[arin-ppml] New Policy Proposal

[Martin Hannigan]

At this time, I'm going in favor of advancing this proposal.

I support the concept, but the ARIN region contains multiple
jurisdictions and has a requirement to attempt to balance policy for
fairness across all of them. Achieving this balance by insuring that
utilization requirements are applied broadly vs. narrowly is entirely
feasible.

I would instead suggest that we address utilization holistically by
either lowering the threshold to 50% across the board or waiving them
altogether for transfers. But we're re-arranging the deck chairs as
the ship is rolling over at this point.

This proposal also brings to mind the comments that Cameron Byrne made
recently related to the definition of wireless access services e.g.
residential or commercial and their implications on utilization and
transfer. His comments should also be considered and addressed as part
of a much more generalized edit of this proposal. If we are going to
address utilization, let's do it holistically.


Best,

-M<

On Sun, Jul 29, 2012 at 1:56 AM, Owen DeLong <owen at delong.com> wrote:
> Jimmy,
>
> This is essentially a case of providers that have to allocate addresses in much the same way as cable ISPs covered under 4.2.3.7.3, but which may not be able to meet the 50% across-the-board requirement.
>
> Essentially, this isn't about a blank check, it's about addressing a squeeze created between the regulators (CRTC) and the ability of the incumbent Cable carriers to control the underlying network topology, the competitive TPIA is required to deploy addresses which may not meet current utilization requirements depending on the percentage of market they capture.
>
> As I understand it, if you have 3 competing companies in a market, for example, you are virtually guaranteed that at least 2 of them cannot meet the 50% utilization requirement.
>
> Owen
>
> On Jul 28, 2012, at 7:18 PM, Jimmy Hess wrote:
>
>> On 7/27/12, Peter Rocca <rocca at start.ca> wrote:
>>
>> This situation should fall under  4.2.3.4.2;  allocations for
>> downstream ISPs, without additional special rules.  I am not in favor
>> of giving  some ISPs  a blank check on utilization, by automatically
>> considering their usage justified,  as soon as they designated IPs for
>> their equipment.
>>
>> As an LIR / registration authority creating sub-delegations from ARIN
>> allocated resources, the "TPIA" provider (or whatever it's called)
>> should be required to maintain their sub-delegations contact records,
>> and maintain the documentation of usage, and  that the subdelegations
>> are efficiently used, based on a utilization criterion  in compliance
>> with policy,  as any other LIR has to do.
>>
>>
>>
>>> The high-level overview is that the allocation is routed to the TPIA
>>> provider who then carves it up into smaller blocks and routes them to
>>> different 'serving areas' which are geographical groupings of CMTS's. Those
>>> serving areas then have smaller DHCP pools (generally /27's or /28's)
>>> assigned at the node level. End-users are assigned IP's from the DHCP of the
>>> node they are served by. Once the space is provided to the TPIA provider the
>>> ISP no longer has control over the routing, renumbering or specific
>>> assignments within the TPIA network.
>> [snip]
>>
>> --
>> -JH
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