[arin-ppml] IP Address Policy

Kevin Kargel kkargel at polartel.com
Thu Aug 9 12:55:25 EDT 2012

Mr. Ryerse,
Perhaps I can relate what has been my personal experience.  When our organization started out we were quite small and needed limited space.  We originally were not multi-homed and obtained a /24 of PA space from our provider.  We had the provider SWIP the /24 to us so we could advertise our space in BGP.

As time went on we got a second upstream connection and were given another /24 from that provider.  This provider also willingly registered a SWIP for this block of IP addresses.

Neither of our providers gave us any trouble at all in assigning PA space for us to use.
We got an ASN from ARIN and both providers were very amenable to setting up BGP peering sessions and advertising the PA space we were using in our ASN.

As time went on and we grew and needed more IP space we did a couple of times get larger blocks from our upstreams.
Also as time went on for economic reasons we changed upstream providers a couple of times.  Because we were operating in PA space we needed to renumber some devices.  Yes, this was a bit of work, but with some organization and planning it is neither onerous or painful.  It all depends on how you manage the renumbering.  

After doing that a couple of times and noting that we were still growing we applied for and received a PI allocation from ARIN.  The first time through that process was a learning curve.  We ended up resubmitting that initial application a few times with assistance and suggestions from ARIN staff.  
We have subsequently gotten further allocations from ARIN and as we grow familiar with the application process it gets easier.
We took our time renumbering and moving things until we were able to return the PA space to our upstreams.  Neither the upstreams nor ARIN gave us any grief or tried to hurry that process or force us to deadlines.   

I am sure this story is pretty textbook similar to the story of many if not most of the organizations out there.  We all pretty much went through the same steps.
1.	Get PA space from upstream
2.	Get multi-homed with more PA space.
3.	Get PI space from ARIN (Yes, renumber and return)
4.	Get more PI space from ARIN

It really isn't that hard, though I understand you want to shortcut the process and don't think you need to do what everyone else has done.  I know you have already gotten ahead of the game by multi-homing at the start.  

I think though, the shortest path for you is going to be to take the same steps the rest of us have taken.  It is not terribly surprising that you don't get a lot of sympathy from the rest of the community when you don't think you need to follow the same rules we do and you don't think you should have to jump through the same hoops we did.  

We really do welcome you to the community.  We really are on your side and want to help you get through all of this as painlessly as possible.  I would suggest that if you try and work within the system you will get to your goal with munch less aggregation and expense.  

Perhaps if you do as I did, and when someone at ARIN rejects your application, ask that particular person for their advice and what they think is your best course you will find that they really will help you get there as quickly and painlessly as possible.  Of course this only works if you actually take heed of their advice.

I myself have had for the most part good experiences when dealing with ARIN.  Part of this was because of realizing that it is easier to work with the rules than trying to buck the system.  

Good Luck with your endeavors.  

From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On Behalf Of Steven Ryerse
Sent: Thursday, August 09, 2012 3:02 AM
To: Heather.skanks
Cc: John Curran; ARIN PPML (ppml at arin.net)(ppml at arin.net)
Subject: Re: [arin-ppml] IP Address Policy

Well now that is constructive isn’t it.  I don’t see how this comment helps anyone in this community.  I think it would be more helpful if you disagree with my opinion to just state that.  Then maybe there is a chance at something positive coming out of these submissions.  I might also offer this question to you: If an organization our size can’t get approval for an IP address block from ARIN, just exactly how do you think one of our customers whose IP needs are much smaller than ours is going to get approved.  I can’t wait to hear the solution.  Do you really think I should be recommending my customers who only need 5 IP addresses to apply for independent space so they can have independence – what a great idea.  

In fact I would do that if ARIN allowed it and it could be done on less than a /24.  Doubt that will ever happen though.  I have made sure my customers are listed as the Administrative contact for their web domain names for about 15 years now even though I could have put their domain names in our name and married them to us in that way.  Some companies actually do try to look out for the best interests of their customers.  Those are the companies that keep customers for a long time.

Steven L Ryerse
100 Ashford Center North, Suite 110, Atlanta, GA  30338
770.656.1460 - Cell
770.399.9099 - Office
770.392-0076 - Fax

℠ Eclipse Networks, Inc.
                    Conquering Complex Networks℠

From: Heather.skanks [mailto:heather.skanks at gmail.com] 
Sent: Thursday, August 09, 2012 3:13 AM
To: Steven Ryerse
Cc: Zolla, Christopher; McTim; John Curran; ARIN PPML (ppml at arin.net)(ppml at arin.net)
Subject: Re: [arin-ppml] IP Address Policy

Then why aren't you advising and helping your customer get provider independent space from ARIN so they can drop you without the hassle of renumbering?  When it becomes competitively advantageous of course..


