Regarding TPIA and MDN, John wrote:
> If it were to be adopted, it would provide for any organization at 80%
> overall utilization
> to transfer at least as much address space as is presently held.
If I have a MDN buildout in Toronto, Calgary, Montreal, Winnipeg, and
Vancouver, and Toronto hit 85% quickly and needs more space, but the other
sites aren't at 80%, I'm not going to be at 80% overall utilization. TPIA
examples are even more complex, as they deal with more granular buildouts.
2014-20 should not attempt to simplify this, as there are operational realities
that should not be ignored.
Regarding forward-looking projections, John wrote:
> Correct, but that flexibility comes at a cost, as it creates a burden of
> demonstrating
> your projected need via an inherently a manual process of engagement and
> review
> with ARIN staff.
ARIN staff have been performing this since 8.3 was created, and in general,
since the beginning for end-users. In my experience, this step has rarely been
the holdup if transfers or end-user requests are taking time. There are
exceptions, of course, but that's life running a registry, no?
WRT new-entrants, John writes:
> The new entrant situation is a a very important one to consider, but the
> draft policy
> appears to provide language specifically covering new organizations with
> ability for
> them to transfer space so long it will be at least 50% utilized on receipt.
> Is that not sufficient?
It is not, and it is grossly inequitable. You don't plan and build a network
with the intent of using
50% of the requested address space "upon receipt". You have a responsibility
to your colleagues,
your customers, and your investors to plan and build for the future - one and
two year (and longer)
timeframes if possible.
For 17 years, ARIN policy has severely penalized new entrants in a way that
protects incumbents.
Unlike the RIPE and APNIC model, which treats everyone the same at the
beginning ("you can have
a /20 just by opening an LIR account, no questions asked"), ARIN PPML continues
to treat small
and new companies inequitably.
I reiterate my main point: there is nothing wrong with the current 8.3
language that says ARIN staff
shall accept a 24-month horizon. It is fair, and your own Counsel tried to
make this 36-months.
> Present transfer policy will effectively preclude new entrants from obtaining
> any IPv4 address space
> via transfer (unless they can somehow first get resources allocated from
> their upstream ISPs during
> this time of increasing scarcity), so continued thinking and discussion on
> solutions would indeed be prudent.
A simple fix solves this: remove the "25% immediately" from 8.3.3 and continue
the staff practice of
interpreting "50% within one year" as "50% within two years". It's sound
math, consistent with the
original RFC2050's intent of proper conservation.
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