Hi John,

My biggest argument against this is that this encourages abusive squandering of IP space, in order to get more. Especially for anyone who wants to own as much as possible 'real estate'.

Ie an operator can use this as a vehicle, say they get a /16. Their mandate is then to fill it up as fast as possible. So they 'rent' space to anyone they can, eg affiliate email marketers, or any use that can sneak by being recognized as 'used'.

Hit 80% aggregate and you get more, rent it out... (it doesn't even matter if it is done profitably, that isn't the goal here)

With diminishing IP Space, if there was some way to set standards on what usage qualifies on 80% usage, I could get behind it.

But we are already seeing what appears to be this activity amongst hosters ("..get it used, I don't care what for..")

I know, I can't think of a way to set those standards that the community can get behind, so I am sure ARIN can't ;)

All I am saying, is that anything that encourages or allows for the larger players to 'land grab' isnt' in the best interests of the community either.

I think that this will encourage the incumbants, at the expense of new entrants, and those looking to 'land grab' more than the existing policies, and thus I am against this policy change.

However, we don't want to disadvantage someone just because they have been successful either.

I think we need another idea to come up..

Jeffrey -
   For sake of argument, imagine a large ISP which over the course of
time has
   ended up with a /8, two /16, and a /14 IPv4 blocks (with the /14
being the most
   recently issued block because of nearly full utilization of all prior
blocks at the
   time.)
   Under present policy, the ISP cannot request address space until they
have
   brought the utilization of the most recently issued block (the /14)
up to 80%.
   Under the proposed policy, the ISP is immediately eligible to request
space,
   since their aggregate utilization (even with a completely unused /14)
is going
   to be very high (potentially as much as 97% due to the fully-used /8
block.)

   The proposed policy allows organizations to request space so long as
their
   aggregate utilization is higher than 80%, and this means many existing
   organization with large IPv4 holdings will suddenly qualify to
receive an
   additional allocation if they choose to request it.  Whether that is
desirable
   or not is a matter for the community to decide.

FYI,
/John

John Curran
President and CEO
ARIN




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