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Today's Topics:

   1. Re: ARIN-PPML Digest, Vol 94, Issue 3 (John Curran)
   2. Re: Draft Policy ARIN-2013-3: Tiny IPv6 Allocations for ISPs
      (John Curran)
   3. Re: Draft Policy ARIN-2013-3: Tiny IPv6 Allocations for ISPs
      (Matthew Kaufman)
   4. Re: Draft Policy ARIN-2013-3: Tiny IPv6 Allocations for ISPs
      (Matthew Kaufman)
   5. Re: Draft Policy ARIN-2013-3: Tiny IPv6 Allocations for ISPs
      (Matthew Kaufman)
   6. Re: Draft Policy ARIN-2013-3: Tiny IPv6 Allocations for ISPs
      (Michael Sinatra)
   7. Re: Draft Policy ARIN-2013-3: Tiny IPv6 Allocations for ISPs
      (John Curran)


----------------------------------------------------------------------

Message: 1
Date: Sun, 7 Apr 2013 03:36:48 +0000
From: John Curran <[email protected]>
To: MsRachelleCross/GM <[email protected]>
Cc: "[email protected]" <[email protected]>
Subject: Re: [arin-ppml] ARIN-PPML Digest, Vol 94, Issue 3
Message-ID:
        <[email protected]>
Content-Type: text/plain; charset="us-ascii"

On Apr 3, 2013, at 11:56 AM, MsRachelleCross/GM <[email protected]> 
wrote:

> We are ARIN. Therefore, it's our jobs to ensure safety on the Internet.  I 
> personally know of several IP hosts who have violated intellectual genre, and 
> (c) laws, having taken over people's Domains after providing service. There 
> are other people out here who's entire IPv6 networks get hacked. People have 
> related stories of losing information off of all their computers, mainframe, 
> and all software licenses.
>   Sirs, will any of the new protocol protect innocent everyday people, making 
> the Internet safe for everyone, and not just those of us with technical 
> knowledge?
>    I would very much appreciate an opportunity to work with your team if I 
> can be of assistance.
> 
> Namaste,
> Rev Rachelle C.Navarro

Rev Rachelle C.Navarro -

  My apologies for not responding earlier, and do hope that this
  response finds you well.

  You are correct: We (the community participating on this list)
  are ARIN.  ARIN strives to maintain open participation and it
  is fair to characterize those on this list as shaping how ARIN
  accomplishes its mission.

  The mission of ARIN is focused on the administration of the IP 
  address space in this region, and not per se on ensuring "safety 
  on the Internet"  It is true that some aspects of administering
  IP addresses will have implications for safety on the Internet, 
  but actually ensuring that outcome is a much bigger job requiring 
  many more participants and the balancing of various public policy 
  concerns of governments & law enforcement with due consideration
  to civil society and human rights.
 
  There is no central body which ensures "safety on the Internet"
  but you can find the topic discussed at the "Internet Governance
  Forum" (IGF), which is an open forum for multi-stakeholder policy 
  dialogue about the Internet, including public policy issues such
  as sustainability, robustness, security, stability and development 
  of the Internet.  You can find out more information on the IGF
  here <http://www.intgovforum.org/> such how to participate in their 
  workshops and conferences (including remote participation options)

  If you have any questions or would like to discuss this further, 
  please feel free to contact me directly at <[email protected]>

Thank you!
/John

John Curran
President and CEO
ARIN



------------------------------

Message: 2
Date: Sun, 7 Apr 2013 03:44:12 +0000
From: John Curran <[email protected]>
To: Blake Dunlap <[email protected]>
Cc: "[email protected] List" <[email protected]>
Subject: Re: [arin-ppml] Draft Policy ARIN-2013-3: Tiny IPv6
        Allocations for ISPs
Message-ID:
        <[email protected]>
Content-Type: text/plain; charset="iso-8859-1"

On Apr 5, 2013, at 1:20 PM, Blake Dunlap <[email protected]> wrote:

> I also opposed minimums for ISPs below /32 based on an issue of business 
> model for ARIN. Fix the billing problem, or the board membership problem, 
> don't try to make this a technical solution to a business problem.

Blake - 
 
  There is not any business problem - the Revised Fee schedule lowers fees 
  for smaller ISPs even under present IPv6 allocation policy, as ISPs already 
  have the option to request a /36 allocation per existing NRPM 6.5.2.

