifying for PI space ourselves and so understand the position of your customers.
Also, apologies in advance.  I am not intending any insult to anyone.

On 4/8/11 9:33 AM, Scott Helms wrote:
> Fair enough.  Do find what my company has done to be objectionable?

Actually, yes I do.  Essentially, in addition to the other services you describe your company providing, it is providing a service circumventing ARIN PI qualification criteria.

> So what do you think of what we do today, and have for over 5 years,
> which is reassign or reallocate space to ISPs we are not providing a
> connection to in order for smaller providers to gain access to portable
> address space?  We started doing this to help ISPs that don't qualify in
> some way 

If they don't (didn't) qualify, there is (was) a reason.  Circumventing policy rather than proposing policy change should not be condoned.

> (hard to be multi-homed in areas without more than one
> provider)

The multi-homed requirement for allocations smaller than /20 is to prevent route de-aggregation (IIRC).  If route de-aggregation is a valid issue, then circumventing should, once
again, not be condoned.  If its not the issue it was once thought to be, then policy should be changed to drop the multi-home requirement.  Again, we should promote policy change
rather than condoning policy circumvention.

> or don't want to deal with ARIN.  

Shouldn't having connectivity provider independent address resources within the ARIN region require having to 'deal with ARIN'?

> You could say we are a
> corner case and most of the customers that leverage this service from us
> are smaller (often in rural) retail ISPs, which ARIN seems to be
> recognizing have different needs from their larger brethren.  I'd also
> point out that we push the same requirements down to those ISPs that
> ARIN places on us and frankly our ability to accurately assess
> utilization is _much_ better than ARIN's because in most of these cases
> we're also helping take care of the network infrastructure.  That was
> the other reason we started leasing space, we were spending too much
> time renumbering networks for ISPs that were desperate to obtain lower
> cost Internet connectivity.

Even if you are fervently enforcing ARIN utilization requirements, your company is still enabling your customers to circumvent policy.

On 4/8/11 9:39 AM, Scott Helms wrote:
> We really only started doing reallocation because service providers were changing their upstream ISP (because of price mainly) so often it was creating a burden on my network
> engineering and end user support staff doing the network renumbering.  We ran into this problem because these ISPs were almost universally using IP space allocated by their
> upstream connection provider.

Any of your ISP customers who are frequently changing upstream providers have the option to multi-home (because they have choice of multiple providers) and thus easily qualify for
PI space.  Any that are in an area that only has one choice of upstream provider aren't going to be frequently renumbering because their upstream ISP will in turn either be
multi-homed using PI space or single-homed using PA because they lack choice in their upstream (the upstream's upstream).  And so on...

This basically cuts down the justification of the address allocation service you provide to "ISP's that ... don't want to deal with ARIN."


-- 
Charles O'Hern
Network Operations

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