I oppose the proposed policy as currently drafted. The notion of a /16 being "small" is ludicrous. By the time you need a /16, you have enough staff to handle tracking your SWIP/rwhois data for your customers, and justifying needs is just part and parcel of running your business.
I would support a modified version of the policy that stipulated a single needs-free transfer of a /22 per year per org-ID as a means to help support truly small entities getting going. I would further encourage a cap; such needs-free transfers would only apply to org-IDs so long as they remain in the "small" category based on overall cumulative holdings. Once an org-ID exceeded the total holdings allowed in the "small" category, it's time to trade in the diapers for the big-boy pants, and track your utilization and show demonstrated need over time. Thanks! Matt
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