Thanks,
/John

John Curran
President and CEO
ARIN



------------------------------

Message: 3
Date: Sat, 06 Apr 2013 22:07:08 -0700
From: Matthew Kaufman <[email protected]>
To: [email protected]
Subject: Re: [arin-ppml] Draft Policy ARIN-2013-3: Tiny IPv6
        Allocations for ISPs
Message-ID: <[email protected]>
Content-Type: text/plain; charset=ISO-8859-1; format=flowed

On 4/5/2013 9:41 AM, Kevin Kargel wrote:
> I am still trying to figure out how having one *additional* database entry 
> costs $1000/year.

How about why the same number of database entries but different bits set 
costing different amounts?

None of it really makes sense in the world of IPv6. Clearly the cost to 
maintain the entry for a single IPv6 /24 is no more or less than a 
single IPv6 /32 or /40, but there is some attempt to charge more to orgs 
that can afford to pay more here I guess.

Matthew Kaufman



------------------------------

Message: 4
Date: Sat, 06 Apr 2013 22:14:14 -0700
From: Matthew Kaufman <[email protected]>
To: [email protected]
Subject: Re: [arin-ppml] Draft Policy ARIN-2013-3: Tiny IPv6
        Allocations for ISPs
Message-ID: <[email protected]>
Content-Type: text/plain; charset=ISO-8859-1; format=flowed

On 4/6/2013 12:00 PM, Michael Sinatra wrote:
> On 03/27/13 17:45, David Farmer wrote:
>> On 3/27/13 18:00 , Michael Sinatra wrote:
>>
>>> Or, to put more bluntly, if ARIN's fee structure is itself creating
>>> disincentives for proper IPv6 adoption, then let's go back and (re-)fix
>>> that problem.
>>>
>>> Oppose 2013-3.
>> Michael and others opposed,
>>
>> What about modifying the proposal to /40, require a minimum reservation
>> of /32 (or maybe /28) be held for ISPs that elect for /40 or /36
>> allocations, allow subsequent allocations to expansion from /40 to /36
>> and then to /32 without evaluating there current IPv6 usage.  Thereby
>> ensuring they can grow their allocation in place and allowing policy
>> flexibility that enables the fee structure equity that the new xx-small
>> category seems to provided.
> Sorry to be responding to an earlier part of the thread, but I was on
> vacation and lost track of this thread, and you did ask me a direct
> question.  I owe you the courtesy of an answer.
>
> The answer to your question is no.  If I start out with a /40 or /36 and
> then rapidly grow into a /32 (and can justify the fees), then I am going
> to end up with a largely organic addressing plan.  We're giving
> incentives for people to cram all of their addressing into a corner of
> the total space that they should be using and it will create a really
> messy IPv6 deployment.

Worse, we're creating a messy IPv6 situation downstream... as Owen 
points out, this type of financial pressure towards false conservation 
is going to give us things like /64-per-household instead of something 
sensible that lets the thermostat be on a different subnet than the Xbox.

We should be telling ISPs of all sizes "IPv6 is huge... come get a /32 
or bigger... do sensible things when you make your addressing plans... 
do sensible things when you sell service to your customers" and not 
"here's a way to save a buck by pretending IPv6 is like IPv4"

You're right (in the part below that I deleted)... the bug is the fee 
structure and there's absolutely no reason to try to muck with the 
policy, which can't possibly fix the real problem.

Matthew Kaufman


------------------------------

Message: 5
Date: Sat, 06 Apr 2013 22:18:33 -0700
From: Matthew Kaufman <[email protected]>
To: [email protected]
Subject: Re: [arin-ppml] Draft Policy ARIN-2013-3: Tiny IPv6
        Allocations for ISPs
Message-ID: <[email protected]>
Content-Type: text/plain; charset=ISO-8859-1; format=flowed

On 4/5/2013 10:27 AM, William Herrin wrote:
> On Fri, Apr 5, 2013 at 1:12 PM, David Farmer <[email protected]> wrote:
>> Furthermore, there are no obvious solutions to this problem within the fee
>> structure domain that are fiscally responsible and sustainable for ARIN,
>> especially in the long-term.
> Hi David,
>
> The obvious solutions within the fee structure are:
>
> 1. The non-profit discount
>
> 2. No-fee IPv6 for IPv4 holders until IPv6 becomes dominant
>
>
> #2 solves the short-term problem of folks who won't spend money on a
> protocol that won't yet make them money while #1 addresses the
> community network need.

