Comments on Name Based Virtualk Hosting Policy Recommendation

[A. M. Salim]

Hi,

The POLICY simply states that the ISP will provide "technical
justification", and that ARIN will review it in the light of "OPERATIONAL
EXPERIENCE".

a) I feel these terms need elaboration, otherwise there is immense room
for individual interpretation by the reviewer.

b) Is the intent of this policy to coax small ISP's out of business?  If
not, please be aware that this is what I am currently staring at in the
face, a a direct result of this policy recommendation.  Here is a real
life example:

I am currently using 6-7 class C's (quite efficinelty by my reckoning but
who knows how ARIN's reviewer will judge it on any given day).

My current provider decided to give up their ISP business six months ago
and asked a third party company to take over being the upstream ISP for
all their existing customers, myself included (for reasons unrelated to
me, for their own business reasons). The new ISP is steadfastly refusing
to grant me more than 1.5 class C's not because I can't justify them and
not because they have studied my justification and decided I don't need
that many IP's, but because they are scared that ARIN's new policy will
force them to return IP's they have been allocated etc. etc.

They are specifically pointing to the "Last Call for Name-based Web
Hosting Policy Recommendation" on http://www.arin.net/.  True, it can be
argued that they should not be referring to that page, that they are being
unreasonably cautious etc. etc. but the hard facts remain that they are
taking this position on the basis of this "Last Call for Name-based Web
Hosting Policy Recommendation" and I am a victim of it.  I do not have the
luxury of debating their position with them.

If I do not get my 6 class C's in the next 20 days, I am dead.

ARIN's wordings needs to change asap!

I recommend the following be phrased into the wording of the policy and/or
best practice:

a) that the policy duly take into account existing allocations and not
force existing allocations to be squeezed/returned when the ISP can show
unreasonable business distress would result from this requirement to them
or their client(s).

b) when an ISP requests an allocation of two or more class C IP's to
replace an allocation that is equal in size to an existing allocation that
they currently have been using from their existing provider (for say at
least 6 months or 1 year or some suitable grandfather period) that request
should be granted regardless of size of requested allocation, and
regardless of whether it is being efficiently used or not, provided they
agree to return a portion of it to the pool within 18 months, the portion
to be returned being decided by mutual discussion between ARIN and the
ISP, and provided that this request is being made because the requesting
ISP is changing their upstream provider and will no longer be using the IP
allocation being replaced, and that the new and old providers are in
agreement with the request.

(Why 2 or more clas C's and not 16 and not 1?  If someone is using just 1
class C, chances are they are not an ISP.  If they are using 2, chances
are very high they are an ISP of one kind or another. By the same token
there are many ISP's who do not yet use 16 C's but maybe 5 or 6 or 12, and
that is by no means a negligible "drop in the bucket" number.  If less
than 16 Class C's is a negligible amount, then there would not be such a
fuss about IP shortages in the first place!).

best regards
Mike.