Apologies to the list.  The actual text of draft ARIN-2015-3 did not attach 
correctly.

The current draft text can also be located at: 
https://www.arin.net/policy/proposals/2015_3.html

--

Draft Policy ARIN-2015-3
Remove 30 day utilization requirement in end-user IPv4 policy

Date: 26 May 2015

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 removed.

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.

Policy statement:

Remove the 25% utilization criteria bullet point from NRPM 4.3.3.

Comments:

a.Timetable for implementation: Immediate

b.Anything else




-----Original Message-----
From: Leif Sawyer 
Sent: Tuesday, September 08, 2015 11:10 AM
To: [email protected]
Subject: Draft Policy ARIN-2015-3: Remove 30-Day Utilization Requirement in 
End-User IPv4 Policy

ARIN Legal and Staff have conducted a review of Draft Policy 2015-3.

ARIN Advisory Council are seeking any additional feedback on this draft policy, 
prior to public discussion at ARIN 36 in Montreal next month.


The text of the staff review is below:
___

Date of Assessment:  18 August 2015
___
1.  Summary (Staff Understanding)
 
This proposal would remove the 25% utilization (within 30 days of issuance) 
criteria bullet point from NRPM 4.3.3.

___
2.  Comments
A.  ARIN Staff Comments
 
This policy would more closely align with the way staff applies the existing 
policy in relation to 8.3 transfers. Because there is no longer an IPv4 free 
pool and many IPv4 requests are likely to be satisfied by 8.3 transfers, the 
adoption of this policy should have no major impact on operations and could be 
implemented as written.
 
Note that both NRPM 4.3.3 and NRPM 4.2.3.6 contain references to obsolete RFC 
2050.  Additionally, 4.2.3.6 references the 25% immediate use (within 30 days 
of issuance) requirement.
 
Staff suggests removing the first two sentences of 4.2.3.6 to remove the 
references to RFC 2050 and the 25% requirement.  Additionally, staff suggests 
removing the reference to the obsolete RFC 2050 in section 4.3.3.
 
B.  ARIN General Counsel – Legal Assessment

No material legal risk in this policy.

___
3.  Resource Impact
 
This policy would have minimal resource impact from an implementation aspect.  
It is estimated that implementation would occur immediately after ratification 
by the ARIN Board of Trustees. The following would be needed in order to 
implement:
 * Updated guidelines and internal procedures
 * Staff training
___



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