[arin-ppml] New Policy Proposal

[William Herrin]

On Thu, Aug 16, 2012 at 12:50 PM, Bill Sandiford
<bill at telnetcommunications.com> wrote:
> Your analysis on 1 thru 4 is very close.  The only thing that I
> would say is that the nodes aren't empty in all cases.  They
> may have 1 or 2 customers on them, but still very underutilized.
> In some cases they could be empty though.

Hi Bill,

I'm pretty sure I could show a /29 DHCP block with only one or two
customers as fully utilized under current ARIN policy. I'd have to
keep records more carefully than I'd really like to but if I would be
a "CLEC" then I have to be prepared to play the game.

With 1 customer: SWIP the whole /29 block to them since they're the
only user of any of those addresses. Last I heard ARIN doesn't get
terribly skeptical about /29 assignments to a single customer.

With 2 customers: Lose the network and broadcast addresses to the
vagaries of the protocol and then lose one address to the default
gateway. Voila, 5 addresses consumed in a /29 pool, the pool is
configured at the minimum size the protocol allows, hence fully
utilized.

It seems to me, then, that the major problem is going to be all the
/29's with no customers attached at all. Those aren't in use per ARIN
policy under any truthful presentation of the data.

Right?


> I'm not sure I would say the Cable Companies
> tricked the CRTC into anything.  The CRTC
> established a framework for third party access,
> and the cable companies were given the latitude
> to decide how to implement it.  Naturally they
> chose an implementation that was similar to their
> own implementation for retail customers, namely
> assigning pools to nodes and handing out
> addresses by DHCP.

So, the cable companies found a loophole in the CRTC's requirement
that they could exploit to compel the competitive ISPs to act in a
manner inconsistent with ARIN policy. Rock and a hard place, as
someone else said, but the rock is the cable company not the CRTC. And
the CRTC has a large hammer which they use to pound on the rocks when
they find it needful.

What's your guess as to what would happen if one of the ISPs filed a
complaint with the CRTC to the effect that a cable company had made an
unreasonable addressing demand? What if the complaint was accompanied
by written guidance from ARIN to the effect that assigning IPv4
address pools far in advance of actual users is inconsistent with
current international standards for IPv4 address management.

Would the CRTC rule that requiring preassignment of address pools to
nodes without pending customers was no longer allowed? How long would
it take?


By the by, I hope someone from the FCC is present and paying
attention. It sounds like the CRTC has a major jump on you with
respect to regulating telecom infrastructure in the Internet age.

Regards,
Bill Herrin


-- 
William D. Herrin ................ herrin at dirtside.com  bill at herrin.us
3005 Crane Dr. ...................... Web: <http://bill.herrin.us/>
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