[arin-ppml] Draft Policy ARIN-2014-20: Transfer Policy Slow Start and Simplified Needs Verification

[David Huberman]

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.