John,

1) how many 8.3 transfers have been approved as of 30 April 2016?

2) of those, how many were reviewed and verified with the explicit requirement 
that 25% of the requested space to be transferred-in would be used immediately?

David

> On May 12, 2016, at 4:11 PM, John Curran <[email protected]> wrote:
> 
>> On May 12, 2016, at 4:03 PM, Jason Schiller <[email protected]> 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.) 
> 
> Thanks,
> /John
> 
> John Curran
> President and CEO
> 
> 

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