[arin-ppml] New Policy Proposal

Alexander, Daniel Daniel_Alexander at Cable.Comcast.com
Mon Aug 20 18:02:27 EDT 2012


After digesting some of the staff's comments I would like to ask if anyone thinks this would address some of the issue?

Looking at

Section 4.2.3.7.3.1 Residential Market Area
"In most cases, ISPs that have residential subscribers assign address space to their access infrastructure to which their customers connect rather than to individual subscribers....."

This section allows the 50% utilization rule to be applied to the most recent allocation instead of the 80% rule in section 4.2.4.1.

If the first instance of the word "their" was struck from the section, "...ISPs that have residential subscribers assign address space to their access infrastructure to which their customers connect rather than to individual subscribers....", should include third party ISPs to be considered with the lower utilization requirement in section 4.2.3.7.3.1?  Would this address enough of the problem?

Dan Alexander
AC Member


On 8/16/12 10:59 AM, "Bill Sandiford" <bill at telnetcommunications.com<mailto:bill at telnetcommunications.com>> wrote:

John:

The CRTC CISC process that you have mentioned is actually a totally separate process.  That process, which I was part of, was a process to come up with a solution for Third Party ISPs to be able to assign static IP addresses over the cable companies infrastructure.  To date, the only available assignment method is, and remains, dynamic allocation via DHCP.


Bill:

The problem that this policy attempts to address is a result of the framework that the CRTC has mandated for the Cable Companies to open up (or unbundle) their internet access services in a similar fashion to what the ILECs are also required to do here with DSL.

The CRTC passed a framework that mandated the cable companies to provide third party internet access (TPIA) to any competitive ISP that chose to do so.  The problem is that the CRTC did not define specifically as to how it would work technically and left those decisions to the cable company (ie the CRTC didn't want to tell the cable companies how to run their network, they just mandated that it be open).

When a TPIA ISP subscribes to the cable companies wholesales services the cable company REQUIRES that the third party ISP provide an assignment of addresses large enough so that they can adequately provision all of the CMTS's in their network for the service for assignment via DHCP.  This is usually done by reserving a /29 or /28 for each node on a CMTS.  To be clear, the TPIA ISP has no control over this process.  If they want the service they must provide the required amount of IPs to the cable co.  No IPs, no service.  This has typically required a /18 or /17 of space to accomplish.

Most ISPs have been able to acquire this *initial* space by making use of the immediate needs policy.  The problem occurs however when the ISP needs additional space.  For example, when one node (or two or three) fill up and exhaust the /29 or /28 that was assigned to them they require an additional block for that node.  In some cases additional blocks are required when the cable company augments their network and does a "node split" which requires another /28 or /29 to get used.  The ISP then makes a request to ARIN for additional space however they are unable to receive additional space because, although the address space is assigned to equipment, it doesn't meet the current definition of "utilized" under policy.

The problem is also exacerbated by the fact that there is more than one cable carrier in Canada (there are 4 major cable companies here, each with their own exclusive geographic territory).  An ISP makes an initial request because they plan to subscribe to the TPIA services of Cable Co 1 and receives a  /17.  They assign that space to Cable Co 1 to use for numbering their network for my customers.  They then decide to subscribe to the services of Cable Co 2, which requires another /17 and they are unable receive an address allocation to do so because their first allocation for Cable Co 1 isn't fully utilized according to the definition in policy.  Or, they exhaust their IPs with Cable Co 1, but are unable to receive more because their utilization with Cable Co 2 is too low.

For further clarity, there is no geographical overlap with the cable companies, so if you want to offer a ubiquitous service, you must subscribe to the services of all the cable companies.

This policy proposal attempts to solve the problems described above.  I wish to emphasize that the current policy text in the NRPM is causing a real world problem that is creating MARKET FAILURE in Canada.  To illustrate this point, in the Ontario market (Canada's largest province) there are several hundreds of ISPs that subscribe to the ILEC's (Bell Canada) wholesale DSL service.  In the case of cable, there are only 3 ISPs currently live and offering service.

Also keep in mind that the entire population of Canada is about equivalent to that of the State of California so the actual resource impact of this policy is minimal.

I hope this helps to clarify the issues for you such that you can support this proposal.  if you have any further questions please ask.  My company is not actually a cable TPIA customer, but there are a few others on here that can give further commentary if I've missed something.

Regards,
Bill



-----Original Message-----
From: arin-ppml-bounces at arin.net<mailto:arin-ppml-bounces at arin.net> [mailto:arin-ppml-bounces at arin.net] On Behalf Of John Curran
Sent: August-15-12 8:19 PM
To: William Herrin
Cc: arin-ppml at arin.net<mailto:arin-ppml at arin.net>
Subject: Re: [arin-ppml] New Policy Proposal

On Aug 15, 2012, at 7:36 PM, William Herrin <bill at herrin.us<mailto:bill at herrin.us>> wrote:
For discussion purposes it would also be helpful to have a link to
something that explicitly describes the CRTC's action here. Did they
wade in to regulating address management without consulting ARIN? If
so, perhaps John could explore the matter further directly with the
CRTC in parallel with our discussions here.

Bill -
Request by CRTC to CRTC Interconnection Steering Committee (CISC) to "develop a solution for static IP address allocation for TPIA services" - <http://www.crtc.gc.ca/eng/archive/2011/2011-330.htm>

CRTC approval of the recommendations made by the CISC's Network Working Group regarding static address allocation for third-party Internet access services.
- <http://www.crtc.gc.ca/eng/archive/2012/2012-96.htm>

The CRTC does not appear to be making IP number resource policy but rather determining appropriate responsibilities for address management when a service is jointly provisioned via wholesale infrastructure.  As it has been described to me, the typical manner by which wholesale third-party Internet services are deployed can result in IPv4 addresses from the ISP being fairly sparsely allocated to the infrastructure without the ability to readily reallocate to match the POPs of high demand. ARIN's IPv4 additional allocation policies (except for MDN) are predicated upon the ability to reallocate deployed IP resources until an overall utilization level of 80% is achieved.  Hence, there is a real potential for conflict between the assumptions from the third-party Internet access services and existing ARIN policy.

I hope this helps in your consideration of the proposed policy change.

Thanks,
/John

John Curran
President and CEO
ARIN
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