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. _______________________________________________ PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: http://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.