[arin-ppml] comment - Draft Policy ARIN-2013-8

Mike Mazarick mike.mazarick at virtudatacenter.com
Tue Jul 8 16:57:45 EDT 2014

RE:  Recommended Draft Policy ARIN-2013-8

My comments:

All of computer science is made up of allocating storage (memory/disk),
de-allocating storage, or moving bits around.   Like all organizations, the
current situation we are all in (exhaustion of IPv4 addresses) is due to an
improper de-allocation of IP addresses.   The fact that we are in 2014 after
a 30 year run talking about what to do means that de-allocation is already
good.   The current situation is due to desktops/servers/storage units
requiring a new IP address (throwing away the old one) while the core
routers have the same IPs that were in place when the internet was created.
There have been effective solutions put in place by ARIN and others to 'put
a thumb in the dike' of this de-allocation issue.   There are many possible
solutions, but the proposed solution means that ARIN will 'go slow' with
allocating the remaining IPv4 addresses stringing out the deployment of IPv4
addresses for as long as possible.   It is already economically very
difficult for a new entrant to get 'in' and it will be impossible once the
new policies are in place.

Now, it is not all bad for there not to be any new entrants into a market
(it is the heart of standards), and the market gravitates towards three
major solutions anyway once something becomes a commodity.   The real
question is "has the internet become a commodity already, or is there still
some juice left in it?".   It is impossible to answer this in advance.   I
do know that when ARIN was formed, the biggest problem was giving everyone
internet connectivity, which involved a major expense running wires, buying
wireless spectrum, etc and the investors who made it possible deserve to be
paid a profit because they were very successful at deploying internet

1)   It appears that there will be no new ISPs and no one will get into this
business.   It is difficult already, but if the draft policy by ARIN is put
in place, it solidifies and codifies ARIN's ratification of this.  Although
we all saw the unintended consequences arising when the US Congress made
possible CLECs (which were unsuccessful in the market) and new ISPs are very
much like CLECs were, it is a very dangerous thing to provide policy that
makes sure there will be no new ISPs because there is no economic incentive
for one to be created.   The opportunity to get ahead by creating a new ISP
will soon be removed by ARIN policy.   Does ARIN want to enable the entire
country to remain a 'banana republic' where the rich are getting richer at
the expense of the middle class/small business, or does ARIN wish to be
associated with the 'land of opportunity' (not subsidy) by allocating
resources to large and small enterprises on an equal basis?  

2)   There is no need to mess with IPv6 policy.   The current situation
which we have all been trying to implement for a decade will not be enhanced
by this policy change.   The change in policy is that IPv4 is getting a lot
more restrictive in allocation and IPv6 will be tied to existing IPv4
allocations.   It really means that there will not be an opportunity for a
new ISP even after the IPv4 addresses are a thing of the past.   If it ain't
broke, don't fix it.  There is ample opportunity for ARIN to create an
"intellectual property tax" for payment to ARIN based on existing allocation
size and market prices for the IP addresses (separate ones for IPv4 and
IPv6).   Does ARIN want to make sure only incumbents are able to get IPv6

3)  If we return to the 'bank of modems' of the dial up modem era, then
every modem has to have its own separate dial tone.   There may be a way to
use one phone number (like IP addresses), but the modem pool still has to
have an isolation mechanism per modem.   The policy as written will specify
that someone getting into the 'dial up modem' business can't deploy but a
handful of modems at a time, that all modems must be 80% utilized before any
more can be bought, and that the phone number will change for all modems on
the modem bank if more modems are deployed.   An ISP ensures that a customer
is able to put their own phone number on the banks of modems while a large
enterprise means that they have to control the phone numbers too.   It is a
subtle distinction but it at the heart of the question "Does ARIN wish to
have a more relaxed policy for large Enterprises than ISPs?".

4)  It is important for ARIN to maintain the existing internet policy thru
allocation.   It is hard to see how the existing policy change will enhance
an accurate allocation other than there will be less players to watch after
and the expense will be known in advance.   Does ARIN want to 'remove the
band-aid slowly' which the proposed policy change does, or does ARIN and
others involved undergo less pain if the IPv4 band-aid is removed quickly?

5)  Doing something now is akin to 'closing the barn door after the horse
has run off', similar to anyone that gets broken in to buying a burgler
alarm system after they were robbed.   In an effort at fairness, because
ARIN must serve both large and small internet clients and because of the
huge allocations in place in 2012-2013 (.5% of the companies got most of the
IP address allocations from ARIN), the attention has been to be fair in
administration of ARIN policies.   Will the existing policy change enable
ARIN to be more or less 'fair' with the remaining IPv4 allocation?

Mike Mazarick

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