[arin-ppml] Draft Policy ARIN-2014-9: Resolve Conflict Between RSA and 8.2 Utilization Requirements

[John Curran]

On Mar 21, 2014, at 2:04 PM, Matthew Kaufman <matthew at matthew.at> wrote:

> I don't see a *documented* 40% abandon rate on 8.2 transfer requests as "fear mongering". I strongly suspect that every single one of those abandoned requests is a case where a M&A *actually happened* and yet, because it was abandoned, the registry no longer accurately reflects that M&A activity. (I really can't imagine anyone who would simply, for entertainment value, file 8.2 M&A transfer requests when no M&A has occurred.)

Actually, as noted earlier, it is quite common for parties to 
start an transfer request when there is no M&A activity.  We 
get those from folks who are simply the contacts on an address 
block (which may or may not be legitimate depending on the actual
origin of the block, e.g. was it assigned to a DBA entity of the
contact which somehow has morphed over time and is now operating 
under another name?); it occurs when organizations that think 
they were permanently assigned address space from their ISP come
to "update it" to their most recent organization name; and it 
happens when companies come in to clean up their long-neglected
records, as was noted previously.  All of these may result in 
what looks to be an NRPM 8.2 transfer request without any actual
recent M&A activity.

In the case where there has been an actual M&A transfer, ARIN works
very hard (as Gary Buhrmaster noted in his earlier message) with the
requestor to get the records updated, and with out-of-date records
this can indeed involve several validation steps to make sure that 
we're not updating the registry in error.  There are also those 
who may get nervous during the registration service agreement and
utilization discussion who decide that the effort or risk is not
worth continuing the process.

None of this is a recommendation for keeping the present policy,
but simply to make sure that community understands how the 40% NRPM 
8.2 abandonment rate number covers quite a range of circumstances.  
Note that ARIN is unlikely to be able to provide any more detailed 
objective measures, as the counts of "those who actually had past
M&A activity and then abandoned due to the effort" compared to the 
counts of "those who claimed M&A activity and then abandoned due to 
the effort" (i.e. actually a hijacking deterred) are the same 
transaction when viewed from ARIN's side.

FYI,
/John

John Curran
President and CEO
ARIN