[arin-ppml] Draft Policy ARIN-2014-20: Transfer Policy Slow Start and Simplified Needs Verification
David.Huberman at microsoft.com
Mon Sep 22 05:12:40 EDT 2014
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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