Important New Requirement for IPv4 Requests

Rich Kulawiec wrote:

If the effort that will go into administering this went instead
into reclaiming IPv4 space that's obviously hijacked and/or being
used by abusive operations, we'd all benefit.

But they can't do that without impacting revenue. In order to continue
charging fees that are wholly out of proportion to their cost ARIN must:

   A) ignore all the unneeded legacy /16 allocations, even those owned by
   organizations with fewer than 300 employees (like net.com) who could
   easily get by with a /24

   B) do nothing while IPv6 languishes due to the absence of a standard for
   one-to-many NAT and NAPT for v6 and v4/v6

   C) periodically raise fees and implement minimal measures like requiring
   someone to sign a statement of need, so they can at least appear to have
   been proactive when the impacts of this artificial shortage really begin
   to impact communications

Bottom line: it's about the money. Money and short-term self-interest,
same as is causing havoc in other sectors of the economy. Nothing new
here.

IMO,
Roger Marquis

Roger -

     A few nits:

     A) ARIN's not ignoring unneeded legacy allocations, but can't take
        action without the Internet community first making some policy
        on what action should be taken... Please get together with folks
        of similar mind either via PPML or via Public Policy meeting at
        the the Open Policy Bof, and then propose a policy accordingly.

     B) Technical standards for NAT & NAPT are the IETF's job, not ARIN's.

     C) We've routinely lowered fees since inception, not raised them.

Thanks,
/John

John Curran
Acting CEO
ARIN

Rich Kulawiec wrote:

If the effort that will go into administering this went instead
into reclaiming IPv4 space that's obviously hijacked and/or being
used by abusive operations, we'd all benefit.

But they can't do that without impacting revenue.

Well, yes, in the sense that pretty much anything an RIR does would impact their revenue one way or another.

In order to continue
charging fees that are wholly out of proportion to their cost ARIN must:

A) ignore all the unneeded legacy /16 allocations, even those owned by
organizations with fewer than 300 employees (like net.com) who could
easily get by with a /24

The term "legacy" here is relevant. Under what agreement would an RIR evaluate an allocation that occurred prior to the existence of the RIR? And when the folks who received legacy space and don't like this upstart RIR nosing around in their business, the legal fees that the RIR incur will cost non-trivial amounts of, well, money.

B) do nothing while IPv6 languishes due to the absence of a standard for
one-to-many NAT and NAPT for v6 and v4/v6

So, you'd propose the RIRs become (more) involved in the IETF? But that would cost, you know, money.

C) periodically raise fees and implement minimal measures like requiring
someone to sign a statement of need, so they can at least appear to have
been proactive when the impacts of this artificial shortage really begin
to impact communications

"Artificial"? Heh.

Bottom line: it's about the money.

Well yes, it is _always_ about the money.

Regards,
-drc

Well I'm not sure what your definitely of "routinely" is, but we've not seen in decrease in our fees any time in the past 8 years.

Chris

- ------------------------------------------------------------------------------
Chris Owen - Garden City (620) 275-1900 - Lottery (noun):
President - Wichita (316) 858-3000 - A stupidity tax
Hubris Communications Inc www.hubris.net
- ------------------------------------------------------------------------------

John Curran wrote:

A) ARIN's not ignoring unneeded legacy allocations, but can't take
action without the Internet community first making some policy
on what action should be taken... Please get together with folks
of similar mind either via PPML or via Public Policy meeting at
the the Open Policy Bof, and then propose a policy accordingly.

Thanks for the reply John, but PPML has not worked to-date. Too many
legacy interests willing and able to veto any such attempt at a sustainable
netblock return policy. Not sure how us folks, of a similar mind as it
were, would be able to change that equation. IMO this change has to come
from the top down. Towards that goal can you give us any hint as to how to
effect that?

B) Technical standards for NAT & NAPT are the IETF's job, not ARIN's.

Too true, but no reason ARIN could not be taking a more active role. This
is after all, in ARIN's best interest, not the IETF's.

C) We've routinely lowered fees since inception, not raised them.

Not raised since they were raised, granted. Not raised for large
unnecessary allocations either. Is that the job of the PPML as well?

What telecommunications consumers need here is leadership and direction.
What we see is, well, not what we are looking for.

Roger Marquis

David Conrad wrote:

The term "legacy" here is relevant. Under what agreement would an RIR evaluate an allocation that occurred prior to the existence of the RIR? And when the folks who received legacy space and don't like this upstart RIR nosing around in their business, the legal fees that the RIR incur will cost non-trivial amounts of, well, money.

Good points all. I fully admit to ignorance of how to remedy this and the
other valid points raised in defence of the status quo (except by raising
the issue when appropriate).

Not sure what could be cited as presidence either, except perhaps the
transition from feudal landowning aristocracies a few centuries back.

