I don't support this proposal.  I believe if restrictions are removed, then 
both End User and ISP should be aligned entirely.  One policy for all.

Regards
Marla Azinger

-----Original Message-----
From: [email protected] [mailto:[email protected]] On Behalf 
Of ARIN
Sent: Tuesday, May 26, 2015 11:58 AM
To: [email protected]
Subject: [arin-ppml] Draft Policy ARIN-2015-3: Remove 30 day utilization 
requirement in end-user IPv4 policy

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

On 21 May 2015 the ARIN Advisory Council (AC) accepted "ARIN-prop-217 Remove 30 
day utilization requirement in end-user IPv4 policy" as a Draft Policy.

Draft Policy ARIN-2015-3 is below and can be found at:
https://www.arin.net/policy/proposals/2015_3.html

You are encouraged to discuss the merits and your concerns of Draft Policy 
2015-3 on the Public Policy Mailing List.

The AC will evaluate the discussion in order to assess the conformance of this 
draft policy with ARIN's Principles of Internet Number Resource Policy as 
stated in the PDP. Specifically, these principles are:

   * Enabling Fair and Impartial Number Resource Administration
   * Technically Sound
   * Supported by the Community

The ARIN Policy Development Process (PDP) can be found at:
https://www.arin.net/policy/pdp.html

Draft Policies and Proposals under discussion can be found at:
https://www.arin.net/policy/proposals/index.html

Regards,

Communications and Member Services
American Registry for Internet Numbers (ARIN)


## * ##


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
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