For those community or other non-profit networks for which that discount 
is sufficient.

In my case my legacy-numbered IPv4 network isn't getting IPv6 until IPv6 
is free or enough money is made selling the IPv4 space to create a fund 
to pay for the IPv6 fees.

But this is largely tangential to the  issue at hand, which is that at 
the very least we should be giving nothing smaller than /32 to an ISP 
that is paying for their registration. If the board can't figure out how 
to charge small ISPs a small enough fee with an allocation policy of 
no-smaller-than-/32 (which is what it should be, despite the current 
availability of /36), then maybe they're not doing their job with regard 
to encouraging IPv6 deployment... but we're not going to magically fix 
that with a change to allocation policy without breaking a lot of other 
things that could be good about IPv6 in the process.


Matthew Kaufman



------------------------------

Message: 6
Date: Sun, 07 Apr 2013 02:02:25 -0700
From: Michael Sinatra <[email protected]>
To: John Curran <[email protected]>
Cc: "[email protected] PPML" <[email protected]>
Subject: Re: [arin-ppml] Draft Policy ARIN-2013-3: Tiny IPv6
        Allocations for ISPs
Message-ID: <[email protected]>
Content-Type: text/plain; charset=windows-1252

On 04/06/13 19:31, John Curran wrote:
> On Apr 6, 2013, at 12:00 PM, Michael Sinatra <[email protected]> 
> wrote:
> 
>> The second issue is that it's not even clear what the goals of the fee
>> schedule are.  
> 
> <https://www.arin.net/fees/faq_fee_schedule.html>
> "   
>    ARIN adopted the new Fee Schedule in order to:
>        ? Ensure members receiving comparable services are paying comparable 
> fees where feasible
>        ? Meet the community's expectations for new and future services such 
> as RPKI
>        ? Maintain and reduce, where possible, cost for smaller ISPs
>        ? Provide a revenue model based on long-term expenses
> "
> (This is also very similar to the information in community 
> consultation held in October 2012 on the Revised Fee schedule.)
> 
> Note that the present fee schedule does not provide an xx-small 
> size category at all, and the fees associated with the current 
> x-small category are also lowered by the Revised Fee schedule.

That doesn't really answer my question.  My question revolves around the
following *types* of questions:

o Is the fee schedule intended to be based on fairness?
o Is the goal to reduce complexity at a (reasonable?) cost of fairness?
 Or increase fairness at a reasonable cost of complexity?  If I suggest
that we tweak the fee schedule, am I going against one of the
fundamental goals of not making it "too complex" by some definition thereof?
o Is fairness determined in terms of revenue, capitalization, or just
address space?
o How do we define terms like "comparable service."  Given that ARIN
provides registration services, not addresses, how *should* "comparable
service" be defined.

>> Are we trying to provide incentives for IPv6 uptake?  For IPv4 return?
> 
> We're trying to provide more more uniform fee categories and
> introduce lower fees for both x-small and xx-small ISPs as 
> noted in the Revised Fee schedule faq.  
>
>
>> Are we trying to charge ISPs and end sites based on their size?  
>> On their profits?
>>  (Address space allocations measure neither.)
> 
> ARIN has always had fees based on relative size of organizations,
> generally based on the total address space held.  This is the case
> with both the present fee schedule and the Revised Fee Schedule. 

That may be true, but where is that codified and/or hashed out?  What is
that basic philosophy discussed and reviewed?  I am not saying it needs
to be right now, but I have a hard time understanding why we need to
contort the NRPM to patch over bad incentives in the fee schedule.

Moreover, that standard is called into question by the fact that ARIN
charges based on the larger of the two address family allocations, with
no regard to the situation where there are radical differences between
IPv4 size and IPv6 size.

What I am trying to say here is that there is huge amount of slack
between the actual implementation of the fee schedule and what it
appears to be trying to do.  So let's stop pretending that policy ought
to be beholden to the vagaries of the fee schedule and let's be willing
to tweak the fee schedule where necessary to provide the right
incentives, since we acknowledge that the fee schedule is imperfect.

That said, I disagree with the comments section of the proposal that
there is no obvious solution to the problem that still provides for
sustainability of ARIN.  One obvious possibility is to treat a /32 IPv6
allocation as a special case for ISPs: If you have both IPv4 and IPv6
allocations, and your IPv6 allocation is a /32, then your fees are based
on your *IPv4* allocation, even if it drops you into a lower fee
bracket.  If we're reserving the /32 indefinitely anyway, then I don't
think that creates a sustainability issue for ARIN.  It's still a single
allocation, so it's not costing ARIN anything more to provide a /32 but
simply charge for only the smaller IPv4 allocation.

