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<DIV><FONT face=Arial size=2>Proposal 2002-7</FONT></DIV>
<DIV><FONT face=Arial><BR><FONT size=2></FONT></FONT></DIV>
<DIV><FONT face=Arial size=2><U>9/24/2002 Bernard:</U></FONT></DIV>
<DIV><FONT face=Arial size=2>Arin should reduce the current minimum IP
allocation requirement to /21 - /24 if an organization is multihomed and
actively using AS number(s).</FONT></DIV>
<DIV><FONT face=Arial size=2>Arin may periodically inquire and verify that the
multihomed organization<BR>is actively using AS number(s). ARIN may reclaim its
IP's from<BR>organizations that no longer are multihomed and/or stop using
AS<BR>number(s).<BR></FONT><FONT face=Arial size=2>The following new fee
schedule for /21 - /24 should be implemented as<BR> follows (based on the
current fee schedule with a smaller minimum):<BR>$400.00 per year for /23 -
/24<BR>$1000.00 per year for /21 - /22<BR> <BR><U>9/25/2002
Alec</U></FONT></DIV>
<DIV><FONT face=Arial size=2>I do not believe the proposed fees would be fair to
either ARIN or other <BR>ARIN members. I don't think the amount of
work that the ARIN staff would <BR>need to perform for allocations of this
size jibes with the proposed fees.<BR> </FONT></DIV>
<DIV><FONT face=Arial size=2></FONT> </DIV>
<DIV><FONT face=Arial size=2><U>9/26/2002 Bernard:</U></FONT></DIV>
<DIV><FONT face=Arial size=2>Can you explain how much work is involved for ARIN
to perform allocations? If you believe it is too much work for the stated fee,
our company will be glad to take over allocations of a smaller size at half
the stated fees, maintaining and updating the necessary database and any work
needed to process smaller allocations. As an example, NSI (Network
Solutions) used to charge the public $100/two years for one domain and
after competition was introduced, the prices are now as low as $16/two
years.</FONT></DIV>
<DIV><FONT face=Arial size=2></FONT> </DIV>
<DIV><FONT face=Arial size=2>ARIN's policy should be made so it's fair to the
general public not ARIN staff and its members. Your above statement of "not
being fair to ARIN's members" is the clear indication that you lien toward
implementing policies that benefits current ARIN's members not general public. I
don't think that it's fair for ARIN to have you in their Advisory Counsel
since you only have the ARIN's and its best interest in mind not the
general public.</FONT></DIV>
<DIV><FONT face=Arial size=2></FONT> </DIV>
<DIV><FONT face=Arial
size=2>-------------------------------------------------------------------------------------------------</FONT></DIV>
<DIV><U><FONT face=Arial size=2></FONT></U> </DIV>
<DIV><FONT face=Arial size=2><U>9/24/2002 Bernard:</U></FONT></DIV>
<DIV><FONT face=Arial size=2>1. ARIN's current minimum IP allocation policy has
a direct correlation<BR>with the size of a company. Generally a company that
uses a /20 IP<BR>allocation has a larger network and customer base,
therefore they would be<BR>considered in the category of large size companies.
