> On 9 May 2016, at 11:37, Fabio Zannicolò - Voix s.r.l. <f...@voixit.com> 
> wrote:
> 
> Today small companies have competitiveness problems due to lack of IPv4 
> resources.

Tough. We’re out of IPv4. We’re all struggling due to a lack of IPv4 resources. 
Everyone just has to make the best of it with whatever they have now. Anyone 
planning to grow their network using IPv4 simply cannot base their plans on 
repeatedly going to the NCC and asking for more. It’s that simple.

Let’s suppose 2015-05 is adopted. We quickly burn through the remaining IPv4 
pool because some LIRs continue to grow their IPv4 networks instead of coming 
to terms with the end of IPv4. At that point, those LIRs will have a very nasty 
shock. There would literally be no IPv4 remaining at the NCC. So these LIRs 
will then be forced to do something else: use NAT, deploy IPv6, use ALGs, buy 
addresses on the secondary market, whatever. These LIRs could and should be 
doing that "something else" now. They’re going to *have* to do it eventually 
and might as well start now if they’ve not already done that.

These LIRs surely know today that they cannot continue with a model that 
assumes they can issue IPv4 addresses forever or go back to the NCC and get 
more. So all these LIRs would have achieved with 2015-05 is buy themselves a 
little extra time to persist with a doomed model that they already know no 
longer works. At that point the NCC would have no IPv4 left for any future 
entrants who will need some IPv4 to connect to the legacy v4-only Internet.

Burning through what’s left of IPv4 for the short-term benefit of LIRs who 
can’t/won’t face up to the exhaustion of IPv4 seems wrong to me. Future 
entrants would not thank us for frittering away those resources. They’ll need 
some IPv4 too. We should think about their needs too. Our IPv4 address policies 
can’t ignore that in favour of some what appears to be mistaken/misguided 
short-term benefit and self-interest.

The NCC will reach IPv4 exhaustion point of course. The current policy ensures 
this happens much later than it would than if 2015-05 was adopted. That is a 
Good Thing. And that is more than enough reason to reject 2015-05.

> I consider unfair the current treatment, the big companies have stocks of 
> IPv4 addresses.

The holders of those resources got them as a result of the prevailing 
allocation policies at that time. Apart from the implementation detail of the 
size of the allocation an LIR gets, this is exactly the same as how requests 
from those who apply today get IPv4 addresses according to the allocation 
policies which are in use now.

BTW I can’t travel back in time to buy the ticket which would have won 
yesterday’s lottery. That’s unfair too.

> We need a balance between resource conservation and fair treatment

IMO the existing policy already achieves that. 2015-5, if adopted, does not.

> in addition to those already proposed my suggestions are:
> 
> -allocations of a /22 every 18 months only from IPv4 Addresses Available 
> Outside 185/8 to small LIRs (if LIR own < /20 of total allocations)

That’s discriminatory. It’s unfair on those LIRs who have a /20 or greater.

> -leave the current policy only for IPv4 Addresses Available in 185/8 to avoid 
> the too fast depletion of resources

No. 185/8 should not be treated as “special”. The current last /22 policy 
applies to all IPv4 blocks at the NCC. That policy kicked in as soon as the NCC 
made its first allocation from 185/8, the last /8 it got from IANA.

> -the addresses acquired with this system should not be able to be transferred 
> for a long period of time to avoid profit

Define “long period of time” and “profit”.

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