[arin-ppml] LAST CALL for Recommended Draft Policy ARIN-2015-3: Remove 30 day utilization requirement in end-user IPv4 policy

John Curran jcurran at arin.net
Thu May 12 16:11:29 EDT 2016

On May 12, 2016, at 4:03 PM, Jason Schiller <jschiller at google.com> wrote:
> I am surprised that staff would not apply the 30 day need (albeit extended to 60 day need) for end-sites requesting a transfer.
> My understanding is that 8.3 references "demonstrating need" "under current policies" albeit extended to 24 months (double an ARIN assignment).
> Current policy 4.3.3 defines meeting 25% utilization immediately (30 days) and 50% within 1 year.  
> Extended this doubles the values.
> This is also seems to be consistent with what I heard at the meeting:
> "Kevin Blumberg:  The question was, to clarify for everybody, when it comes -- this policy is in reference to free pool space. When you take into account that almost every request will now be based on transfer via 8.3 or 8.4, which has a 24-month, can you explain how staff calculates in transfers versus what -- when somebody is just reading and saying 25 percent over 30 days, how does that now work with a 24-month transfer?
> John Curran:  It still requires them to use 25 percent of the block being transferred. Now, this is the unfortunate circumstance of having transfer policies which chained to needs assessment which come from allocation and assignment policies in elsewhere in the NRPM.
> When the AC has some free time, if it would like to unwind those, that would be greatly appreciated."
> I trust ARIN is very good at finding fraud and abuse, however I think this change makes fraud and abuse (or as Owen put it simply having dreams of grandeur [note this was wrt 2015-9 but it applies equally here].)  makes it much harder to catch as per Jonh's comments when discussing this policy.
> "John Curran:  We can go back on the present policy and confirm that someone has done the utilization that they claim they do, but it's much more difficult to know whether or not someone has made a fraudulent request if we don't check shortly after we've assigned to them.
> In other words, someone will find address space utilization within a year one way or the other. But whether or not they're valid for what we assigned is much easier to determine if they've made use of it within the first 30 days, or 30 days, 60 days, the immediate future."
> Can staff comment do you apply the 25% need in 60 days to specified transfers?  Or is this ignored and obsolete? 

Jason - 
   ARIN does not, by default, go back to the organization afterwards and confirm that 
   they have met the 25% utilization requirement, but organizations must conform to 
   policy and thus it remains a valid criteria if we should review a request later (e.g. 
   as a a result of a fraud report.) 


John Curran
President and CEO

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