Sent from my iPhone

On Aug 9, 2012, at 12:15 AM, Steven Ryerse <SRyerse at eclipse-networks.com> wrote:
Glad to hear from you!  Hopefully more will respond.  I don’t recall threatening any legal action on my part over this in any of my submissions.  If you inferred that I am very unhappy over ARIN denying my request then you inferred correctly.  I did say that there are larger company’s out there who might want to use a denial like mine for their legal purposes.  Of course any legal action would be counterproductive and should only be used as a last resort after all reasonable avenues have been explored.  I would never threaten to sue someone unless I actually intended to do so and I didn’t here.  I also haven’t questioned anyone’s character.  I don’t think this policy is against our company, I think it is against all smaller companies.  Sounds like you agree with that based on your actual experience.  I don’t see anything in ARIN’s mission statement that says that they are only to serve larger organizations.  They need to serve us and you as well!
Renumbering in the future is out of the question as for just one of my customers it affects over 600 end users.  It is a physical impossibility since they would all have to be renumbered over a weekend and there isn’t enough time in a weekend to do it all.  I’m not willing to risk significant customers business in the hope that an upstream provider would let us keep an IP block.  
There is a lot of theoretical discussion in a community like this which is mostly productive.  In the real world that you and I have to live in there is competition that wants to sell similar services to the ones we sell.  When bandwidth prices go down significantly as they have just in the last year, I have to be able to purchase from the less expensive vendor just like my competitors do - or they will take my customers by offering lower prices.  If I'm locked into a long term contract just to keep my IP addresses then I can't switch to the lower cost vendor and then I can't compete with my competitors lower price.  
So I really don't have a choice.  I have to control my own IP addresses, and ARIN, which is a monopoly has denied my request.  A request which is very reasonable.  One /22 is peanuts compared to all of the /8's out there in legacy status.  Anyone who can demonstrate a need should be able to get a /22.  In my opinion for ARIN to deny my reasonable request is a blatant disregard and is opposite of their mission.  ARIN publicly states that no address blocks should change hands without their involvement and approval, but when they deny a request like mine they force a secondary market to exist which they don't control and don't like.  Doesn’t make sense.  They can either fix the policy to make it more reasonable or the secondary market will take away their monopoly status by creating an above ground second market and the beginnings of that are happening already.  I hope I don't have to utilize that market but I have a business to run.
Steven L Ryerse
100 Ashford Center North, Suite 110, Atlanta, GA  30338
770.656.1460 - Cell
770.399.9099 - Office
770.392-0076 - Fax
<image001.jpg>℠ Eclipse Networks, Inc.
                    Conquering Complex Networks℠
From: Zolla, Christopher [mailto:zolla at neonet.org] 
Sent: Wednesday, August 08, 2012 11:51 PM
To: Steven Ryerse; McTim
Cc: John Curran; ARIN PPML (ppml at arin.net) (ppml at arin.net)
Subject: RE: [arin-ppml] IP Address Policy
I can understand you frustration and can sympathize.  I also understand the policy all too well as my organization did follow the procedure to obtain a /22 assignment.  Consequently we did readdress at a reasonable pace and with good planning.  Most ISPs require multiple year contracts to obtain optimal pricing so there is nothing here that your organization can’t overcome like the rest of us did.  I don’t normally get involved in these discussions as I don’t follow ARIN policy close enough to provide much insight, but in this particular instance the opinion of the community is what you asked for.  I did my due diligence to get the assignment my organization has, just like many other organizations like me.  The path ARIN policy has you follow may not seem optimal for you, but it does have merit.  It is my impression that you feel there is a hidden agenda to prevent your company from getting the IP addressing it is rightfully owed.  While I commend the effort to change policy you don’t believe in, threating legal action and questioning someone’s character are not the ways to make change.  Like you said, constructive comments and active discussion are great, but you lose credibility in my mind when you go beyond that.
Christopher Zolla
Assistant Director, Network Manager
(330)926-3900 ext. 601110
From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On Behalf Of Steven Ryerse
Sent: Wednesday, August 08, 2012 11:27 PM
To: McTim
Cc: John Curran; ARIN PPML (ppml at arin.net) (ppml at arin.net)
Subject: Re: [arin-ppml] IP Address Policy
I appreciate constructive comments.  It certainly is good that ARIN tries to listen to the Internet community as that is who they serve.  However they do this voluntarily and the community does not have any real legal vote.  The fact that the CEO & Board of Directors tries to listen to the community is of course positive but they have absolutely no legal requirement to do so.  They are a US corporation of whatever flavor and as such are actually bound by the corporate laws of the United States.  The CEO and board have a fiduciary responsibility just like any corporation.  It is their duty to honor that responsibility or they should not hold office.  If there are policies that are contrary to their mission they have a fiduciary responsibility to either change or remove the policy or they need to change the mission they were chartered under.  I’m glad they exist and I have no beef with them as long as they do what they are chartered to do.  