Roger Marquis

Except they weren't pushing to transition people to LANDv6, just fighting to determine who held control of the existing LANDv4 and its resources :slight_smile:
Not that dissimilar from what we're going through today...

jms

At this point, the community consists of far more non-legacy holders
than legacy holders. Additionally, nobody has "VETO" power other than
the ARIN Board as a body in the policy development process.

As such, I don't think that your argument quite fits the situation.

If folks of a similar mind are able to put a policy proposal together
and submit it to policy@arin.net (there's a template on the ARIN
web site), it will receive the same treatment as any other policy
proposal.

How the community as a whole reacts to the proposal is another
matter, but, if a substantial majority of the community feels the
policy proposal is a good one, then, it should be possible to
obtain consensus. If that's not the case, then, I'm not sure how
you can justify implementing such a policy contrary to the
consensus of the community.

I hope there is no way to effect a top-down policy within ARIN since
we work very hard to maintain a bottom up policy process. If there
is, then, something is very broken.

Owen

There is work happening in the behave wg of the IETF on such. We welcome operator input.

http://www.ietf.org/html.charters/behave-charter.html

Let's translate that: There is no consensus in the community who defines goals and objectives for ARIN to do Something. Can you tell me how we can hijack the process and subjugate the community to our will?

Roger -- although you'll find I'm no fan of Legacy holders and their "rights", I can't say that I follow your logic on having ARIN just "do something" against the will of the community.

I'm not sure if anyone agrees with me, but these responses seem like a big cop out to me.

A) If ARIN is so concerned about the potential depletion of v4 resources, they should be taking a more proactive roll in proposing potential solutions and start conversation rather then saying that the users should come up with a proposal which they then get a big vote one.

B) Again, while it might be the IETF's "job", shouldn't the group trusted with the management of the IP space at least have a public opinion about these solutions are designed. Ensuring that they are designed is such a way to guarantee maximum adoption of v6 and thus reducing the potential for depletion of v4 space.

C) Are ARIN's books open for public inspection? If so, it might be interesting for the group to see where all our money is going, since it's obviously not going to outreach and solution planning. Perhaps it is being spent in a reasonable manner, and the fees are where they need to be to sustain the organizations reasonable operations, but perhaps not.

Mr Curran, given the response you've seen from the group, and in particular the argument that most CEO's or Officers of firms will simply sign off on what they IT staff tells them (as they have little to no understanding of the situation), can you explain what exactly you are hoping to achieve by heaping on yet an additional requirement to the already over burdensome process of receiving an IPv4 allocation?

Shane Ronan

--Opinions contained herein are strictly my own--

Shane Ronan wrote:

C) Are ARIN's books open for public inspection? If so, it might be interesting for the group to see where all our money is going, since it's obviously not going to outreach and solution planning. Perhaps it is being spent in a reasonable manner, and the fees are where they need to be to sustain the organizations reasonable operations, but perhaps not.

A quick search of the website found this:

- Kevin

Mr Curran, given the response you've seen from the group, and in particular the argument that most CEO's or Officers of firms will simply sign off on what they IT staff tells them (as they have little to no understanding of the situation),

You really should go ask a CEO if he'd sign off on something that he doesn't understand. Really. I can assure you that your impression is wrong, and most CEOs don't prefer to be standing in court defending their actions.

can you explain what exactly you are hoping to achieve by heaping on yet an additional requirement to the already over burdensome process of receiving an IPv4 allocation?

Burdensome? Really? If you have your documentation together it takes about 15 minutes from beginning of the application form until receiving your new allocation. I spend longer on hold any time I deal with any other vendor.

It is a little out of date and not terribly detailed but they did post the 2008 budget at:

https://www.arin.net/about_us/corp_docs/budget.html

Budget is just over 13M. About 1/2 of that is salaries/benefits (maybe more if you add in 'legal fees').

A couple of interesting notes when looking at it:

12+M divided by the 3300 "members" is just shy of $4,000 per customer.

Payroll is $5,707,134 for 47 full time employees. That is an average salary of $121,428 across all employees.

Internet Research and Support is $164,500

Travel (which includes travel for board members, etc) is $1,315,349.

There is more detail but older data at:

https://www.arin.net/about_us/corp_docs/annual/2007_audited_financials.pdf

Chris

- ------------------------------------------------------------------------------
Chris Owen - Garden City (620) 275-1900 - Lottery (noun):
President - Wichita (316) 858-3000 - A stupidity tax
Hubris Communications Inc www.hubris.net
- ------------------------------------------------------------------------------

More specifically:

https://www.arin.net/about_us/corp_docs/annual/2008/

-brandon

I'm not sure if anyone agrees with me, but these responses seem like a big cop out to me.

A) If ARIN is so concerned about the potential depletion of v4 resources, they should be taking a more proactive roll in proposing potential solutions and start conversation rather then saying that the users should come up with a proposal which they then get a big vote one.

