[arin-ppml] RE Draft Policy ARIN-2012-7: Reassignments for Third Party Internet Access (TPIA) over Cable

[Jean-Francois.TremblayING at videotron.com]

> Draft Policy ARIN-2012-7
> Reassignments for Third Party Internet Access (TPIA) over Cable

Oppose as written.

There is indeed an issue with justification for allocations that 
have to be split in very small prefixes, such as those of TPIAs. 

However the proposal, as written, would completely remove utilization 
requirements. Including the staff comments in the proposal text would
be an improvement, but they are probably too vague to be acceptable 
criteria (more below). 

> Insert new section to NRPM to read as follows:
> 4.2.3.8 Reassignments for Third Party Internet Access (TPIA) over Cable
> When IP address resources are reassigned by an ISP to an underlying 
> cable carrier for use with TPIA, those addresses shall be deemed as 
> utilized once they are assigned to equipment by the underlying cable 
> carrier.

This proposal, as written, would allow a TPIA to request new space as
soon as its last allocation is assigned to hardware without justifying 
utilization at all. 

>          IP addresses reassigned by an ISP to an incumbent cable 
operator
> for use with Third Party Internet Access (TPIA) will be counted as fully
> used once they are assigned to equipment by the underlying cable carrier
> provided they meet the following requirements:
> 
>     * initial assignments to each piece of hardware represent the
> smallest subnet reasonably required to deploy service to the customer 
> base served by the hardware

What is a reasonably smallest subnet? TPIA clients are typically 
spread geographically and represent very few addresses per device. 
Initial assignment could therefore be as small as a /29 per device. 

This also does not cover devices serving multiple IP domains, which 
further dilutes the size of the prefixes. (one proprietary term for 
this "CMTS bundles" and their number vary by operator)

>     * additional assignments to each piece of hardware are made
> only when all previous assignments to that specific piece of hardware 
> are at least 80% used and represent a three month supply.

This is criteria is better, but remains fairly vague. Adding 3 customers 
out of a /29 is 100% utilization (the device counts as one). It can happen 

in a week and make the utilisation rate jump suddenly. On the other hand, 
2 customers are only 75% and would not meet the criteria. I'm not sure 
this wording, if included, would actually solve the problem. 

/JF Tremblay
Videotron

Full disclosure: Videotron is a Canadian cable operator used by 
several TPIAs.