I think this is a good approach.

I also think we also need to recognize in the problem statement that, by
the time any new policy is adopted, almost everyone qualifying for space
under NRPM 4 will be getting it via transfer.  And in a world where
addresses are being obtained on the transfer market, strict constraints on
how quickly addresses must be used probably make less sense than they did
when most addresses were obtained via the free pool.

-Scott

On Mon, Apr 13, 2015 at 11:30 AM, David Huberman <
[email protected]> wrote:

> I am planning on submitting the following policy template to ARIN in the
> coming days.  I'd like feedback please.
>
> Template: ARIN-POLICY-PROPOSAL-TEMPLATE-3.0
> 1.Policy Proposal Name: Remove 30 day utilization requirement in end-user
> IPv4 policy
>
> 4.Problem Statement:   End-user policy is intended to provide end-users
> with a one year supply of IP addresses.  Qualification for a one-year
> supply requires the network operator to utilize at least 25% of the
> requested addresses within 30 days. This text is unrealistic and should be
> remove.
>
> First, it often takes longer than 30 days to stage equipment and start
> actually using the addresses.
> Second, growth is often not that regimented; the forecast is to use X
> addresses over the course of a year, not to use 25% of X within 30 days.
> Third, this policy text applies to additional address space requests. It
> is incompatible with the requirements of other additional address space
> request justification which indicates that 80% utilization of existing
> space is sufficient to justify new space. If a block is at 80%, then often
> (almost always?) the remaining 80% will be used over the next 30 days and
> longer.  Therefore the operator cannot honestly state they will use 25% of
> the ADDITIONAL space within 30 days of receiving it; they're still trying
> to use their older block efficiently.
> Fourth, in the face of ARIN exhaustion, some ISPs are starting to not give
> out /24 (or larger) blocks.  So the justification for the 25% rule that
> previously existed (and in fact, applied for many years) is no longer
> germane.
>
> 5.Policy statement: Remove the 25% utilization criteria bullet point from
> NRPM 4.3.3.
> 6.Comments:
> a.Timetable for implementation: Immediate
> b.Anything else
>
> END OF TEMPLATE
>
> Thank you,
> David
>
> David R Huberman
> Principal, Global IP Addressing
> Microsoft Corporation
>
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