This policy currently<BR>discriminates, puts a small business at a disadvantage
and promotes and<BR> helps to monopolize large ISP's and upstream
providers.<BR> <BR><U>9/25/2002 Alec:</U></FONT></DIV>
<DIV><FONT face=Arial size=2>ARIN's policies were not crafted to discriminate
against anybody. They <BR>were crafted to help manage the resources that
ARIN has responsibility for <BR>(autonomous system numbers and IP
addresses). Contrary to your point <BR>below, the issue with routing table
size relates to routing table <BR>processing (CPU cycles), and not
memory.</FONT></DIV>
<DIV><FONT face=Arial size=2><BR><U>9/26/2002 Bernard:</U> </FONT></DIV>
<DIV><FONT face=Arial size=2>I don't believe that ARIN and ICANN are
elected federal administrative agencies; hence, they have been invoking the
techniques of administrative law and implementing important public
policies. They also have invoked the techniques of consensus; however,
they do not have a working procedure in place that can determine and recognize
consensus. There seems to be a small group of people and/or
volunteers who are not publicly elected and they are arriving at policies
that affect millions of people. There are also ethical questions such
as its membership influence and a monopoly in IP address
allocations.</FONT></DIV>
<DIV><FONT face=Arial size=2>I would like to find out how ARIN has arrived
at the consensus of setting the /20 minimum IP implementation. I do not believe
that this policy which affected millions of people has been implemented in our
ordinary way of invoking public policymaking. I guess we are dealing
with technology and the public does not understant it, so
they accept the policies trusting that someone arrived at it by our
ordinary public consensus procedure. The public enjoys a
government-free-Internet; however, if the current Internet's governing body
takes advantage of its power and invokes bureaucratic methods, I
believe the public would prefer that our government helps to provide
fair and balanced policies. For example, anytime I have called
ARIN's registration services, I've been imediately turned away by their staff;
the first thing they say is: "You are not qualified to receive IPs from us;
you need to get your IPs from your upstream provider." Unless the caller is
WorldCom or some recognized company name, I believe that ARIN has the
pre-determined decision to not provide IPs to non-familiar company names and
assuming that they are a small company. It seems that no startup
small company is ever going to qualify for ARIN's initial IP request.
</FONT></DIV>
<DIV><FONT face=Arial size=2>ARIN has taken the responsibilities of IP addresses
and policymaking. There have been policies regarding minimum IP allocations
of /20; however, I do not see any data analysis from ARIN that can explain
how they arrive at this decision. Since there are restrictive policies like a
minimum /20 in place today, the public should have at least the
following data analysis:</FONT></DIV>
<DIV><FONT face=Arial size=2></FONT> </DIV>
<DIV><FONT face=Arial size=2>1. What is the current global IPv4
usage?</FONT></DIV>
<DIV><FONT face=Arial size=2>2. What is the maximum capability of IPv4 usage?
</FONT></DIV>
<DIV><FONT face=Arial size=2>3. What is the current global IP
allocation?</FONT></DIV>
<DIV><FONT face=Arial size=2>4. How many IPs are available in each regional
registries?</FONT></DIV>
<DIV><FONT face=Arial size=2>5. What is the growth rate per year for
IPv4?</FONT></DIV>
<DIV><FONT face=Arial size=2>6. What are the new capabilities of our
current routers?</FONT></DIV>
<DIV><FONT face=Arial size=2>7. What is the current usage for IPv6?</FONT></DIV>
<DIV><FONT face=Arial size=2>8. How many equipment manufacturers are supporting
IPv6?</FONT></DIV>
<DIV><FONT face=Arial size=2>9. When do you predict we will be using IPv6 as our
main IP usage?</FONT></DIV>
<DIV><FONT face=Arial size=2>10. If IPv6 should take care of our current IP
shortage, why does ARIN continue with its extremly restrictive policies in
allocating and promoting IPv6?</FONT></DIV>
<DIV><FONT face=Arial size=2></FONT> </DIV>
<DIV><FONT face=Arial size=2>I suggest inviting</FONT><FONT face=Arial
size=2> several non-partial technical, governmental and educational
organizations that would analyze the foregoing items
and make a determination that ARIN's current
restrictive policy of a minimum /20 allocation is made for the best
interest of our general public, not just for the benefit of
ARIN's organization and its members.</FONT></DIV>
<DIV><FONT face=Arial size=2></FONT> </DIV>
