[arin-ppml] Draft Policy ARIN-2014-18: Simplifying MinimumAllocations and Assignments

[Owen DeLong]

Steven,

You are properly following the procedure just fine. Please don’t take my comments personally, they were not intended as any form of personal slight. This is the proper forum to effect policy change and I applaud your choosing to participate in the process and bringing a proposal to try and solve what you perceive as a problem.

However, I believe that the policy you have proposed would be irresponsible for the reasons I outlined.

I’m not sure what you mean about “what goes on during the allocation process for medium and larger organizations”. You claim to be trying to help smaller organizations, so I’m not sure what you think is different for them than for smaller organizations when they apply.

In my experience (and I have done applications for organizations of virtually every size category available), they are all treated exactly the same and held to the same standards for documentation, validation, verification, utilization, etc. Effective September 17 (or thereabouts) when ARIN implements the recently ratified policy change, the minimum size will be a /24. The requirement to get a /24 for an end user will be to show utilization of 63 addresses immediately and 127 addresses within 1 year. The requirement for an ISP to get a /24 will be to show efficient utilization of a /24 from an upstream provider or immediate need for a /24 (I don’t know the exact minimum host quantity used by ARIN for this, but I have a hard time imagining how I could build anything I would call an ISP with downstream assignments that wouldn’t justify at least a /24).

As such, I believe that any legitimate need for a /24 or more is well served by policy already adopted.

Is it your argument that anyone with a single host should be able to obtain a /24 per year? If so, then we can agree to disagree and move on.

If not, where, between 1 and 63 do you think that bar should be set? You clearly seem to think that 63 is too high.

Owen

On Sep 3, 2014, at 12:38 PM, Steven Ryerse <SRyerse at eclipse-networks.com> wrote:

