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

Matthew Kaufman matthew at matthew.at
Tue Jul 8 19:21:27 EDT 2014

I can't tell... do you support or oppose the policy proposal?

Matthew Kaufman

On 7/8/2014 1:57 PM, Mike Mazarick wrote:
> 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
> connectivity.
> 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
> addresses?
> 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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