<DIV><FONT face=Arial size=2>In regard to routers' processing power, the new
routers have increased in both processing power and memory size. As an example,
even within the lower end Cisco 2600 routers series, the new model 2600XM/2691
has a processing power increase of 33%-50% and holds two to four times more
memory than the old 2620 model. Also, with less than $4000.00, a person
could build a Linux router/server with dual Xeon or dual Athlon processors,
4 GB PC2100 DDR SDRAM and two T1 CSU/DSU cards. Are you telling us
that dual Xeon processors and 4 GB PC2100 DDR SDRAM is not enough to run
BGP?<BR></DIV>
<DIV>
<DIV><FONT face=Arial size=2>
<DIV><FONT face=Arial
size=2>-------------------------------------------------------------------------------------------------</FONT></DIV></FONT></DIV>
<DIV><U></U> </DIV>
<DIV><FONT face=Arial size=2><U>9/24/2002 Bernard:</U></FONT></DIV></FONT></DIV>
<DIV><FONT face=Arial size=2> 2. Currently, many ISP's and upstream
providers are in bankruptcy and/or<BR> have gone out of business;
therefore, getting IP's from upstream<BR>providers is no longer a good solution
since small businesses will have<BR> the disadvantage of returning and
re-numbering their IP's.<BR><BR>3. Once a small business obtains IP addresses
from their upstream<BR>providers, upstream providers are able to hold that small
business<BR>"hostage" and increase their rate without any consequences, because
the<BR>level of difficulty to move to another upstream provider is great
and<BR>could put the small company out of business.<BR> <BR><U>9/25/2002
Alec:</U></FONT></DIV>
<DIV><FONT face=Arial size=2>Renumbering is not always trivial, but at the same
time it is not <BR>impossibly hard either. Things like DNS and DHCP make
the process <BR>bearable, especially for small amounts of address
space.<BR> <BR><U>9/26/2002 Bernard:</U></FONT></DIV>
<DIV><FONT face=Arial size=2>A small business and/or ISP could be running
hundreds of sites under virtual hosts and have colocation customers who run
hundreds of sites under their virtual host servers. There is no flip of a switch
to change IP addresses; there is a gray area of time when customers will be out
of service. The process of changing IP's requires a company to change the DNS
server's IP addresses for all of their sites, then send a request to
Network Solutions to make their changes; hundreds of sites will go down
until the proper changes can be made. Thousands of web sites and
emails would likely go down because the logistics, timing and
coordination of a vast number of people is overwhelming for a small
company. This process also requires the re-numbering of hosts and DNS
server's data. A small ISP could lose customers when the customers
find out that they are using IP's from upstream providers that
are in bankruptcy and/or financial trouble, which happened in cases such as
WorldCOM, XO, Global Crossing, PSInet, @home, ZipLink, ICG, CAIS, E.SPIRE,
William Communications, WinStar, Northpoint, Rhythms, Flashcom and more.
</FONT><FONT face=Arial size=2>The small ISPs would lose customers and the big
ISPs could capture the small ISPs' customers. This is one of the ways
that ARIN's policy hurts small businesses.</FONT></DIV>
<DIV><FONT face=Arial size=2></FONT> </DIV>
<DIV><FONT face=Arial size=2>
<DIV><FONT face=Arial size=2>
<DIV><FONT face=Arial
size=2>-------------------------------------------------------------------------------------------------</FONT></DIV></FONT></DIV>
<DIV><FONT face=Arial size=2><U></U></FONT> </DIV>
<DIV><FONT face=Arial size=2><U>9/24/2002 Bernard:</U></FONT></DIV></FONT></DIV>
<DIV><FONT face=Arial size=2>4. The global routing table and its minimum
allocation requirement must<BR>be investigated by several third party technology
companies, who are<BR>non-partial and do not benefit from ARIN's decision in any
way. They<BR>could determine what is the best minimum requirement in order for
the<BR> Internet to run at its optimum and without any routing table
problems.<BR> <BR><U>9/25/2002 Alec:</U></FONT></DIV>
<DIV><FONT face=Arial size=2>Given this suggestion I don't see why a specific
minimum of /24 was <BR></FONT><FONT face=Arial size=2>proposed in this
proposal. However, ARIN is a perfect example of a body <BR>that does
not benefit from ARIN's policies. ARIN has an advisory council <BR>that is
elected by its membership and whose job it is to consider the <BR>technical
impact of ARIN's policies. In the interest of disclosure, I <BR>currently
sit on the ARIN AC.<BR></FONT></DIV>
<DIV><FONT face=Arial size=2>
<DIV><FONT face=Arial size=2><U>9/26/2002 Bernard:</U></FONT></DIV></FONT></DIV>