Well... ARIN is structured with a bottom-up community driven policy process. That has
served us well for many years, and, I think that changing it would be a mistake. However,
in this case, that means that the following people are specifically excluded from proposing
policy:

  The BoT (other than via the emergency process)
  ARIN Staff

Policy proposals must come from the community. Either at large, or, from the ARIN AC
which is an elected subgroup of the community tasked with developing good policy for
ARIN. The AC itself depends largely on community input for what kind of policy the
community wants us to develop, and, at the end of the day, community consensus is
required in order for a proposal to become policy.

B) Again, while it might be the IETF's "job", shouldn't the group trusted with the management of the IP space at least have a public opinion about these solutions are designed. Ensuring that they are designed is such a way to guarantee maximum adoption of v6 and thus reducing the potential for depletion of v4 space.

The IETF specifically does not accept organizational input and requires instead that
individuals participate. This is one of the great strengths, and, also one of the great
weaknesses of the IETF. However, it means that even if ARIN could develop a public
opinion (which would have to come from the ARIN community by some process which
we don't really have as yet), this opinion wouldn't mean much in the IETF's eyes.

C) Are ARIN's books open for public inspection? If so, it might be interesting for the group to see where all our money is going, since it's obviously not going to outreach and solution planning. Perhaps it is being spent in a reasonable manner, and the fees are where they need to be to sustain the organizations reasonable operations, but perhaps not.

I will leave this to the BoT to answer, but, I know that the treasurer presents a report
at every members meeting which provides at least some high level details. I believe
that as a non-profit corporation, a great deal of openness is required for accountability
to ARIN members.

Mr Curran, given the response you've seen from the group, and in particular the argument that most CEO's or Officers of firms will simply sign off on what they IT staff tells them (as they have little to no understanding of the situation), can you explain what exactly you are hoping to achieve by heaping on yet an additional requirement to the already over burdensome process of receiving an IPv4 allocation?

I can't say what Mr. Curran expects, but, here's how I see it:

1. If an officer of the organization signs off, then, that means that both the
  organization and the officer personally can be held accountable for any
  fraud that is later uncovered. If the officer is an idiot, perhaps he'll just
  sign, but, most officers I have experience with don't do that. They usually
  engage in some level of verification before signing such a statement.

2. Organizations which are submitting fraudulent requests may be less
  willing to do that when someone has to make a signed attestation under
  penalty of perjury. Especially when that person has fiduciary liability to
  the organization as an officer.

3. There are lots of things people will do if they don't think there are potential
  consequences. A signed attestation by a corporate officer dramatically
  reduces the apparent lack of consequences to a fraudulent application.

Sure, there will always be criminals and criminals may not be bothered
by this signed attestation process. However, having it does give the ARIN
legal team a better shot at them as well.

I am not a lawyer and these are just my own opinions.

Owen

12+M divided by the 3300 "members" is just shy of $4,000 per customer.

Small nit... Not all customers are members.

Owen

Jo Rhett wrote:

Let's translate that: There is no consensus in the community who defines goals and objectives for ARIN to do Something.

And there is no consensus because the process and/or community has not been
capable of the task. Design-by-committee is a problem we are all familiar
with. The resolution is to either A) apply direction from outside the
committee, B) wait until things get bad enough that they can achieve
consensus (if that is an option), or C) wait for a higher authority to step
in (as occurred recently when the DOC gave ICANN direction regarding TLDs).

Given a choice I'd take plan A. Direction could come from ARIN directors
by way of their advocacy, issuing RFCs, offering financial incentives, and
a number of other things to speed the process (of reclaiming unused IPs and
of incentivizing the IETF). Taking a hands-off position and waiting for
consensus to develop, well, that will just lead to B or C. Do you
disagree? Are there other options?

Can you tell me how we can hijack the process and subjugate the
community to our will?

Would the process survive addresses exhaustion?

Roger

So who's going to have standing to drag them into court over false declarations
to ARIN? Will ARIN be suing their members? Not likely.

   - mark

You really should go ask a CEO if he'd sign off on something that he doesn't understand. Really. I can assure you that your impression is wrong, and most CEOs don't prefer to be standing in court defending their actions.

Actually, being a CTO of a company, I know that my CEO signs things ALL the time based just on my say so. I don't see how signing a document for ARIN would land them in court, further if he were to go to court, he'd simply say that he relied on the opinions of his technical staff since he does not have the experience or expertise to evaluate it's validity. And as history shows, this is an acceptable answer, it happens all the time in the case of financial filings that others produce for the CEO to sign.

Burdensome? Really? If you have your documentation together it takes about 15 minutes from beginning of the application form until receiving your new allocation. I spend longer on hold any time I deal with any other vendor.

Really, 15 minutes? I applied for a new AS Record recently, presented all the valid documentation, as well as additional documentation in the form of network diagrams, and was asked to explain things that were clearly spelled out in the documents I provided. This entire process took DAYS.