ARIN Justified..

[Clayton Lambert]

Answers/comments are inline:

-----Original Message-----
From: Charles Scott [mailto:cscott at gaslightmedia.com]
Sent: Wednesday, January 10, 2001 6:47 PM
To: Clayton Lambert
Cc: bmanning at vacation.karoshi.com; 'Gilbert Martin @ Learning
Solutions'; 'Joe DeCosta'; 'Chris Miller'; 'Jim Macknik'; vwp at arin.net
Subject: RE: ARIN Justified..



Clayton:
  So you're saying that nobody is going to be asked to change existing
operations from IP to name based hosting in order to justify additional
address space?

++ I am not saying that people wouldn't try that, but the escalation to ARIN
would allow for nonsense to get straightened out pretty simply.  There
should be a supporting statement to the policy that clearly defines what is
acceptable with regards to previous allocations...And that points out the
fundamental: The planned growth would have been accounted for in the LAST
assignment request...Right?  And, that would eliminate 99.5% of this
particular element.

 If you agree, then what about hosting that's in progress
but not yet deployed.

++ Again, in progress should already be accounted for in the previous
assignment.  If it wasn't, the maintainer should have the discretion to
handle the case, or they could escalate it to ARIN (with supporting
documentation).

Continuing from there, how much time should be
permitted for a company to move to a model that's compatible with name
based hosting, a couple months, a couple years?

++ This would fall under the technical justification.  Nothings easy.
Companies that have had it easy will have to buckle down and comply with the
policy.  Case by case basis can be addressed at the maintainer level and
escalations can be passed to ARIN.

+++ The policy should be implemented immediately and should have a grace
period of 6 months.  The grace period should be as I described above, such
that the Maintainer would have discretion (during the 6 month period)
similar to the "Technical Justification" discretion on the policy...This
would provide the added benefit of allowing the Maintainers and ARIN to
'shake down' the escalation process.  After the 6 months, the policy would
be in full effect and the "previous assignment" methodology would be in
force.


 One thing is for sure,
changing the way you do business isn't easy and it takes time.

++ Agreed, but we have all (in the Internet arena) gotten pretty good at
being fast on our feet...This ability could be applied towards getting in
line with IP conservation as well as we handle the 'growth' in our industry.

 Clearly
that should be justification for some period of time and clearly the
current momentum of a business model needs to be a component of
justification.

++  this would fall into the 6 month grace period.  As webhosting is
"service providing" it should be on a 90 day cycle anyway, not a 50%@12month
model...This would indicate two full cycles of assignment/allocation for the
requesters to make accurate projections and document their usage (and any
technical justification) before the grace period would end.

  Also, policy and business model must have some bearing on justification
because it is one's policies and models that makes a business successful.
If in order to impliment a competative business model there is a need for
IP based hosting (such as bandwidth profiling) then isn't that as valid as
something like technical justification for giving dial-up/DSL/cable
customers globally routable addresses space.

++  Agreed, on the policy and bizz model stuff...But, if a company tracks
anything via the IP address and that method of tracking isn't limited due to
something protocol specific, the justification isn't there.  Again, vendor
specific limitations should NOT be considered a technical justification.

I personally think that
forcing a business to change their model in order to obtain future
allocations is perhaps more intrusive than forcing the holder of a largely
unused allocation to renumber to free up space, and perhaps may be as
likely to trigger legal challenges.

++  I don't think it would trigger any more legal challenges than those that
already occur due to current IP allocation/assignment limitations, rules,
and policies.

++ In fact, a well defined policy is more difficult to litigate against...As
opposed to the current ambiguous, nebulous, gray-area based policy that is
in place.


  I just can't see these as separate issues, since both the reclamation of
unused address space and reasonable efficiency in consumption relate
directly to minimizing future impact of a limited resource. Targeting one
without targeting the other is clearly not a balanced and reasonable
approach.

++ Boy, I definitely agree with you on this one :-)  However, I think the
policy for Efficient IP usage.  I think it is a HUGE MISTAKE to call this
the "web-hosting" or "virtual hosting" policy! Referring to this policy as
anything specific as those, would unfairly single out the webhosting
community.  This policy should be squarely aimed at efficiency of use.  As
such, it should define "Service Providing" as a high level description.
There are multiple types of "Service Providing" such as ISP, ASP, MSP, as
well as webhosting (WSP or HSP?).

Clayton Lambert
Compliance Services Director,
Exodus Communications











Chuck


On Wed, 10 Jan 2001, Clayton Lambert wrote:

> requiring past allocations to adhere to a new policy is not what was
> discussed. Recovering vast amounts of previously allocated (and UNUSED) IP
> address space is an entirely DIFFERENT subject.
>
> I would not suggest applying new policies to existing USAGE.  Remember,
> recovering unused IP space from /8s that are floating around out there is
> not the same as establishing a clearly defined, efficiency focused IP
> address usage policy that allows for exceptions but does require technical
> reasons (in the form of documentation) for not adhering to that policy.
It
> should be clear in stating that policy and business model are NOT
> justification (as they are not technical reasons).  On the same line, I
> think a technical justification exceptions should be protocol-based, not
> vendor based.
>
> On Wed, 10 Jan 2001 bmanning at vacation.karoshi.com wrote:
>
> > 	"grandfathered" delegations have been done so for a reason.
> > 	changing the rules after the fact and forcing renumbering
> > 	will bring legal challanges.
>
>   This is a good point, but the same can be said of existing allocations
> when trying to justify additional address space. In otherwords, if a
> hosting service has currently deployed IP based hosting, which was
> necessary/reasonable/acceptable in the past, it would seem to be unfair to
> refuse additional address space until those conform to a new policy
> (which may require significant time and expense).
>
> Chuck Scott
> Gaslight Media