This was proposal number one for OPERATIONAL changes to ARIN's functional allocation policies. Note that this gets us to an objective, neutrally-verified criteria that allows, IMHO, all organizations with a legitimate use for PI space to have it. I am expanding the discussion list to NANOG and the ARIN Members mailing lists. Please post comments PUBLICALLY, or if you feel you cannot do so without "cloaking" yourself, through someone else (who you trust to strip the attribution). FIRST PROPOSAL: 1) The allocation policy of ARIN should be changed to reflect that any organization which can demonstrate that it can constructively use PI space should be able to receive it. "Constructively demonstrate" is stated to mean: a) The organization is multi-homed, possesses an ASN, and two or more independant T1-or-above rate connections to more than one backbone or other carrier (ie: to an exchange, to a NSP, to other ISPs). Documentation in the form of a signed connectivity agreement for a period of at least one year, or connectivity provable via existing network tools (ie: treno) is sufficient to satisfy this requirement. b) The ASN is visible at industry-accepted peering points and shows multiple paths available (ie: "nitrous.digex.net") c) The organization is EITHER: 1) Engaged in the business of selling connectivity to the general public, or can otherwise document a REASONABLE expectation that at least 75% of the /19 will be fully utilized at some point in the future during the expected lifetime of the IPv4 space (defined as 10 years). The firm must be able to prove this without resorting to a claim of confidentiality; in other words, you must be able to show that you're in the business of doing this from your public, visible, documentable actions. OR 2) The firm contains enough employees, staff members, and EXTERNALLY ADDRESSABLE infrastructure equipment within its boundaries to qualify for efficient use of a /19 on its own (ie: more than 5,000 staff members). 2) To receive MORE space, regardless of the size of the organization, the requestor must document that more than <X>% of the existing space allocated to it is either; a) In use internally; OR b) Delegated to actively visible customers who actually use said IP address space. An IP address shall be deemed to be "constuctively used" if any of the following apply to it at the /32 level: a) It responds to a PING or other network packet addressed to it when queried. b) It is properly referenced in both forward and reverse DNS files, and the hostname is traceable and billable to a customer who has ongoing revenue associated with same. (ie: an ISDN connectivity provider sells a class of service which has a /29 associated with it; they generate hostnames for all 8 addresses, and the customer is routed behind those addresses). c) It is a member of a operational DCHP or other dynamic pool, and is properly referenced in both forward and reverse DNS maps. d) It is delegated to a dedicated circuit or other routed business customer, and is part of a block of no more than 64 addresses assigned to that customer. Network broadcast addresses (defined as "all ones" host components) are excluded from these requirements, as are "all zeros", since some equipment demands that the "zeros" address remain). The value for "X%" shall be set by discussion within the AC and ratified by vote. All organizations must prove up use in all blocks delegated to or through them in order to receive any further delegation of space. I recommend that the value of "X" be set somewhere between 50 and 70%. This provides for some "slop", particularly in dedicated circuit customer situations (which are going to have some slop). However, it also prevents the practice of assigning a /24 to a customer who has five computers in their office - a practice which is extremely common! 3) A delegate producing documentation for classes of service (a - c) above may not claim privilege for these classes of information, as such is discernable from an external connection. 4) A delegate producing documentation for classes of service (d) may claim privilege as to the identities of the organizations involved, and may redact that information from their submissions, however, the actual allocations themselves must be documented. 5) All submitted documentation and prove-up performed under these policies are public information and subject to challenge by any member of the Internet community. -- -- Karl Denninger (karl@MCS.Net)| MCSNet - Serving Chicagoland and Wisconsin http://www.mcs.net/ | T1's from $600 monthly / All Lines K56Flex/DOV | NEW! Corporate ISDN Prices dropped by up to 50%! Voice: [+1 312 803-MCS1 x219]| EXCLUSIVE NEW FEATURE ON ALL PERSONAL ACCOUNTS Fax: [+1 312 803-4929] | *SPAMBLOCK* Technology now included at no cost