Obviously, this would have to be revisited at the time that ARIN ceases
to provide IPv4 registration services.  But I suspect that at that
point, it would be time to revise the fee schedule anyway.

michael



------------------------------

Message: 7
Date: Sun, 7 Apr 2013 11:21:38 +0000
From: John Curran <[email protected]>
To: Matthew Kaufman <[email protected]>
Cc: "[email protected]" <[email protected]>
Subject: Re: [arin-ppml] Draft Policy ARIN-2013-3: Tiny IPv6
        Allocations for ISPs
Message-ID:
        <[email protected]>
Content-Type: text/plain; charset="us-ascii"

On Apr 6, 2013, at 10:14 PM, Matthew Kaufman <[email protected]> wrote:

> Worse, we're creating a messy IPv6 situation downstream... as Owen points 
> out, this type of financial pressure towards false conservation is going to 
> give us things like /64-per-household instead of something sensible that lets 
> the thermostat be on a different subnet than the Xbox.

Matthew - 
 
The current fee schedule reads as follows:

   IPV6 ANNUAL FEES (NOTE: FEE WAIVERS IN EFFECT), EFFECTIVE UNTIL 30 JUNE 2013
   Size Category   Fee (US Dollars)     Block Size
   Small           $2,250       /40 to /32
   Medium          $4,500       /31 to /30

   There is 25% IPv6 fee waiver in effect (this started out at 100% and
   was to be phased out over the last 4 years, although it was extended
   at the 25% discount level for this year to carry us into the Revised
   Fee schedule.)

So, any ISP using IPv6 under _today's_ fee schedule has a minimum annual 
fee of $1687 per year [$2250 * 75%] and that covers an allocation up to 
/32 of IPv6.  Unless we continue with the Revised Fee schedule, this is
effectively a minimum annual cost for any ISP making use of IPv6.

If we want to lower that cost of using IPv6 for smaller organizations, 
we need to find some manner to distinguish these smaller ISPs from all 
ISPs, and this is typically done through the total address block holdings.

At this point, ARIN can sustain some number of smaller ISPs having lower 
fees, and the Revised Fee schedule supports an ISP with no more than /20 
of IPv4 space and /36 of IPv6 being categorized as "x-small" with annual
fees of $1000/year.  This category makes IPv6 more approachable for these
ISPs but it is indeed at the downside of a smaller IPv6 allocation.  As
you are aware, /36 of IPv6 space would provide for more than 4000 /48 
and _lots_ of /56 assignments (but there would be less in practice due 
to internal hierarchy in assignment management.)

Draft Policy ARIN-2013-3, combined with the Revised Fee schedule as
corrected, would continue this approach of allowing very small ISPs
with no more than /22 of IPv4 to obtain a corresponding IPv6 allocation
of /40 and have annual fees of $500 year in the "xx-small" category.
The downside that you assert with Draft Policy ARIN-2013-3 is that 
"this type of financial pressure towards false conservation is going 
to give us things like/64-per-household instead of something sensible 
that lets the thermostat be on a different subnet than the Xbox."  

Given that any ISP qualifying as xx-small (even with wildly aggressive 
NAT) has no more 1024 customers each with a single IPv4 address, and the 
/40 IPv6 allocation would provide them with the ability to make 65K /56 
assignments to these same customers, it does seem somewhat strange that 
"false conservation" of those 65 thousand potential assignments would 
drive xx-small ISPs to instead make /64 IPv6 customer assignments.  

The community can indicate that it does not support ARIN-2013-3 if the 
resulting "false conservation" is a problem, and then there will be no use 
of the xx-small/$500/yr fee category.  Under the Revised Fee schedule, these 
ISPs would be paying at least $1000/year based on a /36 IPv6 allocation 
(which is still better than today's fees with IPv6 use as noted above.)

It would be good to hear from ISPs who would qualify for the xx-small
$500/year category about the resulting temptation that it poses for 
making smaller IPv6 customer assignments (and how they feel safer with
the /36 IPv6 minimum and corresponding $1000/year annual fee), as they 
are the ones who are most affected by the outcome of this draft policy
consideration.

Thanks!
/John

John Curran
President and CEO
ARIN





------------------------------

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