Dear Mr Loubser,
At 06:56 PM 29-09-2018, Coenraad Loubser wrote:
I would like to add that we wholeheartedly support the current recommendations - and that they do perhaps provide enough of a platform to address the issue.

Thank you for the feedback on that section.

The caveat is that, for an LIR, there is still the initial hurdle to cross, that has not been "smoothed out", and which the suggested provision can "smooth out" - which I would like to unpack more.

I'll comment below.

Also, the addition of a clause such as the revenue-based one proposed could potentially free up the board and/or CEO from having to consider a number of individual applications - something that could also be a restricting factor if the opportunities for such reviews are spaced too far apart, or if they turn out to be too time consuming. Ie. if an ISP is starting up, and can be convinced to get its own ASN, but has to wait some months before it can actually get it, it might just start without it and conclude that it's not really necessary - and only revisit the benefits much later when truly necessary - or never.

Is the time taken for getting approval for a discount a major factor for getting a new LIR to have its own ASN? It looks like the other parts of setting up the operation could take more time; I am assuming that there isn't sequential processing.

I suppose that there is another side to this is - and that is the possibility for "fly-by-night" ASNs - or ones created to be used for nefarious purposes and then discarded. although I am not sure if there is a blanket control for the board to reject an any application, is there? Then again, going through the trouble of setting up a company, licensing it, getting the financials in place, and applying for the concession, setting up peering - is likely enough of a deterrent.

ASN requests are handled by the member services department. The policies which are used to evaluate the requests are set by the Policy Development Working Group. I could not think of a reason to be involved in a decision about the approval of such a request. As a comment about "blanket control", the usual approach at Board-level is to see that there are adequate organizational processes.

Regards,
S. Moonesamy

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