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<DIV align=left class=OutlookMessageHeader dir=ltr><FONT face=Tahoma
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<DIV>
<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 size=2><FONT face=Arial>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.<BR><FONT color=#0000ff><SPAN
class=559061522-26092002>[Whipple, Scott
(CCI-Atlanta)] </SPAN></FONT></FONT></FONT></DIV>
<DIV><FONT size=2><FONT face=Arial><FONT color=#0000ff><SPAN
class=559061522-26092002>I think this statement is exactly why we have an
organization like ARIN. Of course your company would be glad to
take over allocations (as would the one I work for) it has the
potential to be very profitable. That's why ARIN is a
non-profit organization. You don't only have the work that is
involved in updating the database but you have the actual evaluation of the
requests. Making sure that the requester does actually meet the
requirements. If this policy were to be passed I think the community
should realize that ARIN will need to at least double the size of there
registration services dept. because of the new amount of requests that would
come in. I don't believe that should be a consideration in adopting this
policy but if trying to decide what the fee should be that will have to be a
factor.</SPAN></FONT></FONT></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 size=2><FONT face=Arial>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:<BR><FONT
color=#0000ff><SPAN class=559061522-26092002>[Whipple, Scott
(CCI-Atlanta)] </SPAN></FONT></FONT></FONT></DIV>
<DIV><FONT face=Arial size=2></FONT> </DIV>
<DIV><FONT color=#0000ff face=Arial size=2><SPAN class=559061522-26092002>I
don't personally know how the decision of a /20 came about as the minimum and
would also like the history, but ARIN staff is employed to enforce the
policies that have been adopted by the ARIN membership. If they told you
that you don't meet the minimum requirements I don't think it's because of
your organizations name it's probably because you don't meet the minimum
requirements that are set right now. I think it also has to be stated
that you don't have to get IP space from ARIN to be a member. Anyone
that has $500 can be a member. No matter what the size of your company
you only get one vote on policy issues so the largest ISP has no more
influence then Ma and Pa ISP when it comes to creating or modifying ARIN
guidelines. </SPAN></FONT></DIV>
<DIV><FONT size=2><FONT face=Arial><SPAN class=559061522-26092002><FONT
color=#0000ff> </FONT></SPAN></FONT></FONT></DIV>
<DIV><FONT size=2><FONT face=Arial><SPAN class=559061522-26092002><FONT
color=#0000ff> </FONT></SPAN>1. What is the current global IPv4
usage?</FONT></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 size=2><FONT face=Arial>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?<BR><FONT color=#0000ff><SPAN
class=559061522-26092002>[Whipple, Scott
(CCI-Atlanta)] </SPAN></FONT></FONT></FONT></DIV>
<DIV><FONT size=2><FONT face=Arial><FONT color=#0000ff><SPAN
class=559061522-26092002>I'm sure you can find the answer to any of these
questions if you dig hard enough. If you would like to see them on the
ARIN website then I think that is a valid request.
I also think some of these questions may be debatable and I
would only be for putting information on ARIN's website that are true
statistics. </SPAN></FONT></FONT></FONT></DIV>
<DIV><FONT face=Arial size=2></FONT> </DIV>
<DIV> </DIV>
<DIV><FONT face=Arial size=2>I suggest inviting</FONT><FONT size=2><FONT
face=Arial> 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.<BR><FONT color=#0000ff><SPAN
class=559061522-26092002>[Whipple, Scott
(CCI-Atlanta)] </SPAN></FONT></FONT></FONT></DIV>
<DIV><FONT size=2><FONT face=Arial><FONT color=#0000ff><SPAN
class=559061522-26092002>I'm sure the general public has no clue who ARIN is
and if they do they have all the right in the world to be a
member. I don't think there is such thing as a non-partial
technical, or governmental organization that's why policies and guidelines are
proposed by the ARIN membership who should be the people that the policies
directly effect. I would like to say again that anyone can be an ARIN
member so my suggestion would be if ARIN policies have an affect on your
organization then pay the $500 and become a member so you can vote.
</SPAN></FONT></FONT></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.
