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<DIV dir=ltr align=left><SPAN class=809441119-27102008><FONT face=Arial
color=#0000ff size=2>I would not support this policy. I have enough annual
admin tasks the way it is. I remember the trouble I have had providing
"sufficient" documentation for each of my allocations. I would resist any
effort to assess fees for "insufficient" documentation.</FONT></SPAN></DIV><BR>
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<FONT face=Tahoma size=2><B>From:</B> arin-ppml-bounces@arin.net
[mailto:arin-ppml-bounces@arin.net] <B>On Behalf Of </B>Chris
Grundemann<BR><B>Sent:</B> Monday, October 27, 2008 1:53 PM<BR><B>To:</B> ARIN
PPML<BR><B>Subject:</B> [arin-ppml] The Library Book Approach to IPv4
Scarcity<BR></FONT><BR></DIV>
<DIV></DIV>This is (yet another) a policy that may help us ease away from
IPv4, maintain contact between ARIN and it's members and maybe even avoid a
transfer market. I have been kicking the general idea around for over
six months and it has recently matured with input from some very intelligent
folks. I do not want to associate them with this particular idea
unwittingly so I won't name them here but I would like to thank them here
anonymously - thank you. It is not an official proposal yet as I fear
that there won't be much support for it. If you do think that this is a
good idea or at least on the right track, please let me know - on or off
list. I don't want to bang my head against the wall too long if I am
alone. Also, if you hate it, think I am crazy or just don't think it
will work, I would love to hear why. Although many have influenced
it, this is my work and my opinion alone and does not represent the views of
any organization or individuals I may be affiliated with. ((IMHO))<BR>Thank
you,<BR>~Chris<BR><BR><BR>== Potential Proposal:<BR><BR>Once every 12months
each holder of IPv4 addresses is required to fully document their IP
utilization and demonstrate that the current utilization standard for IPv4
assignments and allocations is being met. This shall include all currently
held IPv4 space, regardless of origin or registration status.<BR><BR>A fee
shall be assessed for underutilization or insufficient
documentation.<BR><BR> * The fee for one 12m period shall be
waived if the address holder returns a contiguous block of IPv4 space equal to
at least 1/256th of currently held space and no less than one /24 (class C
equivalent) to ARINs free pool.<BR> * The fee for one 12m
period shall be waived if the address holder signs an ARIN RSA for any
uncontested and unregistered IPv4 space, this waiver shall be restricted to
one use per member organization.<BR><BR><BR>== Rationale:<BR><BR>IP space (v4,
v6, vX) is a public resource and as such should be borrowed, used and returned
by those with a need for it. Think of IPv4 prefixes like library books
(another finite public resource): When you check out a book, you are expected
to return it on a certain date. If that date comes and you are still actively
using the book, you are allowed to state that and keep the book. Since we are
at a point now where IPv4 space is recognizably finite, it makes sense to
implement a similar policy at the RIR(s) - that is a time frame. This policy
would require that after X amount of time, the LIR/EU would need to return to
the RIR with justification if they wish to keep the space. The burden should
be on the LIR/EU to prove that they are actively using the
space.<BR><BR><BR>== Some thoughts:<BR><BR>1) This policy should be part of a
comprehensive plan including:<BR>- A policy to identify abandoned space<BR>- A
policy to reclaim abandoned space<BR>- A policy to restrict some (if not all)
IPv4 space allocations/assignments to new entrants deploying IPv6<BR>- A
continuing increase in utilization requirements<BR><BR>2) I do worry that some
(perhaps many) will try to game the system by exaggerating or falsifying
'proof' of efficient utilization. At the same time I think that having that
caveat will make this much easier for most to swallow and hopefully accept
than a similar proposal which assessed the fee to all holders of IPv4 space
regardless of utilization. The idea (hope) is that as IPv4 becomes more and
more scarce, the community will raise the utilization requirements to include
things like NAT and IPv6. This would provide a constant pressure on all
community members to become more efficient in their IPv4 use which in turn
should help keep some addresses free for new entrants. This is the opposite
effect of an unrestricted market based approach which would encourage large
holders of addresses to hold more and more IPv4, to store value and bar new
competition.<BR><BR>3) I am not sure what the fee should be or if it should be
spelled out in policy, this is probably something that ARIN staff should set
and be able to change when needed. Perhaps the policy should define simply how
the fee is assessed, ie: per IP or per % underutilized, etc. It may also be
helpful or necessary to add a statement in the policy requiring any proceeds
from these fees to be used for something in particular (legacy outreach, IPv6
promotion, payment/credit to orgs with utilization above the efficiency
requirement, etc).<BR><BR>4) I expect that some (possibly many) organizations
will find it easier to simply return some space than even trouble themselves
with trying to justify their current holdings. This will be especially true of
organizations which hold large amounts of space.<BR><BR>5) I am expecting that
bringing resources under an ARIN RSA may be easier and less painful for
organizations which already hold other RSA covered space than a full IP audit
or returning space. Under this assumption the final sentence has two
goals:<BR>A) To help incent organizations to secure legacy space in any
existing or inevitable grey/black market early on (and get it over with). If
there are no back-room deals for exchange of legacy space now or in the
future, than this is not an issue and can be ignored, this policy will have no
affect in this area.<BR>B) To get any transfered legacy IPv4 space (see point
A) under an RSA so that we are all playing on the same field by the same
rules. I think if everyone had a more similar role in the game we might work
together better. I will note however that legacy holders with no RSA
covered space have no increased incentive to sign an RSA under this proposal
then they do today (and no increased risk in not signing one).<BR><BR>6) I
originally considered a period of 24 months but shortened it to 12 months
considering the rapid approach of IANA free pool exhaustion; 24 months will be
far to long of an interval to have a significant impact on IPv4
availability.<BR><BR clear=all><BR>-- <BR>Chris Grundemann<BR><A
href="http://www.chrisgrundemann.com"
target=_blank>www.chrisgrundemann.com</A><BR><A
href="http://www.linkedin.com/in/cgrundemann"
target=_blank>www.linkedin.com/in/cgrundemann</A><BR></BLOCKQUOTE></BODY></HTML>