It is pretty clear to me that they are doing the opposite of their mission in this instance.  It does not destroy any trust if they do what they are chartered to do.  They sometimes make decisions that are not shared with the community and which may be at odds with this community, but as long as they are following their charter then it is their right and responsibility to do so.  In this case there is a policy which I believe is contrary to their mission and they should act accordingly which is their right and responsibility as well.  I don’t know why you would think “He rightly can” if it is contrary to his mission.  Why would you want him to do things contrary to his mission?  Make no sense.  
Upstream does not meet our competitive needs.  If this community does not decide to change this policy then the courts eventually will.  Maybe my case will be used by some smart attorney somewhere to do just that.  Hopefully it won’t come to that as I hope reasonable ness prevails here!
Steven L Ryerse
100 Ashford Center North, Suite 110, Atlanta, GA  30338
770.656.1460 - Cell
770.399.9099 - Office
770.392-0076 - Fax
<image001.jpg>℠ Eclipse Networks, Inc.
                    Conquering Complex Networks℠
From: McTim [mailto:dogwallah at gmail.com] 
Sent: Wednesday, August 08, 2012 10:48 PM
To: Steven Ryerse
Cc: John Curran; ARIN PPML (ppml at arin.net) (ppml at arin.net)
Subject: Re: [arin-ppml] IP Address Policy
Hi Steven,
On Wed, Aug 8, 2012 at 10:19 PM, Steven Ryerse <SRyerse at eclipse-networks.com> wrote:
John, you seem to miss my point so let me be very clear.
I think you may be missing the point.  ARIN is a body that supports a rule making community.
In addition to being the Secretariat for the community, they are the org that does the allocation and assigning according to community set policies.
There are policies in place.  You are asking for the Secretariat to ignore them.
not valid according to current policy, so you can get policy changed OR follow Jimmy's advice.
I am formally requesting here and now that you review my request and approve it.  That is the only way I am going to drop my request.  It is not reasonable to tell me to wait for months since others who get allocations don’t have to wait for months.  What is reasonable is for you to go to your staff and have them reopen my request #20120801-X7252 and have them allocate us the /22 IP v4 block requested.  Simple.  You definitely do have the power as President & CEO to do that if you decide to.
While that may be true, it would destroy a great deal of trust in the entire global Internet resource administration regime.  In other words, you are demanding that the CEO override the policies that he has a duty to uphold in order for you to get your data center going.
Then in the future when ARIN gets similar requests from others your staff should approve them as well.  That fulfills your mission!
It doesn't actually, since the mission includes following policies set by us (we are ARIN).
You cannot use this community as your reason why you won’t fully fulfill your mission and your fiduciary responsibility as President & CEO.
He rightly can IMHO.
  Policies that originate from this community still have to be voted on and approved by you and your board of directors as this community has no legal standing in your organization.  That vote is what puts those policies in force and since you and your board of directors have the power to both approve, change, and remove policies without input from this community - you can do so here if you want to.  In fact you have a fiduciary duty to do just that if any policy currently in force is determined to be contrary to your mission, regardless of what this community thinks.
This is a clear case where the policy is contrary to your mission, therefore you should take the appropriate steps to rectify that ASAP.
I’m not going away.   As I said in my first post we have to have these resources one way or the other TO STAY IN BUSINESS.  I prefer ARIN allocate them to us per my request through normal channels.  If that request ultimately fails I will be forced to go off-channel and fulfill my request with a Legacy block that ARIN does not have an agreement on.  Unfortunately those are my only two choices.
See the advice from others on a third way (getting an assignment from an upstream, at least for the short-term).
  If I’m forced to go that route then I will of course come back to your web site and make a request for ARIN to update your database to show our new assignment of additional Legacy addresses.  Requesting that from ARIN is the right and proper thing to do since I don’t want to hide anything or lie to ARIN in any way.  If that request were to be denied then I would come back to this community and ask for their help.
John, the choice is yours, you can fulfill your mission and allocate resources or you can force us to go elsewhere.  I would appreciate it if you would approve our allocation request.
Actually the choice is yours, you can get a PA block from an upstream, work on changing policy, find a block on the transfer market, etc.
I would also ask everyone in this community to share your thoughts on this issue as it is very important. 
See above.

"A name indicates what we seek. An address indicates where it is. A route indicates how we get there."  Jon Postel
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