</FONT></DIV>
<DIV>
<DIV><FONT size=2><FONT face=Arial>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.<BR><FONT
color=#0000ff><SPAN class=559061522-26092002>[Whipple, Scott
(CCI-Atlanta)] </SPAN></FONT></FONT></FONT></DIV>
<DIV><FONT size=2><FONT face=Arial><FONT color=#0000ff><SPAN
class=559061522-26092002>Again this entire reasoning doesn't have much
weight because anyone in the general public that has concern about ARIN
policies can be involved in shaping them. I also believe that if
ARIN did start to assign blocks longer then a /20 you would find that
there are many ISPs that would filter them out. This is not something
that can be voted on or discussed. It is up to the individual
organizations on how they set up there filters. I'm not sure how it
would help companies to get smaller blocks that probably are not going to be
routable anyway. I know routing is not an ARIN concern but I think
if we are going to change an existing guideline we should take it in
consideration.</SPAN></FONT></FONT></FONT></DIV></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 size=2><FONT face=Arial>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.<BR><FONT color=#0000ff><SPAN class=559061522-26092002>[Whipple,
Scott (CCI-Atlanta)] </SPAN></FONT></FONT></FONT></DIV>
<DIV><FONT size=2><FONT face=Arial><FONT color=#0000ff><SPAN
class=559061522-26092002>Your example here doesn't really help your
cause. At this point it is not against ARIN policy to do IP
based web hosting. If there are organizations that have
wasteful IP practices to get their initial block from ARIN it should directly
effect the ISP that organization is getting space from. ARIN
should also be able to see wasteful IP practices when evaluating an
organizations request. I would think that this has a direct relation to
an approval for an initial block as well as for an additional block to an ISP
that continues to give space to a wasteful
organization.</SPAN></FONT></FONT></FONT></DIV>
<DIV><FONT face=Arial size=2></FONT> </DIV>
<DIV> </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 size=2><FONT face=Arial>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. and/or companies have little power, so its easy to
implement restrictive policies that hurt them. <BR><FONT
color=#0000ff><SPAN class=559061522-26092002>[Whipple, Scott
(CCI-Atlanta)] </SPAN></FONT></FONT></FONT></DIV>
<DIV><FONT size=2><FONT face=Arial><FONT color=#0000ff><SPAN
class=559061522-26092002>I agree with there being organizations out
there that have large amounts of IP space that is not being used. I also
would like to see ARIN undertake a reclamation project but I think at this
point all they could do is ask companies to give space back. ARIN does
not have the teeth it would need to be able to go and take unused space
back. </SPAN></FONT></FONT></FONT></DIV>
<DIV><FONT size=2><FONT face=Arial><FONT color=#0000ff><SPAN
class=559061522-26092002></SPAN></FONT></FONT></FONT> </DIV>
<DIV><FONT size=2><FONT face=Arial><FONT color=#0000ff><SPAN
class=559061522-26092002>I find it very difficult to believe
that when this policy was initially created that it was intended to hurt
smaller companies which to me is what you are insinuating. I also
think everyone should remember that ARIN is the body in which the internet
community has created. This means that the internet community has
the ability to change any of the current guidelines but I think if you want
to change a current guideline you should base the argument on technical
issues and how it would be beneficial to the internet community to have this
new policy instead of arguing how the current policies are
detrimental. </SPAN></FONT></FONT></FONT></DIV>
<DIV><FONT size=2><FONT face=Arial><FONT color=#0000ff><SPAN
class=559061522-26092002></SPAN></FONT></FONT></FONT> </DIV>
<DIV><FONT size=2><FONT face=Arial><FONT color=#0000ff><SPAN
class=559061522-26092002></SPAN></FONT></FONT></FONT> </DIV>
<DIV><FONT size=2><FONT face=Arial><FONT color=#0000ff><SPAN
class=559061522-26092002></SPAN></FONT></FONT></FONT> </DIV>
<DIV><FONT size=2><FONT face=Arial><FONT color=#0000ff><SPAN
class=559061522-26092002></SPAN></FONT></FONT></FONT> </DIV>
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