<DIV><FONT face=Arial size=2>As you mentioned, ARIN's current advisory
council is elected by its members. This means that ARIN's current advisory
counsel is partial and could implement and favor policies that
benefit its members. </FONT><FONT face=Arial
size=2>There should be an advisory counsel and/or technical and/or
government organizations that are non-partial to ARIN and/or its members
who could analyze and study ARIN's policy carefully and determine its
technical and/or public communications and trade impact. </DIV>
<DIV>
<DIV><FONT face=Arial size=2>ARIN also claims that the Internet community voted
for their current policies. I believe that ARIN's current restrictive
policies, that are directly affecting general public, are implemented
by a small group of people. ARIN's policymaking is not exercised
within our ordinary understanding of public power and public
policymaking.</FONT></DIV></FONT></DIV>
<DIV><FONT face=Arial size=2></FONT> </DIV>
<DIV><FONT face=Arial
size=2>-------------------------------------------------------------------------------------------------</FONT></DIV>
<DIV><FONT face=Arial size=2></FONT> </DIV>
<DIV><FONT face=Arial size=2>
<DIV><FONT face=Arial size=2><U>9/24/2002 Bernard:</U></FONT></DIV></FONT></DIV>
<DIV><FONT face=Arial size=2> 5. ARIN's current policy of the minimum
requirement of /20 addresses<BR> promotes IP usage and reduces the ability
to conserve IPs, such as<BR> virtual hosting, for web sites. Companies now
have to come up with<BR> wasteful uses for IPs that they don't really need,
just to qualify for the<BR>current policy minimum.<BR> <BR>
<DIV><FONT face=Arial size=2><U>9/26/2002 Alec:</U></FONT></DIV></FONT></DIV>
<DIV><FONT face=Arial size=2> I don't think I follow this. Is the
assertion that if IP addresses are <BR>essentially available with no
requirements that people will use them more <BR>wisely? I believe
history has shown that engineers typically do what is <BR>easiest, and
often it is easiest to be wasteful with address space <BR>reguardless of the
available supply.<BR></DIV></FONT><FONT face=Arial size=2></FONT>
<DIV><FONT face=Arial size=2>
<DIV><FONT face=Arial size=2><U>9/26/2002 Bernard:</U></FONT></DIV></FONT></DIV>
<DIV><FONT face=Arial size=2>If the only way that small companies
and/or organizations are going to be approved for ARIN's
restrictive IP requirement is to use a lot of IP addresses. Small
companies and/or organizations have no other choice other than to
switch their web servers from "virtual hosts" to "regular host per IP" and
stop using NAT in order to qualify for ARIN's minimum IP
requirements.</FONT></DIV>
<DIV><FONT face=Arial size=2></FONT> </DIV>
<DIV><FONT face=Arial
size=2>-------------------------------------------------------------------------------------------------</FONT></DIV>
<DIV><FONT face=Arial size=2></FONT> </DIV>
<DIV><FONT face=Arial size=2>
<DIV><FONT face=Arial size=2><U>9/24/2002 Bernard:</U></FONT></DIV></FONT></DIV>
<DIV><FONT face=Arial size=2>6. ARIN's current policy automatically qualifies a
multihome<BR>organization to obtain an AS number. There isn't any minimum
IP<BR>requirement to obtain AS numbers and AS numbers have the direct effect
of<BR>increasing the global routing table.<BR></DIV></FONT>
<DIV><FONT face=Arial size=2>
<DIV><FONT face=Arial size=2><U>9/25/2002 Alec:</U></FONT></DIV></FONT></DIV>
<DIV><FONT face=Arial size=2>AS numbers are merely identifiers on routes, an
increase in the number of <BR>AS numbers allocated does not cause the routing
table size to increase.<BR></DIV></FONT>
<DIV><FONT face=Arial size=2>
<DIV><FONT face=Arial size=2><U>9/26/2002 Bernard:</U></FONT></DIV></FONT></DIV>
<DIV><FONT face=Arial size=2>Then why can't we allocate smaller IP allocations
to multihomed networks that are using AS numbers?</FONT></DIV>
<DIV><FONT face=Arial size=2></FONT> </DIV>
<DIV><FONT face=Arial size=2>
<DIV><FONT face=Arial size=2>
<DIV><FONT face=Arial
size=2>-------------------------------------------------------------------------------------------------</FONT></DIV></FONT></DIV>
<DIV><U></U> </DIV>
<DIV><FONT face=Arial size=2><U>9/24/2002 Bernard:</U></FONT></DIV></FONT></DIV>
<DIV><FONT face=Arial size=2>7. Regarding the global routing table issue, memory
is very inexpensive<BR> now, and Cisco is introducing new router models
with a larger D-RAM size,<BR> that are reasonably priced and affordable by
small businesses.<BR> <BR>
<DIV><FONT face=Arial size=2><U>9/25/2002 Alec:</U></FONT></DIV></FONT></DIV>
<DIV><FONT face=Arial size=2>This is 100% correct, and 100% irrelevant.