> Owen, I appreciate the dialog but I think you are ignoring what goes on during the allocation process for medium and larger organizations. You and I disagree that the current policies are fair and I do not think I'm being irresponsible to try and correct that!  I've been told this is the proper forum to effect policy change by you and others and I am trying to follow the change procedure as best I can.  
> 
> As I've noted before:
> 
> When a medium or larger organization requests a medium or larger block they probably will come away from it with an allocation, possibly smaller than requested but they are likely to receive an allocation none the less.  When a small organization requests the minimum block size and that request is refused because of policy, they get nothing at all and no offer of something smaller because there isn't anything smaller.  So, no matter how you slice it,  that is an un-even playing field - and it is arbitrary, unfair, and discriminatory against small organizations in favor of larger ones.  I have been pointing this out for years and I've said it just about every way I know how.  The have's get more and the have not's don't. It is time this gets corrected to level the playing field for all as that is ARINs Mission and raison d'etre.  
> 
> My proposal ARIN 2014-18 is specifically designed to rectify and level the playing field so that regardless of what size allocation was requested, a small organization can at least get the Minimum size block.  This then makes it so the larger org gets what they requested or something smaller, and the medium size org gets what they requested or something smaller, and the smaller org gets what they requested or the current Minimum.  This proposed policy Minimum allocation is limited to once per year per this policy proposal. 
> 
> As I said many times before the needs testing policies should be replaced by right-sizing policies,  BUT, ARIN 2014-18 is only intended to correct the unfairness of current policies for allocations to smaller organizations and does not attempt to change any other aspect of the currently policies.  
> 
> Also, as there is a lot of policy talent in this community, I would welcome constructive comments and possible changes to this policy as long as they don't change the intended purpose of this policy proposal. 
> 
> Steven Ryerse
> President
> 100 Ashford Center North, Suite 110, Atlanta, GA  30338
> 770.656.1460 - Cell
> 770.399.9099- Office
> 
> ℠ Eclipse Networks, Inc.
>                     Conquering Complex Networks℠
> 
> -----Original Message-----
> From: Owen DeLong [mailto:owen at delong.com] 
> Sent: Wednesday, September 3, 2014 1:05 PM
> To: Steven Ryerse
> Cc: Gary Buhrmaster; ARIN; arin-ppml at arin.net
> Subject: Re: [arin-ppml] Draft Policy ARIN-2014-18: Simplifying MinimumAllocations and Assignments
> 
> Steven, many of your statements are patently false.
> 
> First of all, the current allocation/assignment process is fair. Everyone is subject to the same policies and it is quite easy for small organizations to obtain IP space under the existing process. I have obtained legitimate assignments for organizations as small as a sole proprietorship with no employees and have obtained allocations for extremely small ISPs.
> 
> I have yet to see an organization so small that they could not obtain addresses under current policy because of their size.
> 
> Needs testing is not merely a vehicle to save the remaining free pool. If that were true, then we would not have subjected the transfer policies to needs testing. Further, I’m all for distributing the remaining IPv4 free pool to organizations with legitimate need as quickly as possible. I believe that the longer we have an IPv4 free pool at this point, the longer we will have to deal with the pain of this transition process and the longer people will continue to procrastinate the necessary move to IPv6. So if I truly believed that needs testing was really a vehicle to save the free pool, I would be leading the charge to eliminate needs testing. Instead, I’ve remained strongly opposed to eliminating needs basis from ARIN policy and preserved needs basis when I proposed a significant rewrite of the IPv6 allocation policy (which was adopted).
> 
> I don’t believe any of Gary’s comments were at all related to organization size, so your retort to his kitchen comment seems non-sequiter.
> 
> ARIN2014-18 is an irresponsible attempt to streamline the process of hoarding address space by creating multiple ORG-IDs and I cannot support it as such. ARIN2014-18 would not only affect the remaining free pool (which I doubt will be meaningful by the time any policy now being discussed could be implemented), but would also not only allow, but encourage an irresponsible fragmentation of address space for the purpose of monetary gains through specified transfers. 
> 
> Opposition to 2014-18 is not about discriminating against small organizations (anyone who has followed my involvement with ARIN or looks at my voting record would have a very hard time claiming I support such discrimination). While I don’t believe that the policy is intended to do what I have said above, nonetheless, the consequences described are, IMHO, the inevitable result should this policy be adopted and therefore, I oppose the policy as written.
> 
> Owen
> 
> On Sep 3, 2014, at 9:22 AM, Steven Ryerse <SRyerse at eclipse-networks.com> wrote:
> 
>> I've been on projects extensively the last month and a half and only now are getting back to this proposal. Gary, I take your comment below to mean that you are not in favor of making the allocation fair to small organizations. I think there has been a consensus building that it is more difficult for a small organization to get an allocation than a larger one, and I don't see anywhere in ARINs Mission that it is OK to discriminate against small organizations. 
>> 
>> I would also add that needs testing is really a vehicle to somehow save the remaining ipv4 pool we all know the only way to stop that is to stop allocating altogether which of course isn't ARINs mission. As to your comment about being in the Kitchen I would ask you where in ARINs Mission does it say that it is OK to discriminate based on an  Organizations size. 
>> 
>> ARIN 2014-18 is a reasonable attempt to rectify that and I would ask for this communities support. As the Minimum was just reduced to a /24, it is really going to save the remaining ipv4 pool to stop small organizations from getting a /24?  When do we stop rearranging deck chairs on the ipv4 Titanic that can't be saved? 
>> 
>> Steven Ryerse
>> President
>> 100 Ashford Center North, Suite 110, Atlanta, GA  30338
>> 770.656.1460 - Cell
>> 770.399.9099- Office
>> 
>> ℠ Eclipse Networks, Inc.
>>                    Conquering Complex Networks℠
>> 
>> -----Original Message-----
>> From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] 
>> On Behalf Of Gary Buhrmaster
>> Sent: Wednesday, July 23, 2014 12:59 PM
>> To: ARIN
>> Cc: arin-ppml at arin.net
>> Subject: Re: [arin-ppml] Draft Policy ARIN-2014-18: Simplifying 
>> MinimumAllocations and Assignments
>> 
>> On Wed, Jul 23, 2014 at 2:58 PM, ARIN <info at arin.net> wrote:
>>> On 17 July 2014 the ARIN Advisory Council (AC) accepted 
>>> "ARIN-prop-210 Simplifying Minimum Allocations and Assignments" as a Draft Policy.
>>> 
>>> Draft Policy ARIN-2014-18 is below and can be found at:
>>> https://www.arin.net/policy/proposals/2014_18.html
>> 
>> Opposed as written.  I believe that continued needs testing is an important criteria for receiving resources, and this proposal would eliminate justified needs testing.
>> 
>> As to the costs of doing business, well, while I can understand the 
>> those seeking resources may not have properly planned for the costs of 
>> their start up and/or expansion, that is a failure of the requesting
>> organization(s) leaders and their staff, and requesting relief from ARIN policy because of that failure is not an appropriate response.  If it gets too hot in the kitchen, do not be a cook.
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