[arin-ppml] 8.2 Transfers at ARIN

David Huberman David.Huberman at microsoft.com
Mon Dec 9 18:43:50 EST 2013

I wrote:

> Thank you for the stats.  They mostly tell the story I was thinking they would:  
> a very low approval and completion rate.  

John Curran replied:

> It's not often that I see >50% characterized as a "very low" percentage rate.
> If one is presuming that 100% should be approved, then that characterization
> makes sense. Given that a number of NRPM 8.2 applicants have been shown to be
> not in good faith during the application process, I am quite pleased that the
> completion rate is less than 100%.

I guess I see it differently than you.  I don't believe bad faith requests are a 
meaningful proportion of the 37% of 8.2 transfer requests which went 
unapproved in 2013 so far.  

During my 14 years of experience on both sides of the ARIN request desk, and 
watching Public Policy events for most of that time, it's clear to me that large
swaths of 8.2 transfers go unapproved because the requestor abandons them. 
Many of the requests are abandoned because some combination of policy and 
procedure is considered too onerous and "not worth it" by the requestor. 

This opinion doesn't at all reconcile with your next paragraph, hypothesizing 
that the increase in numbers is due to deterrence measures and increased 
8.2/8.3 cleanups.  I guess we don't agree on what's going on in the 8.2 
transfer arena.

John Curran also wrote:

> There are other ways to increase the NRPM 8.2 request approval ratio (if that is a 
> desirable goal); however, it is not clear that setting such a goal would contribute
> at all in "making Whois more accurate" as postulated in your early message.

Well, I guess we're disagreeing again.  Because as a customer and a former staffer,
I believe Whois records are grossly out-of-date because of both abandoned transfer
requests (at both approval and completion phases) and because of a desire to not
put oneself through the onerous policy and procedural requirements ARIN presents.
For years we know empirically that requestors were dismotivated from requesting
8.2 transfers to clean-up records in Whois because they were fearful of ARIN reclaiming
parts of their /16s (or what-have-you) which were underutilized (even though no such
process existed).  More policy work on this front is needed, especially as the RSA and
ARIN policy seem to be out of alignment. That policy work, combined with changes in
procedures, hopefully leads to easier 8.2 transfers for requestors, and in turn, more 
accuracy in Whois records.

So I guess going forward, I'll again say thank you for providing statistics promptly, and
I'll start making proposals to align section 4.2, 8.2, 8.3, and 8.4 in a way that I hope 
makes sense for network operators and operations in 2014 and beyond.

David R Huberman
Microsoft Corporation
Senior IT/OPS Program Manager (GFS)

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