Memory is no longer the <BR>limiting factor with respect to routing table size
(it used to be, back in <BR>the AGS/7000 days). Now the issue is the
number of CPU cycles it takes for <BR>a router to generate its own view of the
Internet based on the BGP feeds it <BR>receives.<BR></FONT></DIV>
<DIV><FONT face=Arial size=2>
<DIV><FONT face=Arial size=2><U>9/26/2002
Bernard:</U></FONT></DIV></DIV></FONT><FONT face=Arial size=2>
<DIV><FONT face=Arial size=2>In regard to routers' processing power, the new
routers have increased in both processing power and memory size. As an example,
even within the lower end Cisco 2600 routers series, the new model 2600XM/2691
has a processing power increase of 33%-50% and holds two to four times more
memory than the old 2620 model. Also, with less than $4000.00, a person
could build a Linux router/server with dual Xeon or dual Athlon processors,
4 GB PC2100 DDR SDRAM and two T1 CSU/DSU cards. Are you telling us
that dual Xeon processors and 4 GB PC2100 DDR SDRAM is not enough to run
BGP?<BR></DIV>
<DIV></FONT></FONT><FONT face=Arial size=2><FONT face=Arial
size=2></FONT></FONT> </DIV>
<DIV><FONT face=Arial size=2><FONT face=Arial
size=2>-------------------------------------------------------------------------------------------------</FONT></DIV></FONT>
<DIV><FONT face=Arial size=2></FONT> </DIV>
<DIV><FONT face=Arial size=2>
<DIV><FONT face=Arial size=2><U>9/24/2002
Bernard:</U></FONT> </FONT></DIV></DIV>
<DIV><FONT face=Arial size=2>8. Theoretically, there are 4 billion IPv4
addresses available. Out of<BR>that, only a small fraction of them
(Approx. 100 million) are being used<BR>and approx. 2.3 billion are being
allocated. This makes the current<BR>minimum allocation policy not practical.
Large organizations are sitting<BR>on an exorbitant amount of IP addresses that
they are not using and/or not<BR>capable of ever being used. As an example,
there is a company that owns<BR>approximately 7 million IP addresses and has
roughly 153,000 employees<BR>(employees as of Nov, 1999). What is the
justification for receiving<BR>such large IP space, when a small business is not
allocated any IP space?<BR><BR>
<DIV><FONT face=Arial size=2><U>9/25/2002 Alec:</U></FONT></DIV></FONT></DIV>
<DIV><FONT face=Arial size=2>Poor historical allocation policies should not be
justification for making <BR>the same mistakes all over again.</FONT></DIV>
<DIV><FONT face=Arial size=2></FONT> </DIV>
<DIV><FONT face=Arial size=2>
<DIV><FONT face=Arial size=2><U>9/26/2002 Bernard:</U></FONT></DIV></FONT></DIV>
<DIV><FONT face=Arial size=2>Why doesn't ARIN go to the companies that are
squandering and wasting the valuable IPs that in shortage, and ask them to be
returned; that would be a good policy. Yes, the allocations have
already been made to all of the large and powerful companies
and organizations, and now the small companies are left needing them as
well. Small organizations and/or companies have little power, so its easy to
implement restrictive policies that hurt them.
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